April 21, 2021
The Coronavirus Aid, Relief and Economic Security (the CARES) Act created the Paycheck Protection Program (Triple P or PPP) and entrusted it to the Small Business Administration (SBA). Since then, the US Treasury and the SBA have been relatively consistent in noting that the actions of lenders and borrowers will be weighed against the rules then in effect. The SBA and the Treasury have shown no hesitation in changing the rules well after substantial economic conduct has occurred. In light of the ever evolving Triple P, we have developed a timeline that captures every update specifically related to the Triple P since the passage of the CARES Act, including interim final rules, new FAQs, interagency guidance, and any other regulatory or agency action that impacts the Triple P. The timeline below is an abbreviated version of our comprehensive annotated timeline – please contact us for additional information.
The SBA updated its document on calculating maximum Paycheck Protection Program loan amounts by business type with information on self-employed borrowers. June 26, 2020
SBA released IFR on eligibility of certain telephone cooperatives, June 5, 2020
SBA released IFR on loan forgiveness, May 22, 2020
SBA released IFR on loan review procedures and related borrower and lender responsibilities, May 22, 2020
SBA released Procedural Notice describing the reporting process through which Lenders will report on PPP loans using Form 1502 and collect the processing fee on fully disbursed loans, May 21, 2020
SBA releases IFR on treatment of entities with foreign affiliates, May 18, 2020
SBA and Treasury release another set of PPP FAQs (Question 45), May 6, 2020
Interagency IFR released modifying the Liquidity Coverage Ratio (“LCR”) rule to support financial institutions participating in the PPPLF, May 5, 2020
SBA releases IFR on nondiscrimination, religious exemptions and additional eligibility criteria, May 5, 2020
SBA and Treasury release another set of PPP FAQs (Question 43), May 5, 2020
SBA and Treasury release another set of PPP FAQs (Questions 40-42), May 3, 2020
SBA releases IFR on maximum PPP loans for corporate groups, as well as eligibility requirements for non-bank and non-insured depository lenders, April 30, 2020
U.S. Department of Agriculture (“USDA”) releases FAQs for agricultural producers, farmers, and ranchers, April 25, 2020
SBA and Treasury release guidance on how to calculate maximum loan amounts by business type, April 24, 2020