May 29, 2020

To our clients and friends:

On May 23, 2020, the U.S. Small Business Administration (“SBA”) issued two interim final rules (the “Interim Final Rules”) related to the forgiveness of loans originated under the SBA’s Paycheck Protection Program (the “PPP”). The first Interim Final Rule provides the requirements for loan forgiveness, which includes instructions for properly completing the PPP Loan Forgiveness Application for borrowers. The second Interim Final Rule describes the SBA’s procedures for reviewing PPP loan and forgiveness applications.

Our Alert summarizes both sets of Interim Final Rules, which are effective immediately. Yesterday, the House of Representatives passed a bipartisan bill that would change key PPP loan forgiveness provisions. The Senate has put forth a similar bill, but it has not yet passed. As a result, it is very likely that the Interim Final Rules will be further modified. We are closely monitoring these developments and will provide updates as appropriate.

Our Alert is available here.

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