On May 15 and May 18, 2020, the Small Business Administration (“SBA”) provided additional guidance on the Paycheck Protection Program (“PPP”) through the release of the PPP Loan Forgiveness Application (the “Application,”) as well as the issuance of a new Interim Final Rule (the “Foreign Affiliates Rule”), which supplements the first PPP Interim Final Rule, published on April 2, 2020, and the subsequent interim final rules issued since that date (and linked below). The PPP is a small business loan program established pursuant to Title I of the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act signed by President Trump on March 27, 2020, and supplemented by the Paycheck Protection Program and Health Care Enhancement Act (the “PPP/HCE Act”), which provided additional funding for the program.
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