Paycheck Protection Program – Where Are We Now? An Up-To-Date Guide To The Paycheck Protection Program

Originally published on April 14, 2020. Last updated as of the evening of May 1, 2020.

Since the enactment of the Coronavirus Aid, Relief, and Economic Security Act (the "CARES Act") on March 27, 2020, the U.S. Small Business Administration (the "SBA") and the U.S. Treasury Department ("Treasury") have issued a sizable number of rules and additional guidance to implement the CARES Act's marquee small business loan component – the Paycheck Protection Program (the "PPP").

To date, the SBA and Treasury have issued a number of Interim Final Rules governing the PPP (collectively, the "PPP Rules").¹ In addition, the SBA and Treasury have also published: borrower ( SBA Form 2483) and lender ( SBA Form 2484) application forms; program "fact sheets" for borrowers and lenders; a summary of the applicable affiliation rules; and responses to certain Frequently Asked Questions (which the SBA has updated numerous times).  This rapidly changing regulatory environment