CARES Act: Additional Guidance on the Paycheck Protection Program

The Small Business Administration (“SBA”), in consultation with the U.S. Department of the Treasury (“Treasury”), continues to issue guidance on the Paycheck Protection Program (“PPP”) by updating its Frequently Asked Questions (the “FAQs”) release. The updated FAQs as of May 6, 2020 included additional guidance regarding (i) SBA review of PPP loans, (ii) impact of past layoffs on loan forgiveness, (iii) non-profit hospital qualification under the CARES ACT, (iv) PPP funds return deadline, and (v) applicant employee size standard. Additionally, on April 30, 2020, the SBA released the Interim Final Rule on Corporate Groups and Non-Bank and Non-Insured Depository Institution Lenders (the “Interim Final Rule”), which provides that a single corporate group is subject to a $20 million aggregate limit for all PPP loans received.

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