On April 24, the Small Business Administration (SBA) issued its
Third Interim Rule containing guidance for execution of the
Coronavirus Aid, Relief, and Economic Security (CARES) Act's
Paycheck Protection Program (PPP). Although this is a final rule,
SBA will be taking comments from interested parties through May 25,
2020.
Among other items the Interim Rule responds to specific
questions concerning application of the affiliation rules,
eligibility for the program and justification for the necessity
determination. These topics are discussed in the following
section.
Rule Provisions
Affiliation.
The Interim Rule addresses application of the affiliation test in
the context of large companies, including private equity and hedge
funds.
