On October 2, 2020, the U.S. Small Business Administration (SBA) released a Procedural Notice (the Procedural Notice) that provides a framework to determine whether SBA consent is required for various changes of ownership of an entity that has received Paycheck Protection Program (PPP) funds (each, a PPP Borrower). Although the Procedural Notice was addressed to all SBA employees and PPP lenders, the guidance will ultimately impact any PPP Borrower considering a potential change in control, as well as anyone contemplating acquiring control of a PPP Borrower.