News & Analysis as of

Interim Final Rules (IFR) CARES Act

Schwabe, Williamson & Wyatt PC

Treasury Department Unveils Crucial Changes to Coronavirus Relief Funds

On November 20, 2024, the Treasury Department issued an interim final rule that makes changes to the regulations that govern the Coronavirus State and Local Fiscal Recovery Funds. The new rule clarifies how state, local, and...more

Snell & Wilmer

Bankruptcy Debtor Prevails Over SBA in District of Arizona PPP Loan Dispute

Snell & Wilmer on

The Paycheck Protection Program (“PPP”) was a forgivable loan program administered by the US Small Business Administration (“SBA”) that was created as part of the Coronavirus Aid, Relief, and Economic Security Act (“CARES...more

Dorsey & Whitney LLP

Deferment Period Extended for PPP Borrowers that Appeal Adverse Forgiveness Decisions

Dorsey & Whitney LLP on

Effective July 28, 2021, the Small Business Administration (“SBA”) announced a new interim final rule that, inter alia, extends the “deferment period” for borrowers that appeal a final SBA loan review decision. Borrowers are...more

Lowenstein Sandler LLP

Paycheck Protection Program Round 2: FAQs For Microbusinesses - June 2021

The Paycheck Protection Program closed on May 28, 2021. The SBA is no longer accepting new applications from participating lenders. The following FAQs are for informational purposes only and to assist borrowers who obtained...more

King & Spalding

CMS Issues Medicare IPPS and LTCH Proposed Rule for FY 2021

King & Spalding on

On April 27, 2021, CMS issued the fiscal year (FY) 2022 proposed rule for the hospital inpatient prospective payment system (IPPS) and long-term care hospital (LTCH) prospective payment system (the Proposed Rule). Among...more

Lowenstein Sandler LLP

Paycheck Protection Program: FAQs for Nonprofits - UPDATED March #3

On December 27, the President signed into law the Consolidated Appropriations Act, 2021. The Act includes a roughly $900 billion COVID-19 relief package, known as the “Economic Aid to Hard-Hit Small Businesses, Nonprofits and...more

Lowenstein Sandler LLP

Paycheck Protection Program: FAQs For Microbusinesses - UPDATED March 2021 #3

On December 27, the President signed into law the Consolidated Appropriations Act, 2021. The Act includes a roughly $900 billion COVID-19 relief package, known as the “Economic Aid to Hard-Hit Small Businesses, Nonprofits and...more

Schwabe, Williamson & Wyatt PC

PPP Ineligibility Update: Businesses Ineligible for First Draw and Second Draw PPP Loans - Update

The Coronavirus Aid, Relief, and Economic Security Act (as amended and modified, the “CARES Act”) was enacted to provide immediate assistance to individuals, families, and businesses affected by the COVID-19 emergency. Among...more

Hinshaw & Culbertson LLP

PPP Updates: Calculation of the Loan Amount and Use of Loan Proceeds for Individuals Who File IRS Form 1040, Schedule C and...

On March 3, 2021, the Small Business Administration (SBA), in conjunction with the U.S. Department of the Treasury, adopted an interim final rule (IFR) that: (1) allows individuals who file an IRS Form 1040, Schedule C to...more

Schwabe, Williamson & Wyatt PC

Asking for Forgiveness: Revised PPP Loan Forgiveness Applications and Guidance - Update #2

Protection Program (“PPP”) Loan Forgiveness ‎Applications and the detailed instructions for the revised and updated applications posted on January 19, 2021, ‎as well as other forgiveness procedures as updated by the Economic...more

Schwabe, Williamson & Wyatt PC

Why You May Want to Wait to File for PPP Loan Forgiveness and Other Tips - Update #9

Most Paycheck Protection Program (“PPP”) borrowers are working toward full forgiveness of their PPP loans and are anxious to get this process started. A borrower generally may submit a loan forgiveness application any time on...more

Jackson Walker

Paycheck Protection Program – Biden-Harris Administration Announces PPP Reforms

Jackson Walker on

On Monday, February 22, 2021, the Biden-Harris administration announced several reforms to the Paycheck Protection Program (“PPP“), including - Starting at 9 a.m. EST on Wednesday, February 24, 2021, through Tuesday, March...more

Hinshaw & Culbertson LLP

SBA and U.S. Treasury Issue Interim Final Rule on Paycheck Protection Program Loan Forgiveness

On December 28, 2020, former President Trump signed the Consolidated Appropriations Act. Over 5,000 pages in length, the legislation (referred to herein as the Economic Aid Act) included revisions and additions to the...more

Bowditch & Dewey

New PPP Funding Hits the Streets – A Primer on What Businesses Should Know

Bowditch & Dewey on

Struggling businesses adversely impacted by the COVID-19 pandemic now have access to a second round of Paycheck Protection Program (“PPP”) stimulus funding enacted as part of the Economic Aid to Hard Hit Small Businesses,...more

Schwabe, Williamson & Wyatt PC

What to Know about the Paycheck Protection Program, Round Two - Update

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

Manatt, Phelps & Phillips, LLP

SBA Issues New Guidance on Loan Forgiveness

About the Interim Final Rule - On January 19, 2021, the Small Business Administration (SBA) published new Loan Forgiveness Requirements and Loan Review Procedures pursuant to an Interim Final Rule, or IFR (the PPP...more

Sheppard Mullin Richter & Hampton LLP

New Interim Final Rules Re: PPP Loan Forgiveness Requirements and Review Procedures as Amended by Economic Aid Act

On January 19, 2021, the U.S. Small Business Administration (SBA) published its 28th Interim Final Rule (Forgiveness IFR) covering the loan forgiveness requirements and review procedures for the Paycheck Protection Program,...more

Schwabe, Williamson & Wyatt PC

PPP Loans $2 Million and Up and the PPP Necessity Questionnaires

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

Schwabe, Williamson & Wyatt PC

Updated Key Considerations for PPP Documentation under the Economic Aid Act

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

Schwabe, Williamson & Wyatt PC

Asking for Forgiveness: Revised PPP Loan Forgiveness Applications and Guidance

Forgiveness ‎Applications and the detailed instructions for the revised and updated applications posted on January 19, 2021, ‎as well as other forgiveness procedures as updated by the Economic Aid to Hard-Hit Small...more

Jackson Walker

Paycheck Protection Program – An Overview of the 2021 PPP and Update on PPP Loan Forgiveness

Jackson Walker on

On Monday, December 21, 2020, Congress passed the Consolidated Appropriations Act, 2021 (CAA), which contains a $900 billion COVID-19 relief package that, among many other initiatives, reauthorizes and modifies the Paycheck...more

Schwabe, Williamson & Wyatt PC

The Lender’s Role in the PPP Loan Review Process - After the Economic Aid Act: An Updated Guide to the PPP Loan Forgiveness Review...

Lenders play a large role in the Paycheck Protection Program (“PPP”) loan forgiveness review and appeals process. The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “Economic Aid Act” or “PPP2...more

Schwabe, Williamson & Wyatt PC

Initial Takeaways and Agency Guidance for the Latest PPP Updates - After the Economic Aid Act: An Updated Guide to the PPP Loan...

On January 19, 2021, the Small Business Administration (the “SBA”) in consultation with the Department of Treasury (“Treasury”) posted new forgiveness application forms and the Interim Final Rule on Loan Forgiveness...more

Schwabe, Williamson & Wyatt PC

Economic Aid Act: 10 Things to Know about Second Draw PPP Loans - Update

Late 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”...more

Sheppard Mullin Richter & Hampton LLP

Paycheck Protection Program: SBA Issues Guidance on First Draw and Second Draw PPP Loans and Releases PPP Applications Pursuant to...

On January 6, 2020, the SBA published its 26th Interim Final Rule (the First Draw PPP IFR) and 27th Interim Final Rule (the Second Draw PPP IFR)[1] with respect to the Paycheck Protection Program (PPP), as reauthorized and...more

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