News & Analysis as of

Small Business Loans Interim Final Rules (IFR)

Ballard Spahr LLP

CFPB Releases Interim Final Rule Extending 1071 Compliance Dates

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On June 25th, the CFPB issued an interim final rule with a request for public comment extending the compliance dates for the Small Business Lending Rule in light of the Supreme Court’s decision finding the funding structure...more

Buchalter

CFPB Issues Spring 2023 Agency Rule List

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As a part of Federal agencies’ issuance of their semi-annual Spring 2023 Regulatory Agenda, the CFPB has published its Spring 2023 Agency Rule List (“2023 List”). In that List, the CFPB has set forth the status of its...more

Manatt, Phelps & Phillips, LLP

SBA Issues New Guidance on Loan Forgiveness

About the Interim Final Rule - On January 19, 2021, the Small Business Administration (SBA) published new Loan Forgiveness Requirements and Loan Review Procedures pursuant to an Interim Final Rule, or IFR (the PPP...more

Sheppard Mullin Richter & Hampton LLP

Paycheck Protection Program: SBA Issues Guidance on First Draw and Second Draw PPP Loans and Releases PPP Applications Pursuant to...

On January 6, 2020, the SBA published its 26th Interim Final Rule (the First Draw PPP IFR) and 27th Interim Final Rule (the Second Draw PPP IFR)[1] with respect to the Paycheck Protection Program (PPP), as reauthorized and...more

Downs Rachlin Martin PLLC

New SBA Guidance on the PPP Changes and Second Draw PPP Loans

On December 27, 2020, a new COVID-19 relief bill, the Consolidated Appropriations Act, 2021, passed into law. A portion of that bill, the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “Economic...more

Buchalter

Buchalter COVID-19 Client Alert: New Treasury PPP Rules Clarify Recent Changes to PPP Program, Extend Time to Obtain a PPP Loan to...

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On January 6, 2021, Treasury issued two new Interim Final Rules (IFRs) addressing the new Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act’s (Act) creation of PPP Second Draw Loans, and the Act’s various...more

Snell & Wilmer

SBA Issues Interim Final Rules for PPP “Second Draw” Loans and Existing PPP Loans

Snell & Wilmer on

On January 6, the Small Business Administration (SBA) issued its Interim Final Rule (IFR) for the original Paycheck Protection Program (PPP-1) to reflect changes to the program included in the recent Economic Aid to Hard-Hit...more

Schwabe, Williamson & Wyatt PC

A Guide to the SBA PPP Loan Forgiveness Review Process - Update #3

Borrowers applying for loan forgiveness under the Small Business Administration’s (“SBA”) Paycheck Protection Program (“PPP”) should familiarize themselves with the SBA guidance regarding the loan forgiveness review process....more

Akin Gump Strauss Hauer & Feld LLP

The Paycheck Protection Program: New SBA Questionnaires Require Borrowers of $2 Million or More to Provide Justification for...

Key Points - On October 26, 2020, the SBA announced its intent to require a Necessity Questionnaire for borrowers that received PPP loans of $2 million or greater. - The SBA intends to use the Necessity Questionnaire...more

Pillsbury Winthrop Shaw Pittman LLP

New SBA Questionnaires Ask Borrowers to Justify PPP Loan Necessity

The Small Business Administration’s questionnaires request information related not only to the economic condition of the borrower at the time it received the PPP loan, but also about its economic experience after receiving...more

Foley Hoag LLP

SBA Announces Simpler PPP Forgiveness for Loans Less Than $50k

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The U.S. Small Business Administration (SBA) has announced that it is rolling out a simpler loan forgiveness application for Paycheck Protection Program (PPP) loans of $50,000 or less. The SBA claims the new, more streamlined...more

Schwabe, Williamson & Wyatt PC

Ten Things to Know About the PPP Loan Forgiveness Applications - Update #5

Below are the ten important things to know about the Paycheck Protection Program (“PPP”) Loan Forgiveness Applications and the detailed instructions for the applications posted on June 16, 2020, and October 8, 2020. There are...more

Goodwin

Financial Services Weekly Roundup: Madden Fix/Valid When Made Rule Faces New Challengers

Goodwin on

In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more

Downs Rachlin Martin PLLC

Interim Final Rule Regarding Appeal of SBA PPP Loan Review Decisions

On August 11, the SBA issued an Interim Final Rule regarding the appeal of SBA loan review decisions made under the Paycheck Protection Program (“PPP”). The Interim Final Rule is immediately effective, and while many lenders...more

Proskauer Rose LLP

Paycheck Protection Program – Where Are We Now? An Up-To-Date Guide to the Paycheck Protection Program (UPDATED)

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Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020, the U.S. Small Business Administration (the “SBA”) and the U.S Treasury Department (“Treasury”) have issued a...more

Partridge Snow & Hahn LLP

New PPP Loan Forgiveness FAQs Released

On August 4, 2020, the U.S. Small Business Administration (“SBA”) and the Department of the Treasury released long-awaited FAQs providing guidance to both lenders and borrowers on Paycheck Protection Program (“PPP”) loan...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Agent Fees and the Payment Protection Program

Last week, Arkansas saw its first class action where “agents” claimed entitlement to payment of fees under the Payment Protection Program (PPP). This class action illustrates another area of confusion surrounding the...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Technology Industry - Update #7

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Proskauer Rose LLP

Paycheck Protection Program – Where Are We Now? An Up-To-Date Guide to the Paycheck Protection Program (UPDATED)

Proskauer Rose LLP on

Originally published on April 14, 2020. Last updated as of July 14, 2020. Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020, the U.S. Small Business...more

Hinshaw & Culbertson LLP

A Summary of PPP Updates, Including Early Filing of Forgiveness Application

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

Womble Bond Dickinson

Frequently Asked Questions: Paycheck Protection Program Loan Forgiveness - July 2020

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Revisions Incorporate Paycheck Protection Program Flexibility Act of 2020, New Forgiveness Applications, and Recent Interim Final Rules - On June 16, 2020, the Small Business Administration (SBA) and the U.S. Treasury...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Agricultural Industry - Update #5

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Technology Industry - Update #6

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Schwabe, Williamson & Wyatt PC

CARES Act Questions for the Manufacturing, Distribution and Retail Industry - Update #6

Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”), the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE Act”),...more

Tarter Krinsky & Drogin LLP

SBA Issues New Interim Final Rule For Paycheck Protection Program– Guidance Your Business Should Be Aware Of

Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Small Business Administration (SBA) is tasked with administering the Paycheck Protection Program (PPP), the loan program intended to allow...more

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