Law Alert: PPP Loan Forgiveness Interim Final Rule Released
May 23, 2020
In what is becoming a pattern for SBA and Treasury, the much-anticipated Interim Final Rule (IFR) providing guidance for the calculation of PPP borrower loan forgiveness was released Friday evening. Unfortunately, it does not appear that it was worth the wait as the IFR does not provide much by way of additional guidance. Actually, two IFRs were released, one addressing loan forgiveness, and one addressing lender loan forgiveness application procedures and the SBA loan review process.
We are yet reviewing, but while some clarification is provided through examples contained in the IFR, the guidance seems to basically track with that contained in the loan application forms and instructions released last Friday. The lender IFR provides the framework for lender review of the complex loan forgiveness application and also indicates that SBA will be entitled to review loans in any amount for eligibility, authorized use of funds, and loan forgiveness.
If you have questions about the scope of the information contained in these IFRs or any other aspect of the PPP loan program, contact Scopelitis Partners Greg Feary, Steve Pletcher, Prasad Sharma or the Scopelitis COVID-19 Task Force.