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PPP Guidance Update

The Small Business Administration (SBA), in consultation with the Department of the Treasury, continues to provide additional guidance with respect to the implementation of the Paycheck Protection Program (PPP).  A list of Frequently Asked Questions (FAQs) has been created and is regularly updated to provide this guidance. On May 13, 2020, FAQ #46 was issued to address the good-faith certification concerning the necessity of a borrower’s loan request. This FAQ includes the following safe harbor: “Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.”

Click here to read FAQ #46 in its entirety as well as the full set of FAQs. As guidance continues to change, we encourage you to connect with us to discuss your specific questions so that we can work together to address your needs.