The Second Draw Rules address the new PPP loans available for borrowers. These are generally subject to the same terms and conditions as the first draw PPP loans, which are described more fully below. The Consolidated Initial Rules, in the SBA’s own words, primarily “restates existing regulatory provisions to provide lenders and new PPP borrowers a single regulation to consult on borrower eligibility, lender eligibility, and loan application and origination requirements, as well as general rules on increases and loan forgiveness for PPP loans.”[1] To enhance the “readability” of the guidance, the Consolidated Initial Rules generally does not include the policy and legal justifications for the existing regulatory provisions, but those can be found in the original interim final rules.
The Coronavirus Aid, Relief, and Economic Security Act (as amended and modified, the “CARES Act”) was enacted to provide immediate assistance to individuals, families, and businesses.
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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;.