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Borrowers under the Small Business Administration’s (the “ SBA”) Paycheck Protection Program (“ PPP”) are required to either maintain or submit to lenders and the SBA certain documentation associated with their application for and their use of PPP loan proceeds. In addition, certain documentation is required for an appeal. The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the “ Economic Aid Act” or “ PPP2 Act”) was enacted on December 27, 2020. On January 6, 2021, the SBA in consultation with the Department of Treasury (“ Treasury”) released two interim final rules: (a) Interim Final Rule called Business Loan Program Temporary Changes; Paycheck Protection Program as Amended by Economic Aid Act (“

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