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Implications for Emerging Companies in the CARES Act's Paycheck Protection Program

Client Updates

On March 31, 2020 and April 2, 2020, the Treasury Department issued implementation guidance (the “Treasury Guidance”) regarding the Paycheck Protection Program (the “PPP”), which was created under the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), and the application form for obtaining PPP funds. On April 2, 2020, the Small Business Administration (the “SBA”) issued an Interim Final Rule regarding the Paycheck Protection Program and supplemented it on April 3, 2020 with an Interim Final Rule on Affiliation (together, the “Interim Final Rules”). The PPP authorizes the SBA to make loans to businesses with 500 or fewer employees resident in the U.S. for payroll costs and other approved expenses. Subject to certain restrictions, the funds available under the PPP are forgivable. See the Treasury Guidance here and SBA’s Interim Final Rule here and Interim Final Rule on Affiliation here. See our prior client alert on the CARES Act (which included an overview of the PPP) here and its implications on emerging companies here.

Click on the title link below for a summary of updates for borrowers based on the Treasury Guidance, the Interim Final Rules and updated PPP application form.

Treasury Issues Guidance on CARES Act’s Paycheck Protection Program; SBA issues Interim Final Rule regarding the Paycheck Protection Program and Interim Final Rule on Affiliation

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