On January 19, 2021, the Small Business Administration (the “ SBA”) in consultation with the Department of Treasury (“ Treasury”) posted new forgiveness application forms and the Interim Final Rule on Loan Forgiveness Requirements and Loan Review Procedures as Amended by Economic Aid Act (“ 2021 Forgiveness IFR”). The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “ Economic Aid Act” or “ PPP2 Act”) was enacted on December 27, 2020. The forms and 2021 Forgiveness IFR are effective immediately, and the rules in the 2021 Forgiveness IFR apply to loans that were made in 2020 but for which the SBA had not yet remitted forgiveness to the lender. To explore this new information, we created