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FAQ 46 & 47: Crime & Punishment (or the Lack of Either) for PPP Loans Large and Small

With one day to spare before the May 14 “Limited Safe Harbor” expires, the SBA released FAQ #46 (May 13) to explain the process of how the SBA will review Paycheck Protection Program (PPP) loans. The new FAQ, unfortunately,...more

The Treasury Wants Its PPP Money Back By May 7. How Do We Level The Playing Field For Small Businesses?

Scant and inconsistent instruction from the Treasury Department has wrought havoc among small business owners seeking emergency funding under the Paycheck Protection Program. It's time for Congress to step in with...more

Money? What Money? Is It Time to Give Your Money Back? Updates to the PPP and the FAQ’s

Although the primary focus of this Client Alert is to summarize the key takeaways from the Enhancement Act (which as of April 23, 2020, at noon, awaits House and presidential approval), at the outset we would like to note...more

SBA Loans Regs: The “Bootleg” Redline of SBA Affiliation Rule §301(f) (the changes you’re not seeing online!)

There’s been confusion about the rules governing eligibility for SBA Section 7(a) loans, which we’ve elsewhere written about.1 That confusion focused on whether to conduct “affiliation” analysis under Section in Title 13 CFR...more

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