April 28, 2020
To our clients and friends:
On April 23, 2020, the Paycheck Protection Program and Health Care Enhancement Act (the “PPP Enhancement Act”) was signed into law, which provides $310 billion in additional funding to the U.S. Small Business Administration’s (“SBA”) Paycheck Protection Program (the “PPP”) previously established by the CARES Act. As a result, the SBA has resumed processing PPP loan applications as of yesterday.
Our Alert provides an update on the PPP based upon the PPP Enhancement Act and the latest rules and guidance issued by the U.S. Department of the Treasury (“Treasury”) and the SBA, including the SBA’s fourth interim final rule released on April 23, 2020 as a result of the new PPP funds and Treasury’s Frequently Asked Questions Memorandum for the PPP, updated as of April 26, 2020.
Our Alert is available here.
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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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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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April 8, 2020
The Securities and Exchange Commission recently adopted amendments to its definitions of “accelerated filer” and “large accelerated filer.” Our Alert regarding the changes and how they will affect public companies’ periodic reporting with the SEC is available here.
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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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