On May 22, 2020, the U.S. Small Business Administration (SBA) issued the Interim Final Rule on SBA Loan Review Procedures and Related Borrower and Lender Responsibilities.
On May 22, 2020, the U.S. Small Business Administration (SBA) issued the Interim Final Rule on SBA Loan Review Procedures and Related Borrower and Lender Responsibilities. The interim rule covers the following:
The complete Interim Final Rule on SBA Loan Review Procedures and Related Borrower and Lender Responsibilities is available on the U.S. Treasury website. The key takeaways are:
All PPP loan borrowers (not just borrowers and affiliated borrowers with loans in excess of $2 million) should be prepared to support their need of a PPP loan with documentation. All PPP loan borrowers should consult with their legal counsel on what satisfies the ‘current economic uncertainty which makes the loan request necessary to support the ongoing operations’ requirement. This documentation will need to be maintained for six years.
All PPP Loan borrowers and lenders should obtain a complete understanding of the all the calculation included in the PPP Loan Forgiveness Application to ensure all calculations submitted are accurate and are in accordance with the various and ever changing guidance issued by the SBA. Unfortunately, the PPP Loan Forgiveness Application calculations are extremely complex. To help navigate this complexity, we have developed the blumshapiro PPP Loan Forgiveness Toolkit & Calculator. We will continue to update the blumshapiro PPP Loan Forgiveness Toolkit & Calculator as additional guidance becomes available. As long as the blumshapiro PPP Loan Forgiveness Toolkit & Calculator is downloaded via the blumshapiro.com, all downloaders will get notified of any changes to the PPP Loan Forgiveness Toolkit & Calculator.
blum has been on the forefront of interpreting PPP guidance and providing trusted resources for clients to keep them apprised of constant changes, and providing the most up-to-date information to assist in calculating loan forgiveness. Our team is working with clients to assist them with navigating through compliance requirements of the loan forgiveness program, to ensure forgiveness is received, help expedite the loan forgiveness process and provide a reliable and trusted source of information. Learn more about our loan forgiveness services >>
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Disclaimer: The contents of this resource are for general informational purposes only. While every effort has been made to ensure its accuracy, the information is provided “as is” and no representations are made that the content is error-free. We have no obligation to update any content, comments or other information for retroactive or prospective interpretations or guidance provided by regulators, financial institutions or others. The information is not intended to constitute legal advice or replace the advice of a qualified professional. There are areas of the CARES Act where additional clarification from the Treasury Department and the SBA is needed. Your judgment and interpretation of the act may be needed. Users should consult with their legal counsel and representatives of the lending institution regarding the proper completion of their application and supporting documentation.