The Small Business Administration (the "SBA"), in
consultation with the Department of the Treasury, has been
providing, on an ongoing basis, additional guidance concerning the
implementation of the Paycheck Protection Program ("PPP")
under the Coronavirus Aid, Relief, and Economic Security Act (the
"CARES Act").
The following is a summary of guidance provided with respect to
the SBA's review of borrowers' certification concerning the
economic necessity of their PPP loan application, as well as
clarifications regarding (i) borrower eligibility, and (ii) the
scope of Payroll Costs under the PPP. Note this recent
guidance also provided clarifications with respect to other matters
that affect borrowers and lenders.