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.”