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Wiley Rein LLP

FCC Releases Item Amending Equipment Authorization Rules to Protect U.S. National Security

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On November 25, 2022, the Federal Communications Commission (FCC or Commission) released a Report & Order, Order, and Further Notice of Proposed Rulemaking (R&O, Order, and FNPRM; collectively, the Item) that makes...more

Schwabe, Williamson & Wyatt PC

First Draw Loans at or Over $2 million—SBA Discontinues Use of Necessity Questionnaires and What Is Next

Schwabe, Williamson & Wyatt PC on

As per our earlier articles, in late 2020, the SBA began requiring borrowers with First Draw PPP loans $2 million or greater to complete a PPP Loan Necessity Questionnaire (Form 3509 (For Profit Borrowers) or Form 3510...more

Downs Rachlin Martin PLLC

Borrowers of PPP Loans of $2M or More Must Justify Necessity

Downs Rachlin Martin PLLC on

For-profit and non-profit borrowers of PPP loans of $2MM or more are now required to submit additional forms. On October 26, 2020, the SBA published a notice seeking Office of Management and Budget (OMB) approval of new...more

Perkins Coie

SBA Questions Borrowers About the Necessity of Their PPP Loans

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Over the course of the last week, the Small Business Administration (SBA) has reportedly begun quietly questioning borrowers who had received Paycheck Protection Program (PPP) loans about the “necessity” of their loans. On...more

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