Summary of Paycheck Protection Program Loan Forgiveness Guidance Prepared by The Groom Law Group On the evening of May 22, the Small Business Administration (“SBA”) and Department of Treasury released two interim final rules (“IFRs”) – one IFR relating to the rules that will apply in determining the amounts eligible for loan forgiveness under the Paycheck Protection Program (“PPP”) (“Forgiveness Rules IFR”), and a second IFR relating to the process under which requests for loan forgiveness will be reviewed by lenders and the SBA (“Forgiveness Process IFR”). Forgiveness Rules IFR Much of the content of the Forgiveness Rules IFR affirms concepts that were already reflected in the Loan Forgiveness Application (“LFA”) that SBA released last Friday, May 15. However, some of the highlights are as follows: Eligible Payroll Costs • Affirms that borrowers can measure payroll costs based on either the 8-week default covered period (beginning on the loan disbursement date) or an “alterna
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