We have received questions from a number of clients about whether SBA’s consent is required for a change of control involving a Paycheck Protection Program borrower. On October 2, SBA provided additional guidance that...more
On September 29, 2020, the Department of Defense (DoD) issued a long-anticipated interim rule implementing its Cybersecurity Maturity Model Certification (CMMC) program. The rule introduces a new mandatory construct, the DoD...more
On July 14, 2020, the Federal Acquisition Regulation (“FAR”) Council published a long-awaited interim rule (the “Interim Rule”) implementing the second prong of Section 889 of the 2019 National Defense Authorization Act...more
7/15/2020
/ Breach of Contract ,
China ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Interim Rule ,
NDAA ,
Offerors ,
Subcontractors ,
Surveillance ,
Telecommunications ,
Waivers
Is it just us or does March 4 — the date of our last issue — feel like a million years ago? Like you, and not necessarily in this order, we have been: doing our work; keeping up with COVID-19-related laws, guidance, and...more
7/15/2020
/ Advanced Notice of Proposed Rulemaking (ANPRM) ,
Arbitration ,
Auto-Dialed Calls ,
BSA/AML ,
CARES Act ,
Consent Order ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
CRA ,
Dodd-Frank ,
E-SIGN ,
Fair Lending ,
FASB ,
FDIC ,
Federal Reserve ,
FinCEN ,
FinTech ,
HMDA ,
Interim Final Rules (IFR) ,
Money Market Mutual Fund Liquidity Facility (MMLF) ,
OCC ,
Paycheck Protection Program Lending Facility (PPPLF) ,
Popular ,
Remittance Transfer Rule ,
Request For Information ,
RESPA ,
SPVs ,
TCPA ,
Volcker Rule
As we previously reported, the Paycheck Protection Program Flexibility Act (“PPP Flexibility Act”) became law earlier this month, introducing numerous changes to the Paycheck Protection Program (PPP). The PPP, which is part...more
In the wake of the massive economic disruption caused by the Coronavirus outbreak, Congress enacted the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) on March 27, 2020. The Payroll Protection Program...more
Since the inception of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) nearly eight weeks ago, the Small Business Administration (SBA) has issued loans under the Paycheck Protection Program (PPP) that...more
During these uncertain economic times, the Small Business Administration (SBA) loans under the Paycheck Protection Program (PPP) have been a critical lifeline for many small businesses trying to weather the COVID-19 pandemic....more
Updated May 18, 2020-
As many companies are likely aware by now, Small Business Administration (SBA) loans under the Paycheck Protection Program (PPP) provide aid to qualifying small businesses in the form of loans with...more
As many companies are likely aware by now, Small Business Administration (SBA) loans under the Paycheck Protection Program (PPP) provide aid to qualifying small businesses in the form of loans with terms favorable to...more
In recent weeks Congress has authorized funding for a number of programs intended to provide relief to small- and medium-sized businesses and certain particularly hard-hit industry sectors, as well as to American businesses...more
This post has been updated on May 6, 2020 with new safe harbor deadline for repayment of PPP loans.
Given the proliferation of adverse news articles and TV pundit segments about well-funded companies that have received...more
On April 30, 2020, the U.S. Small Business Administration (SBA) issued a sixth interim final rule on the SBA’s Paycheck Protection Program (PPP), one of the relief programs available under the Coronavirus Aid, Relief, and...more
The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) allows certain eligible companies and individuals to obtain loans of up to $10 million or 2.5 times the average monthly payroll costs over the last...more
Given the proliferation of adverse news articles and TV pundit segments about well-funded companies that have received federal, Small Business Administration (SBA) loans under the Paycheck Protection Program (PPP), it is...more
On Thursday, April 23, 2020, the U.S. House of Representatives voted in favor of the $484 billion relief package that passed in the Senate earlier this week. Once signed into law, the legislation will revive the Small...more
Department of Defense (“DoD”) acquisition chief Ellen Lord earlier this week issued a memorandum reducing internal approvals required to issue other transactions (“OTs”) for prototype projects related to the national...more
Late Friday evening, the Small Business Administration (SBA) issued an Interim Final Rule on affiliation, which was posted to the U.S. Treasury Department’s Paycheck Protection Program (PPP) loan website. This interim final...more
On Tuesday afternoon, the Treasury Department released its guidance concerning the Paycheck Protection Program (PPP), which was authorized by Congress under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. ...more
The Coronavirus Aid, Relief, and Economic Security Act (“CARES” or “the Act”) allows certain eligible companies and individuals to obtain loans of up to $10 million or 2.5 times the average monthly payroll costs over the last...more
Popular science fiction is replete with examples of artificial intelligence (AI) gone awry, from HAL, the killer AI of Arthur C. Clarke’s 2001: A Space Odyssey, to the supercomputer bent on nuclear annihilation in WarGames,...more
The Biomedical Advanced Research and Development Authority (BARDA), part of the U.S Department of Health and Human Services, Office of the Assistant Secretary for Preparedness and Response, has modified an existing broad...more
BID PROTESTS, LATEST DEVELOPMENTS & TWISTS -
Bid Protests: Agenda -
1. LOGCAP V and Task/Delivery Order Protest Jurisdiction
2. SpaceX and Other Transaction Authority Protest Jurisdiction
3. Potential Impact of New...more
You can rejoice in a recent Supreme Court decision if you have ever spent hours trying to convince a government agency not to release your company’s confidential information to the public in response to a Freedom of...more
6/27/2019
/ Appeals ,
Confidential Information ,
Congressional Intent ,
Exemptions ,
FOIA ,
Food Marketing Institute v Argus Leader Media ,
Motion to Compel ,
Private Commercial or Financial Information ,
Protected Disclosures ,
Reversal ,
SCOTUS ,
SNAP Program ,
Statutory Interpretation ,
Substantial-Competitive-Harm Test ,
Trade Secrets ,
USDA
The Small Business Administration (SBA) has statutory authority to establish federal Government-wide policies to implement the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs....more