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First Draw PPP Loans $2 Million and Up and the PPP Necessity Questionnaires - Update #2 | Schwabe, Williamson & Wyatt PC
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PPP Loans Over $2 Million and the PPP Necessity Questionnaires - Update #3 | Schwabe, Williamson & Wyatt PC
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Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There are two questionnaire forms on the Treasury: Form 3509 for for-profit borrowers and Form 3510 for non-profit borrowers. On December 9, 2020, the SBA released FAQ 53, which provides some clarifications on the questionnaire (the “FAQ #53”).
Update: Starting in March 2021, we saw borrowers with loans of $2 million or greater starting to receive requests for additional materials (such as the maintained documents) or being informed by their lenders that they were under “SBA review.” Also, in March, April, and May 2021, we saw several lenders (and perhaps the SBA) stop processing forgiveness applications while they were working on new First Draw and Second Draw PPP Loans. In late May, the le
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 Second Draw Loans” (“
Second Draw Rules”). These rules announced the implementation of section 311 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “
Economic Aid Act”). The SBA also released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (“
Consolidated First Draw PPP 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. Both rules take effect immediately. For more information on the Consolidated First D
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 Second Draw Loans” (“
Second Draw Rules”). These rules announced the implementation of section 311 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “
Economic Aid Act”). The SBA also released an Interim Final Rule called “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act” (“
Consolidated First Draw PPP 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. Both rules take effect immediately. For more information on the Consolidated First D
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