Newsletter – Adjustable Interest Rate (LIBOR) Act

September 19, 2022

To our clients and friends:

The Board of Governors of the Federal Reserve System has proposed regulations to implement the Adjustable Interest Rate Act (the “LIBOR Act”). The LIBOR Act and the Federal Reserve’s proposed implementing regulations are intended to address the discontinuation of the USD LIBOR benchmarks on June 30, 2023, by establishing a SOFR-based replacement benchmark that will automatically apply to agreements that rely on LIBOR and do not have a contractual non-LIBOR-based fallback benchmark.

Our newsletter, which summarizes the key provisions of the proposed regulations, is available here.

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Alert – SBA issues new interim final rule implementing changes to the PPP by the Paycheck Protection Program Flexibility Act

June 17, 2020

To our clients and friends:

On June 11, 2020, the U.S. Small Business Administration (“SBA”) issued an interim final rule (the “Interim Final Rule”) implementing the changes made to the SBA’s Paycheck Protection Program (the “PPP”) by the Paycheck Protection Program Flexibility Act of 2020 (the “PPP Flexibility Act”). The PPP Flexibility Act changed many aspects of the PPP; most significantly extending the covered period for loan forgiveness purposes, lowering the amount required to be spent on payroll costs, extending the loan term to maturity period and revising the loan deferral period.

Our Alert summarizes key provisions of the Interim Final Rule and is available here.

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