U.S. Treasury Issues Additional Guidance Regarding Loan Forgiveness

Client Alert
August 14, 2020

The U.S. Treasury recently issued additional guidance in the form of frequently asked questions regarding the Paycheck Protection Program (PPP) created by the Coronavirus Aid, Relief, and Economic Security Act. The guidance is helpful to clarify answers to certain of the many questions borrowers have on the previously-issued guidance regarding forgiveness of PPP loans. Similar to other U.S. Treasury guidance on PPP loans, we expect this guidance to be updated on a regular basis, so we encourage businesses to continuously monitor the above-included link.  

In addition, the U.S. Treasury recently issued an interim final rule on appeals of loan review decisions by the Small Business Administration (SBA) with respect to PPP loans and the forgiveness of such loans.

While a limited number of banks have begun processing PPP loan forgiveness applications and the SBA began accepting such applications earlier this week, many banks continue to wait for additional guidance before accepting loan forgiveness applications from PPP borrowers. Links to the forgiveness applications and instructions from our earlier advisory that were issued in June remain current, but many banks expect these applications and instructions to change in the coming days, particularly as a result of the recently issued guidance.

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Sullivan has developed a rapid response team of attorneys to help our clients and our communities cope with the impact of the COVID-19 pandemic and understand the implications of the CARES Act and other actions taken by state governments and the federal government. Please refer to Sullivan’s resource center at www.sullivanlaw.com/COVID19 for more information and for access to Sullivan’s library of related advisories.

Please know that Sullivan is focusing substantial efforts to provide assistance to businesses and individuals affected by COVID-19 and benefited by the CARES Act. If you have questions about how to move forward and navigate the novel legal issues raised by COVID-19 and/or the CARES Act, please contact your primary Sullivan attorney or send a message to CARES@sullivanlaw.com.

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