On March 3, 2021, the Small Business Administration (SBA), in conjunction with the U.S. Department of the Treasury, adopted an interim final rule (IFR) that: (1) allows individuals who file an IRS Form 1040, Schedule C to...more
3/16/2021
/ Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
Eligibility ,
Interim Final Rules (IFR) ,
Loan Applications ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Popular ,
SBA ,
Small Business ,
U.S. Treasury
On December 28, 2020, former President Trump signed the Consolidated Appropriations Act. Over 5,000 pages in length, the legislation (referred to herein as the Economic Aid Act) included revisions and additions to the...more
On December 28, 2020, former President Trump signed the Consolidated Appropriations Act. Over 5,000 pages in length, the Act included revisions and additions to the Paycheck Protection Program (PPP). The new PPP will: (1)...more
On December 28, 2020, President Trump signed the Consolidated Appropriations Act. Over 5,000 pages in length, the Act included revisions and additions to the Paycheck Protection Program (PPP). The new PPP will (1) accept...more
1/6/2021
/ Borrowers ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
Economic Injury Disaster Loans ,
Federal Loans ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Relief Measures ,
SBA ,
Small Business ,
Tax Credits
In November 2020, the Small Business Administration (SBA) issued for comment two questionnaire forms, which would need to be provided by Paycheck Protection Program (PPP) lenders to PPP borrowers who, together with their...more
The Small Business Administration (SBA) is seeking comments on two forms of questionnaires: Form 3509 (Loan Necessity Questionnaire for For-Profit Borrowers) and Form 3510 (Loan Necessity Questionnaire for Non-Profit...more
Paycheck Protection Plan (PPP) loans are Small Business Administration (SBA) Section 7(a) loans. Consequently, they are subject to the same regulatory guidelines that generally apply to Section 7(a) loans....more
9/5/2020
/ Acquisitions ,
Approval Requirements ,
Borrowers ,
Buyers ,
Change of Ownership ,
Consent ,
Due Diligence ,
Lenders ,
Mergers ,
Paycheck Protection Program (PPP) ,
Popular ,
SBA ,
Small Business Loans
The Main Street Lending Program has been modified by the Federal Reserve Board (Board) to provide new access to credit for nonprofit organizations such as educational institutions, hospitals, and social service organizations....more
8/1/2020
/ 501(c)(19) ,
501(c)(3) ,
Borrowers ,
CARES Act ,
Compliance ,
Contract Terms ,
Coronavirus/COVID-19 ,
Eligibility ,
Federal Reserve ,
Hospitals ,
Interest Rates ,
Lenders ,
Loan Agreements ,
Main Street Lending Programs ,
Midsize and Large Business Loans ,
Nonprofit Organization Expanded Loan Facility (NOELF) ,
Nonprofit Organization New Loan Facility (NONLF) ,
Relief Measures ,
Social Services ,
Tax Exempt Entities ,
Universities
Last month, the U.S. Treasury and the Small Business Administration (SBA) released two Paycheck Protection Program (PPP) loan forgiveness applications. The first was a new EZ PPP loan forgiveness application with instructions...more
7/17/2020
/ Applications ,
Borrowers ,
CARES Act ,
Certifications ,
Coronavirus/COVID-19 ,
Full-Time Employees ,
Independent Contractors ,
Lenders ,
Loan Forgiveness ,
Pay Reductions ,
Paycheck Protection Program (PPP) ,
Required Documentation ,
SBA ,
Self Employed ,
Sole Proprietorship ,
U.S. Treasury
The U.S. Treasury and the SBA released two Paycheck Protection Program (PPP) Interim Final Rules on June 17, 2020 and June 22, 2020. A summary of the key points of these rules follows below....more
7/16/2020
/ Amended Rules ,
Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
Covered Entities ,
Full-Time Employees ,
Interim Final Rules (IFR) ,
Loan Applications ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
SBA ,
Small Business Loans
On June 8, 2020, the Federal Reserve Board (Board) announced an expansion of the scope and eligibility for its Main Street Lending Program. The Board also issued an updated FAQ for the program on June 9, 2020.
Under the...more
6/16/2020
/ Borrowers ,
CARES Act ,
EBITDA ,
Economic Injury Disaster Loans ,
Eligibility ,
Federal Reserve ,
Libor ,
Loan Forgiveness ,
Main Street Lending Programs ,
Main Street New Loan Facility ,
Paycheck Protection Program (PPP) ,
Small Business Loans ,
Special Purpose Vehicles
On May 22, 2020, the Small Business Administration (SBA) and the U.S. Department of the Treasury released an Interim Final Rule on Paycheck Protection Program (PPP) Loan Forgiveness (the "Loan Forgiveness Rule"). Although...more
In the past few weeks, the U.S. Department of Treasury and Small Business Administration (SBA) have raised issues concerning the economic uncertainty certification made by both public and private companies in FAQs #31 and...more
5/15/2020
/ Borrowers ,
CARES Act ,
Certification Requirements ,
Coronavirus/COVID-19 ,
Good Faith ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Returned Funds ,
Safe Harbors ,
SBA ,
SBA Lending Programs
On April 30, 2020 the Federal Reserve Board (the "Board") announced an expansion of the scope and eligibility for its Main Street Lending Program.
Under the three Facilities—the Main Street New Loan Facility (the "New...more
5/13/2020
/ Borrowers ,
CARES Act ,
Certification Requirements ,
Compliance ,
Credit Unions ,
EBITDA ,
Eligibility ,
Employee Retention ,
Federal Reserve ,
Financial Stimulus ,
Lenders ,
Loan Origination Funds ,
Main Street Lending Programs ,
Midsize and Large Business Loans ,
Relief Measures ,
Small Business Loans ,
Special Purpose Vehicles
PPP Loan Forgiveness is Criticized, Guidance is Forthcoming -
Audits of PPP Loans in Excess of $2 Million -
On April 28, 2020, U.S. Secretary of Treasury Steven Mnuchin announced that all Paycheck Protection Program...more
The CARES Act established the Paycheck Protection Program ("PPP" or "Program"), which provides nearly $350 billion in forgivable loans designed to keep workers employed during the COVID-19 crisis. In this alert, we are...more
4/15/2020
/ Borrowers ,
Economic Injury Disaster Loans ,
Lenders ,
Loan Agreements ,
Loan Applications ,
Loan Forgiveness ,
Main Street Lending Programs ,
New Guidance ,
Paycheck Protection Program (PPP) ,
Popular ,
SBA