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The Federal Reserve recently expanded its Main Street Lending Program (the “Program”) to three separate loan facilities:  the Main Street New Loan Facility, the Main Street Priority Loan Facility and the Main Street Expanded Loan Facility (each, a “MSLP Facility” and collectively, the “MSLP Facilities”).  The MSLP Facilities are aimed at providing up to $600…

On June 5, 2020, the President signed the Paycheck Protection Program Flexibility Act of 2020 (the “Act”), a bipartisan measure aimed at providing additional flexibility and extended relief to small business borrowers under the Paycheck Protection Program (“PPP”). Below is a summary of the key provisions of the Act, highlighting material deviations from those terms…

On Friday, May 15, 2020, the Small Business Administration (“SBA”) released the Paycheck Protection Program Loan Forgiveness Application (the “Application”) and instructions (the “Instructions”), which, together with applicable rules, will govern loan forgiveness under the Paycheck Protection Program (“PPP”).  Despite varying predictions, and with only limited exception, the Application and Instructions are generally consistent with…

The Small Business Administration (“SBA”) has issued a supplemental Interim Final Rule (the “Rule”), along with additional Frequently Asked Questions issued in consultation with the Department of Treasury (released on Friday, April 24, 2020 (as further modified on Sunday, April 26, 2020)), each providing additional guidance with respect to the implementation and administration of the…

On April 23, 2020, the Small Business Administration (“SBA”), in consultation with the Department of Treasury, released supplemental guidance in the form of Frequently Asked Questions (“FAQs”) with respect to the implementation of the Paycheck Protection Program (“PPP”). These FAQs clarify certain aspects of the SBA Interim Final Rules released on April 3, 2020 and…