On April 6, 2020, the Small Business Administration (the “SBA”) in consultation with the Department of the Treasury released additional guidance reflecting the implementation of the Paycheck Protection Program (“PPP”) of the CARES Act in a Frequently Asked Questions (FAQs) format (the “FAQ”), and plans to update the guidance regularly. You can find the FAQ here. The FAQ makes clear that borrowers and lenders may rely on the guidance available at the time of their applications’ submission or approval so are not required to revise applications based on these FAQs. Going forward, we recommend that all borrowers consult the Department of Treasury’s website for current guidance before making an application.
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