CARES Act Small Business Loans Today: Keeping Up and Ensuring Compliance
Crowell & Moring – Over the past two days, SBA has released in the middle of the night two draft Interim Final Rules as well as a final application and additional guidance – including on affiliation – on the overhauled Paycheck Protection Program (“PPP”) loans, implementing Sections 1102 and 1106 of the CARES Act. Since the passage of the legislation a week ago and with only limited preliminary guidance and now-superseded applications from both Treasury and SBA, businesses and lenders have been scrambling to understand loan eligibility, how to apply, as well as key loan terms. The new SBA Form 2483, confirmation of the applicable affiliation test, and the two draft Interim Final Rules reflect significant developments.
