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Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There...more
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 Second Draw Loans” (“Second...more
Unpacking the Economic Aid Act: Consolidated First Draw PPP Interim Final Rule, New First Draw PPP Loans, and Increases to First Draw PPP Loans (January 14, 2021) - Late on January 6, 2021, the Small Business...more
Borrowers under the Small Business Administration’s (the “SBA”) Paycheck Protection Program (“PPP”) are required to either maintain or submit to lenders and the SBA certain documentation associated with their application for...more
In November 2020, the Small Business Administration (SBA) issued for comment two questionnaire forms, which would need to be provided by Paycheck Protection Program (PPP) lenders to PPP borrowers who, together with their...more
The Federal Reserve Bank of Boston announced on July 6, 2020, that the Main Street Lending Program (“Main Street Program” or “Program”) is now fully operational and ready to purchase participation in eligible loans that are...more
Borrowers under the Small Business Administration’s (“SBA”) Paycheck Protection Program (“PPP”) are required to either maintain or submit to lenders and the SBA certain documentation associated with their application for and...more
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
Last month, the U.S. Treasury and the Small Business Administration (SBA) released two Paycheck Protection Program (PPP) loan forgiveness applications. The first was a new EZ PPP loan forgiveness application with instructions...more
On June 8, 2020, the Federal Reserve Bank of Boston, the administrator of the Federal Reserve’s Main Street Lending Program, released updated term sheets for the three types of loans, “New,” “Priority” and “Expanded,” that...more
Late on June 10, 2020, the Small Business Administration (SBA) and Treasury Department issued the 17th “interim final rule,” providing the initial regulations to implement the Paycheck Protection Program Flexibility Act...more
On May 27, 2020, the Federal Reserve Bank of Boston (FRBB) released several forms, agreements and instructions (Required Documentation) for Eligible Lenders and Eligible Borrowers pertaining to the Main Street Business...more
Companies that may want to borrow under the Main Street Lending Program should take note of additional guidance recently issued by the Federal Reserve Bank of Boston. The Federal Reserve Bank of Boston has issued further...more
Between May 20 and May 22, SBA announced three new Interim Final Rules and the U.S. Department of Justice (DOJ) announced three new fraud prosecutions stemming from PPP loans. Those prosecutions reflect that the DOJ does not...more
This alert, originally published May 19, 2020, was updated to reflect further guidance issued by the SBA on May 22, 2020 regarding PPP loan forgiveness. The Small Business Administration (SBA) has released the first major...more
Congress recently passed the economic stimulus package referred to as the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act1”) and the Paycheck Protection Program and Health Care Enhancement Act (“PPPHCE...more
On May 13, 2020, one day before the expiration of the relevant “safe harbor” deadline, the Small Business Administration (SBA) issued new guidance to borrowers who have been considering whether to return their CARES Act...more
This alert has been updated to reflect further guidance issued by the Small Business Administration (SBA) on May 5, 2020 indicating that forthcoming rule changes will extend the repayment date for the safe harbor discussed...more
Following criticism that large restaurant chains were able to obtain funds before the loan program had been depleted - seemingly shutting out much smaller restaurants - Shake Shack has publicly announced that it is returning...more