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Unpacking the Economic Aid Act: Consolidated First Draw PPP Interim Final Rule, New First Draw PPP Loans, and Increases to First Draw PPP Loans (January 14, 2021)
Late on January 6, 2021, the Small Business Administration (the “
SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (sometimes referred to as the “
Consolidated First Draw PPP IFR” or the “
IFR”). That rule restates existing regulatory provisions into a single regulation on borrower eligibility, lender eligibility, and loan application or origination requirement issues for new First Draw PPP Loans, as well as general rules relating to First Draw PPP Loan increases and loan forgiveness.
Late on January 6, 2021, the Small Business Administration (the “SBA”) and the Department of Treasury released an Interim Final Rule called “Business Loan Program Temporary Changes;.
Late on Sunday, December 27
th, after initially raising concerns about the pandemic relief measure that had overwhelmingly passed Congress days before, President Trump signed the measure into law, ending a long political stalemate and beginning the process of sending financial relief to American families and small businesses, further aiding the American economy. As with the CARES Act enacted in March, this bill, the “Consolidated Appropriations Act, 2021,” passed the House and Senate overwhelmingly, on a bipartisan vote of 359-53 in the House, followed swiftly by a 92-6 vote in the Senate.
1 With an official price tag of approximately $900 billion, it is the second largest stimulus measure ever enacted by Congress.