Alert – Payment Protection Program Updated Based on Latest SBA/Treasury Developments (as of April 17, 2020)

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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Alert – SEC Provides Guidance Regarding COVID 19 Disclosure

April 14, 2020

As a result of the outbreak of the coronavirus pandemic (COVID-19), public financial institutions are considering what additional disclosures should be made in their upcoming quarterly reports on Form 10-Q to be filed with the Securities and Exchange Commission (the “SEC”), as well as in their earnings releases. Our alert providing guidance that public financial institutions should consider when preparing these documents is available here.

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Alert – SBA Payment Protection Program – Updated for Treasury Guidance

April 7, 2020

To our clients and friends:

On April 6, 2020, the U.S. Department of the Treasury provided additional guidance and information (the “Treasury Guidance”) to address borrower and lender questions concerning the implementation of the Paycheck Protection Program (“PPP”), which was authorized pursuant to the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”) recently signed into law.

Our Alert, which provides updated information about the PPP based upon the Treasury Guidance issued on April 6, 2020, is available here.

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Alert – The SBA’s Paycheck Protection Program

April 6, 2020

To our clients and friends:

On April 2, 2020, the Small Business Administration ("SBA") issued its interim final rule (the "Interim Final Rule") regarding the implementation of the Paycheck Protection Program ("PPP"), which was authorized pursuant to the Coronavirus Aid, Relief, and Economic Security Act ("CARES Act") recently signed into law.

Under the PPP, SBA and other qualifying lenders can originate up to $349 billion in loans to eligible businesses that would be fully guaranteed as to principal and interest by the SBA, have more favorable terms than traditional SBA loans and may be forgiven if the loan proceeds are used by the borrower for certain purposes.

Our Alert, which provides information about the PPP based upon the CARES Act and the Interim Final Rule, is available here.

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