May 8, 2020

To our clients and friends:

Last week, the U.S. Small Business Administration (“SBA”) resumed processing loan applications through its Paycheck Protection Program (the “PPP”) previously established by the CARES Act due to the additional $310 billion in PPP funding authorized by Congress.

Our Alert provides an update on the PPP based upon a Frequently Asked Question Memorandum, updated as of May 6, 2020, issued by the U.S. Department of the Treasury and the SBA.  Most significantly, it provides that: (1) the SBA will review individual PPP loans in excess of $2 million to further ensure PPP loans are limited to eligible borrowers in need; and (2) the PPP amnesty provision that would allow borrowers to repay their PPP loans in full without penalty upon a determination that their certification of “necessity” is no longer valid has been extended to May 14, 2020.

Our Alert is available here.


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