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To embed, copy and paste the code into your website or blog: Unpacking the Economic Aid Act and American Rescue Plan Act: Consolidated First Draw PPP Interim Final Rule, New First Draw PPP Loans, and Increases to First Draw PPP Loans On January 6, 2021, the Small Business Administration (the “ SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (sometimes referred to as the “ Consolidated First Draw PPP IFR” or the “ IFR”). That rule restates existing re...

On January 6, 2021, the Small Business Administration (the “ SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Second Draw Loans” (“ Second Draw Rules”). These rules announced the implementation of section 311 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “ Economic Aid Act”). The SBA also released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (“ Consolidated First D...

The Coronavirus Aid, Relief, and Economic Security Act (as amended and modified, the “ CARES Act”) was enacted to provide immediate assistance to individuals, families, and businesses affected by the COVID-19 emergency. Among other provisions, the CARES Act allowed Congress to authorize the Small Business Administration (“ SBA”) to temporarily guarantee forgivable loans under a new 7(a) loan program titled the Paycheck Protection Program (“ PPP”). On December 27, 2020, the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “ Economic Aid Act”) was enact...

On January 6, 2021, the Small Business Administration (the “ SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Second Draw Loans” (“ Second Draw Rules”). These rules announced the implementation of section 311 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “ Economic Aid Act”). The SBA also released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (“ Consolidated First D...

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” ...