Since our last update describing changes made to the Paycheck Protection Program (the “PPP”) by the Paycheck Protection Program Flexibility Act of 2020 (the “PPPFA”), which was signed into law by President Trump on June 5, 2020, the U.S. Small Business Administration (the “SBA”) has published numerous revisions to prior interim final rules (“IFRs”) it had released to govern implementation of the PPP with respect to eligibility requirements, disbursement, loan forgiveness and loan review to conform to the PPPFA and clarify certain requirements set forth therein. Generally, the PPPFA provides PPP loan borrowers additional time to incur costs that count towards PPP loan forgiveness, reduces the portion of such costs that must be payroll costs, provides additional exemptions from the CARES Act’s (as defined below) loan forgiveness reduction provisions and extends the deadline to rehire workers in order to remain quali?ed for full forgiveness.
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