April 17, 2020

Yesterday, the Small Business Administration (“SBA”) announced that no new applications for loans will be accepted under the Paycheck Protection Program (the “PPP”), which was authorized pursuant to the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), because the processed PPP loan volume has reached the $349 billion limit under the CARES Act.

Assuming that Congress will authorize more PPP funding (which is expected), our Alert provides an update on the PPP based upon the latest rules and guidance issued by the U.S. Department of the Treasury and the SBA, including the SBA’s second interim final rule released on April 14, 2020.

Although there is bipartisan consensus in Congress to provide more funding for the PPP, it is possible that the eligibility criteria and administration of the PPP may change in consideration of any new funding.  We are closely monitoring these developments and will provide updates to you as appropriate.

Our Alert is available here.

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