As we have previously reported, a recipient of a Paycheck Protection Program (“PPP”) loan may be excused from the obligation to repay the loan if certain “Forgiveness Criteria” are met.
On Friday, May 22, 2020, the Treasury Department released two Interim Rules that detail those Forgiveness Criteria: the Interim Final Rule on Loan Forgiveness, and the Interim Final Rule on SBA Loan Review Procedures and Related Borrower and Lender Responsibilities.
The Interim Forgiveness & Audit Rules inform the instructions contained in the Forgiveness Application. As such, it is critical that PPP loan recipients that intend to request forgiveness fully understand the standards set forth in the Interim Forgiveness & Audit Rules.
The Interim Forgiveness & Audit Rules are complex and nuanced. We’re providing a guidepost summary that is intended to facilitate a loan recipient’s own review and understanding of these standards.