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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;.
Highlights
The Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act), which was part of the Consolidated Appropriations Act, 2021 package, made various changes to the Paycheck Protection Program (PPP) that affect all PPP loans including those funded under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).
The Economic Aid Act opens a new PPP loan period for first loans and implements a second loan draw for certain PPP borrowers, each through March 31, 2021.
President Donald Trump signed the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act (Economic Aid Act), which was included in the Consolidated Appropriations Act, 2021, on Dec. 27, 2020. In turn, the U.S. Small Business Administration (SBA) published a new consolidated Interim Final Rule (IFR) on Jan. 6, 2021, relating to the Paycheck Protection Program (PPP) created by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as revised by the Econ
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PACs and other politically active organizations have already seen a lot of activity in the first few weeks of 2021 – including an upcoming Presidential transition and runoff Senate elections in Georgia. Before we see what else 2021 has in store, we wanted to share a few useful tips for your PAC, lobbying and other political activities. It’s not exhaustive, but it’s our hope that you can use this list to give your political operations a quick tune-up as we kick off the new year.
Now is the time to elect Quarterly Filing status with the Federal Election Commission (FEC). Although the FEC puts PACs on the Quarterly Filing schedule by default, during election years like 2020, we advise clients to choose Monthly Filing to avoid the need to file Pre- and Post-Primary reports. If your PAC was on a Monthly schedule in 2020, make sure that you choose Quarterly for 2021, in which case your PAC will only have to complete the
Who Needs to Know
Why It Matters
In addition to allocating $284.45 billion in new funding, this package of laws include significant clarifications and modifications to the PPP that are important to borrowers and lenders.
On December 27, 2020, the President signed into law the Consolidated Appropriations Act, 2021, which included the Economic Aid to Hard-Hit Small Businesses, Non-profits, and Venues Act (the Act), the COVID-Related Tax Relief Act of 2020, and the Taxpayer Certainty and Disability Relief Act of 2020. These laws include significant clarifications and modifications to the Paycheck Protection Program (PPP), which terminated on August 8, 2020. The COVID-Related Tax Relief Act of 2020 solidifies the tax-free treatment of forgiven PPP loans. In addition to allocating $284.45 billion to the PPP for 2021, the Act: