The U.S. Treasury recently issued additional guidance in the form of frequently asked questions regarding the Paycheck Protection Program (PPP) created by the Coronavirus Aid, Relief, and Economic Security Act. The guidance is helpful to clarify answers to certain of the many questions borrowers have on the previously-issued guidance regarding forgiveness of PPP loans. Similar to other U.S. Treasury guidance on PPP loans, we expect this guidance to be updated on a regular basis, so we encourage businesses to continuously monitor the above-included link.
In addition, the U.S. Treasury recently issued an interim final rule on appeals of loan review decisions by the Small Business Administration (SBA) with respect to PPP loans and the forgiveness of such loans.
While a limited number of banks have begun processing PPP loan forgiveness applications and the SBA began accepting such applications earlier this week, many banks continue to wait for additional guidance before accepting loan forgiveness applications from PPP borrowers. Links to the forgiveness applications and instructions from our earlier advisory that were issued in June remain current, but many banks expect these applications and instructions to change in the coming days, particularly as a result of the recently issued guidance.
