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What to Know about the Paycheck Protection Program, Round Two – First Draw PPP Loans - Update #4 | Schwabe, Williamson & Wyatt PC


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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 regulatory provisions into a single regulation on borrower eligibility, lender eligibility, and loan application or origination requirement issues for new First Draw PPP Loans, as well as general rules relating to First Draw PPP Loan increases and loan forgiveness. ....

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SBA PPP Guidance on First and Second Draw PPP Loans


[1] with respect to the Paycheck Protection Program (
Economic Aid 
Act)) of Division N of the Consolidated Appropriations Act, 2021.  The PPP was originally enacted under the Coronavirus Aid, Relief, and Economic Security Act (as amended, supplemented or otherwise modified from time to time prior to the enactment of the Economic Aid Act, including by the Paycheck Protection Program and Health Care Enhancement Act, the Paycheck Protection Program Flexibility Act, applicable federal regulations and interpretive guidance issued by the SBA and Treasury, the 
CARES Act).
First Draw PPP Loan), while expanding the authorized uses for PPP loan proceeds and increasing flexibility to obtain loan forgiveness.  The Economic Aid Act also permits an eligible business that received a First Draw PPP Loan to apply for a second draw of PPP loan proceeds (a  ....

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