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On June 11, 2020, the Small Business Administration and the U.S. Department of the Treasury released their latest guidance in the form of “Paycheck Protection Program –Revisions to First Interim Final Rule” (the Revised Interim Final Rule). This Revised Interim Final Rule amends the SBA’s initial interim final rule posted on April 2, 2020, by changing key provisions, such as the loan maturity, deferral of loan payments, and forgiveness provisions, to conform with the Paycheck Protection Program Flexibility Act of 2020 (the Flexibility Act) that was signed into law on June 5, 2020, amending the CARES Act (Pub. L. 116-136). With these revisions, the SBA also is making conforming amendments to the use of PPP loan proceeds for consistency with amendments made in the Flexibility Act. Several of these amendments, although not all, are retroactive to the date of enactment of the CARES Act. This guidance is intended to give borrowers seeking forgiveness of their PPP loans a better understanding of the process, subject to future regulatory or legislative changes.

Read the full GT Alert, “Paycheck Protection Program: Treasury/SBA Conform First Interim Final Rule to PPP Flexibility Act.”

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Photo of Bryan X. Grimaldi Bryan X. Grimaldi

Bryan Grimaldi counsels corporate clients, trade associations, destination marketing organizations, and public-private partnerships (P3) nationwide providing industry-specific, cost effective, outside counsel services, operational consulting, and advocacy. With deep knowledge of politics and the ability to navigate complex issues in dynamic environments, Bryan provides

Bryan Grimaldi counsels corporate clients, trade associations, destination marketing organizations, and public-private partnerships (P3) nationwide providing industry-specific, cost effective, outside counsel services, operational consulting, and advocacy. With deep knowledge of politics and the ability to navigate complex issues in dynamic environments, Bryan provides clients a unique perspective on how to deftly handle making an organization successful and bridge the gap between business goals and legal issues, among multiple constituencies.

Bryan develops tailored strategies for his clients as well as with businesses experiencing legal and policy obstacles with their city. He has broad experience in the travel & tourism industry, government relations, not-for-profit management and public/private partnerships.

Bryan draws from his nearly 15 years as Chief Operating Officer & General Counsel at NYC & Company, Inc, New York City’s official marketing, tourism, and partnership organization, where he led the organization on legal, business development, licensing, government relations, regulatory, and policy matters. Bryan provided strategic counsel and advised on matters that advanced the organization’s mission, while growing and protecting its funding streams.

Having served three mayors of New York City, Bryan has deep government experience, credibility, and broad knowledge of the private sector, including sports leagues, marketing firms and industry associations, particularly in relation to the travel, tourism, and hospitality industries.  He draws on his wide-ranging understanding of policy issues and the regulatory schemes of cities, states, and the federal government to represent clients in policy initiatives, transactions, and government relations matters. In his role at the membership-based trade association NYC & Company, Bryan lead the organization on legal, regulatory and policy matters with a focus on the members’ strategic objectives and provided advice on matters that advanced the organization’s mission. He was responsible for centralizing New York City’s marketing, licensing, and other intellectual properties, including the NYPD and FDNY brands.

Bryan previously served as general counsel in the Mayor’s Office of International Affairs, where he provided legal counsel and support to city agencies and senior administration officials in dealings with the United Nations, foreign governments, diplomats, and federal agencies.

Photo of Jennifer S. Zucker Jennifer S. Zucker

Jennifer S. Zucker is a shareholder in the Washington, D.C. office of Greenberg Traurig. Her practice includes a broad range of litigation, counselling and transactional matters for clients that work with federal, state, and local governments. She represents contractors in bid protests, contract

Jennifer S. Zucker is a shareholder in the Washington, D.C. office of Greenberg Traurig. Her practice includes a broad range of litigation, counselling and transactional matters for clients that work with federal, state, and local governments. She represents contractors in bid protests, contract claims and disputes, mergers and acquisitions, False Claims Act matters, and suspension and debarment proceedings. She also counsels contractors on regulatory requirements under government contracts, ethics and compliance issues, and government investigations and audits.

Jennifer’s experience extends across multiple industries, including defense, aerospace, intelligence, information technology, finance, public assistance and management consulting. She maintains an active security clearance and has deep experience advising clients on national security compliance issues and representing clients in investigations and litigation involving classified programs.

