The U.S. Treasury first released a series of FAQs with regard to the Paycheck Protection Program (“PPP”) on April 3, 2020. The list of FAQs continues to grow (almost daily) as new issues are identified. The latest update was issued on April 26, 2020. Many important questions are answered along with some updates, modifications, and new interpretations of the PPP including what is and is not included in the important term “Payroll Costs.” Specifically, the Treasury recently added Question 31 concerning the certification that borrowers must make concerning their need for the funding and the impact that other adequate forms of liquidity may have on that certification. If you have applied for funding under the PPP or are considering doing so, please be sure to read the FAQs as well as the other guidance provided by the original Interim Final Rule issued April 3, 2020, and the new Interim Final Rule – Promiossry Notes, Authorizations, Affiliation, and Eligibility issued on April 24, 2020. The newest interim rule makes clear, among other things, that bankruptcy debtors are not eligible to apply. Further guidance on the loan forgiveness component of the PPP is anticipated this week.
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