On May 13, 2020, the Small Business Administration (“SBA”), along with the Treasury, released FAQ #46, as a follow up to its guidance on FAQs #31 and #37, which is discussed here. As a quick catch up, the SBA and Treasury issued FAQ #31 in response…
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On April 9, 2020, the Federal Reserve, published term sheets for a Main Street Lending Program for small and/or mid-size businesses. The April 9 term sheets set forth two separate loan programs under the Main Street Lending Program—the Main Street Lending Program and the Main Street Expanded Lending Program.…
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For any employer that expected PPP loan proceeds to be “free money,” the IRS has essentially said – not so fast. In guidance issued on May 1, 2020, the IRS clarified that to the extent that an employer makes payments of expenses that result in…
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In response to last week’s blog post, we’ve received many questions (thank you!) about ramifications for ineligible companies that take out PPP loans and fail to return loan proceeds by May 7. This is a huge question. And, unfortunately, we do not have a single,…
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On April 23, 2020, the Treasury added FAQ #31 to its ever-growing list of Paycheck Protection Program Loans Frequently Asked Questions (“FAQs”). A first set of 18 FAQ Questions and Answers, meant to provide guidance to PPP borrowers and lenders, were released on April 6,…
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After being signed into law on March 27, 2020, much of the focus surrounding the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”) has centered around the Paycheck Protection Program and the Economic Injury Disaster Loan and Emergency Grant. Both programs are…
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On April 21, 2020, Treasury Secretary Steve Mnuchin, expressed concern that large companies – not the intended Paycheck Protection Program (“PPP”) participants – had applied for and received PPP loans. He unequivocally showed that the government will closely scrutinize representations made by PPP Loan borrowers…
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