Jennifer serves on the board of directors of SRC Energy, Inc., where she is chair of the Compensation Committee and serves on the Governance and Nominating Committee. She is also a Colonel in the U.S. Army Reserve.

Photo of Carl A. Fornaris Carl A. Fornaris

Carl A. Fornaris is Co-Chair of the firm’s Financial Regulatory and Compliance Practice. With 27 years of legal experience, Carl advises a broad range of financial services firms – banks and their holding companies, money services businesses, investment advisers, securities broker dealers, gaming

Carl A. Fornaris is Co-Chair of the firm’s Financial Regulatory and Compliance Practice. With 27 years of legal experience, Carl advises a broad range of financial services firms – banks and their holding companies, money services businesses, investment advisers, securities broker dealers, gaming firms, Fintechs, cryptocurrency firms and other institutions – on all aspects of their business. These include formation and licensing, capital-raising transactions, acquisitions and divestitures, USA PATRIOT Act/BSA/AML compliance and OFAC sanctions programs, cryptocurrency regulation, mobile money and FinTech, federal and state agency enforcement proceedings, Dodd-Frank Act compliance and COVID-19/CARES Act economic stimulus program advice (ranging from Small Business Administration PPP loans to Federal Reserve Main Street program loans). Throughout his career, Carl has counseled clients in their dealings with the Federal Reserve, OCC, FDIC, FinCEN, SEC, FINRA, Florida Office of Financial Regulation, New York Department of Financial Services and other state supervisory authorities.

Carl is also active representing lenders and credit parties in financing transactions, particularly credits to non-U.S. loan parties, asset-based credits, acquisition financing and stand-by letters of credit.

Carl is a past General Counsel of the Florida International Bankers Association and sits on its Board of Directors. Previously, he served as Head of Legal and Compliance for the Latin America region of Barclays Bank PLC, with responsibility for managing legal and compliance matters throughout the region. Carl is an adjunct professor in the Business Law Department of the University of Miami Business School.

Photo of Lee Ann Anderson Lee Ann Anderson

Lee Ann Anderson focuses her practice on capital markets, structured finance and corporate transactions, with broad experience in U.S. and cross-border securities offerings. In the current global crisis, Lee Ann serves as a member of our COVID-19 Economic Stimulus Response Team and has…

Lee Ann Anderson focuses her practice on capital markets, structured finance and corporate transactions, with broad experience in U.S. and cross-border securities offerings. In the current global crisis, Lee Ann serves as a member of our COVID-19 Economic Stimulus Response Team and has counseled scores of companies about relief under Titles I and IV of the CARES Act and relief programs established by the Federal Reserve.

Lee Ann counsels issuers and investment banks on certificates of deposits, including rates-, commodities-, equity-, and proprietary index-linked products. She has wide-ranging experience in debt and equity capital markets, securitizations, and other structured finance transactions. Her practice has included scores of domestic and international debt and equity offerings, as well as securitizations of receivables and other collateral, complex tax-based structures utilizing swaps and other derivatives. Lee Ann also has advised a number of foreign and domestic public companies with respect to a wide range of corporate and securities matters, including reporting obligations.

Additionally, Lee Ann has deep experience counseling clients on corporate transactions, including mergers, stock purchases, asset sales, joint ventures, and other reorganization transactions. She also provides a range of general corporate and governance advice. Lee Ann has a strong commitment to pro bono work and served as a pro bono coordinator at her previous firm.

Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is a member of the firm’s Global Securities practice group and serves as Co-Chair of the firm’s interdisciplinary Blockchain & Cryptocurrency practice group. She is also co-coordinator of the firm’s interdisciplinary Conflict Minerals Compliance Initiative. Barbara maintains a diverse corporate

Barbara A. Jones is a member of the firm’s Global Securities practice group and serves as Co-Chair of the firm’s interdisciplinary Blockchain & Cryptocurrency practice group. She is also co-coordinator of the firm’s interdisciplinary Conflict Minerals Compliance Initiative. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including blockchain and cryptocurrency transactions, private and public financings (including token offerings), dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. Her practice includes serving as a trusted advisor to public and private company boards of directors on governance and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and companies in blockchain, life sciences and biotechnology, information technology, energy (traditional and renewable), mining, defense and security, telecommunications, media, entertainment and sports. Barbara is also active in the representation of Olympic athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 2003, and headed the international capital markets practice of a major U.S. law firm from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters and strategic alternatives.