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ARTICLE · 24 MAY 2020

Paycheck Protection Program: SBA Issues An Aggregate $20 Million Limit For Entities Within A "Single Corporate Group"

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On April 30, 2020, the U.S. Small Business Administration (SBA) issued its Seventh Interim Final Rule with respect to the Paycheck Protection Program (PPP), ...

United StatesCoronavirus (COVID-19)
Bijal N. Vira
Bijal N. Vira
Nirav Bhatt
Nirav Bhatt
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On April 30, 2020, the U.S. Small Business Administration (SBA) issued its Seventh Interim Final Rule1 with respect to the Paycheck Protection Program (PPP), as enacted under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).2

The Seventh Interim Final Rule limits the amount of PPP loans that any "single corporate group" may receive to $20 million in the aggregate. The SBA reasoned that the $20 million cap is necessary in light of the high demand for PPP loans by eligible businesses and to preserve the finite funds available under the PPP. This limitation for single corporate groups is effective immediately with respect to any PPP loan that has not yet been fully disbursed as of April 30, 2020. For PPP loans that have been partially disbursed, the limitation applies to any additional disbursement that would cause the total PPP loans to a single corporate group to exceed $20 million.

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