Small Business Administration Issues New Guidance That Impacts M&A Transactions Involving PPP Loan Recipients

By Matthew L. Mitchell and Scott R. Bleier     On October 2, 2020, the Small Business Administration (SBA) announced new guidelines that apply the SBA “Change of Ownership” procedures to the PPP context. As a 7(a) loan program, the PPP loans are subject to the same regulations that apply to 7(a) loans. These regulations …

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PPP Loan Update: “Forgiveness Portal” Open; FAQs Posted

By Matthew L. Mitchell and Scott R. Bleier     On August 10, 2020, the Small Business Administration (the “SBA”) opened the “Forgiveness Portal," permitting lenders of Payroll Protection Program (“PPP”) loans to accept forgiveness applications from PPP loan recipients. In addition, Frequently Asked Questions (FAQs) on PPP Loan Forgiveness (the “FAQs”) were published, and …

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Paycheck Protection Program Update: What the Question 46 Guidance Means for Recipients of PPP Loans Under $2 Million

  As we have previously reported, on May 13, 2020, the Treasury Department and the Small Business Administration (the “SBA”) released new guidance, embedded in a Frequently Asked Questions memorandum, that relates to the "economic necessity" requirement for Paycheck Protection Program (“PPP”) loans (the “Question 46 Guidance”). The Question 46 Guidance may be found here. Of particular note:  The Question …

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Treasury Department Announces Safe Harbor for PPP Borrowers with Loans of Under $2 Million

  The Treasury Department announced new guidelines that relate to the "economic necessity" requirement for Paycheck Protection Program loans. Differing from the original guidelines, the updated guidelines appear to indicate that the Treasury Department, as a matter of administrative policy, will not subject a PPP borrower with a loan amount of under $2 million to an …

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The Federal Reserve Main Street Lending Program

    On April 30, 2020, the Federal Reserve released additional details concerning the proposed Main Street Lending Program. The release includes changes to the original term sheets for the Main Street New Loan Facility (MSNLF) and the Main Street Expanded Loan Facility (MSELF) and introduced a new term sheet for the Main Street Priority …

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Client Alert – State and Federal COVID-19 Small Business Loan Programs

By: Joe Hunt and Amanda Thibodeau With COVID-19 causing disruption to businesses large and small, on both the federal and state levels existing programs and new programs are being launched to assist small businesses in these difficult times.  We outline the current status of these programs below. Federal – Small Business Administration (“SBA”) Economic Injury …

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