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The Second Draw Rules address the new PPP loans available for borrowers.  These are generally subject to the same terms and conditions as the first draw PPP loans, which are described more fully below.  The Consolidated Initial Rules, in the SBA’s own words, primarily “restates existing regulatory provisions to provide lenders and new PPP borrowers a single regulation to consult on borrower eligibility, lender eligibility, and loan application and origination requirements, as well as general rules on increases and loan forgiveness for PPP loans.”[1]  To enhance the “readability” ...

Small Business Administration and Department of the Treasury have issued two Interim Final Rules to change the Paycheck Protection Program to extend the authority to make PPP loans through March 31, 2021.

As we recently detailed, on January 6, 2021, the Small Business Administration (SBA) issued two Interim Final Rules (first rule and second rule) setting forth the regulations for the...

On January 6, 2021, Treasury issued two new Interim Final Rules (IFRs) addressing the new Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act’s (Act) creation of PPP Second Draw Loans, and the Act’s various changes to PPP requirements generally. The major PPP components of the Act are set forth in detail in Buchalter’s COVID Alert of December 28, 2020 (Buchalter PPP Changes Alert), which can be found here. While discussing the Act’s requirements in some detail, the two IFRs made several key clarifications not fully spelled out, or left ambiguous, in the Act: The time...

In December 2020, the Federal government passed a new $900 billion stimulus that includes $284 billion in additional Paycheck Protection Program (PPP) funding for small businesses.