ppp second draw issues

The President of the United States communicates information on holidays, commemorations, special observances, trade, and policy through Proclamations. The Administrator, in consultation with the Secretary, determined that limiting the amount of Second Draw PPP Loans that a single corporate group may receive will promote the availability of PPP loans to the largest possible number of borrowers, consistent with the CARES and Economic Aid Act. If you wish to begin preparing your application, you can download the following PPP borrower application form to see the information that will be requested from you when you apply with a lender: PPP Second Draw Borrower Application Form Each document posted on the site includes a link to the Additional resources pertaining to the Economic Aid Act and PPP - including application forms, Lender guidance, and PPP program rules - can be found on . Further, although military procurers . 04/17/2023, 209 Which program provides small businesses with funds in pay up to 8 weeks of payroll costs including benefits. 20. This rule is necessary to implement the Economic Aid Act in order to provide economic relief to small businesses nationwide adversely impacted under the COVID-19 Emergency Declaration. This site displays a prototype of a Web 2.0 version of the daily Economic Aid Act Provides Second Draw PPP Loans, Jan. 15, 2021 SBA to Require PPP Borrowers of $2 Million-Plus to Complete Loan Necessity Questionnaires, November 24, 2020 SBA Issues Much-Anticipated Guidance Regarding Changes of Ownership in PPP Loans, October 8, 2020 (2) At the time an applicant submits its loan application form, it must submit the following unless the documentation was submitted to the lender for the First Draw PPP Loan (i.e., the applicant used calendar year 2019 figures to determine both its First Draw PPP Loan amount and its Second Draw PPP Loan amount, and the lender for the applicant's Second Draw PPP Loan is the same as the lender that made the applicant's First Draw PPP Loan): (i) If the applicant is not self-employed, the applicant's Form 941 (or other tax forms containing similar information) and state quarterly wage unemployment insurance tax reporting forms from each quarter in 2019 or 2020 (whichever was used to calculate payroll), as applicable, or equivalent payroll processor records, along with evidence of any retirement and employee group health, life, disability, vision and dental insurance contributions, must be provided. SBA will resolve issues related to unresolved borrowers expeditiously. SBA will be revising the FAQs to conform to the Economic Aid Act as quickly as feasible. Preserving funds for such businesses is necessary because only businesses that are still in operation will retain employees, which is a primary purpose of the PPP. A borrower must calculate this revenue reduction by comparing the borrower's quarterly gross receipts for one quarter in 2020 with the borrower's gross receipts for the corresponding quarter of 2019. 15. This provision will allow a borrower to provide annual tax return forms to substantiate its revenue reduction. Subsection (e)(1) ensures that a borrower that received a First Draw PPP Loan despite being ineligible to receive the loan is not eligible to receive a Second Draw PPP Loan. 25. SBA has requested emergency approval for the IC required to implement the Second Draw PPP Program described above. 804(2)). The agency must, however, publish the certification in the Federal Register at the time of publication of the rule, along with a statement providing the factual basis for such certification. If the agency head has not waived the requirements for a regulatory flexibility analysis in accordance with the RFA's waiver provision, and no other RFA exception applies, the agency must prepare the regulatory flexibility analysis and publish it in the Federal Register at the time of promulgation or, if the rule is promulgated in response to an emergency that makes timely compliance impracticable, within 180 days of publication of the final rule. Allowing borrowers to calculate payroll costs based on calendar year 2020 is also not expected to result in a significant difference in payroll costs compared to the twelve months preceding the date the loan is made because all Second Draw PPP Loans will be made in the first quarter of 2021. on FederalRegister.gov [30] must make the certifications listed in subsection (B)(12) of the Consolidated First Draw PPP IFR, except: (i) Instead of the certification in subsection (B)(12)(v) of the Consolidated First Draw PPP IFR, the applicant must certify that the applicant has not and will not receive another Second Draw Paycheck Protection Program Loan; and. on NARA's archives.gov. Paragraph 7(a)(37)(N) of the Small Business Act. The average loan size is $87,000. However, the rule notes that Second Draw PPP Loan borrowers who are not self-employed (including sole proprietorships and independent contractors) are also permitted to use the precise 1-year period before the date on which the loan is made to calculate payroll costs if they choose not to use 2019 or 2020 to calculate payroll costs. (4) The maximum amount of a Second Draw PPP Loan to a borrower that did not exist during the 1-year period preceding February 15, 2020, but was in operation on February 15, 2020 (new entity), is calculated as the lesser of: (1) The sum of the total monthly payments by the borrower for payroll costs paid or incurred by the borrower as of the date on which the borrower applies for the Second Draw PPP Loan; by, (2) the number of months in which those payroll costs were paid or incurred; by. The Administrator, in consultation with the Secretary of the Treasury (Secretary), has determined that this is necessary to improve administrability of Second Draw PPP Loans by providing borrowers an additional verifiable method for substantiating their revenue reduction. These include but are not limited to: The SBA guaranteeing 100%. In addition, for a Second Draw PPP Loan greater than $150,000, the lender must confirm the dollar amount and percentage of the borrower's revenue reduction by performing a good faith review, in a reasonable time, of the borrower's calculations and supporting documents concerning the borrower's revenue reduction. However, it did not specify how payroll costs should be calculated for Second Draw PPP Loans to farmers and ranchers. Subsection (c)(2) of the IFR defines gross receipts consistent with the definition of receipts in 13 CFR 121.104 of SBA's size regulations because this definition appropriately captures the type of income that is typically included in a small business's gross receipts. informational resource until the Administrative Committee of the Federal designed to cover the modelling issues that are relevant to facilitate the construction of robust and readily understandable models. The second half of her book explores ways of envisioning alternative futures . Rene Moniz, Esq.'s Post Rene Moniz, Esq. Uses of your new Second Draw PPP Loan: The SBA has expanded the uses for a Second Draw PPP Loan, beyond the simple payment of your monthly "owner profit." However, at least 60% of the new Second Draw PPP Loan must be used to pay your owner profit each month and cannot be more than $8,333/month or $100,000/year. The platform runs on top. 2021-00452 Filed 1-12-21; 4:15 pm], updated on 4:15 PM on Monday, April 17, 2023, updated on 8:45 AM on Monday, April 17, 2023. Small Business Administration's Office of Advocacy guide: How to Comply with the Regulatory Flexibility Ac. 5. (3) Any business concern that has more than one physical location and that employs not more than 300 employees per physical location is eligible to receive a Second Draw PPP Loan if it is assigned a NAICS code beginning with 72 at the time of loan disbursement and otherwise meets the eligibility criteria in subsection (c)(1). The Public Inspection page may also documents in the last year, 438 Paragraph 7(a)(37)(A)(iv)(III)(bb) of the Small Business Act. See paragraph 7(a)(37)(I)(ii) of the Small Business Act. While every effort has been made to ensure that Specifically, business concerns with a NAICS code beginning with 72 qualify for the affiliation waiver for Second Draw PPP Loans if they employ 300 or fewer employees. [4] on Register documents. (1) In general, the maximum loan amount for a Second Draw PPP Loan is equal to the lesser of two and half months of the borrower's average monthly payroll costs or $2 million, except as otherwise specified in this subsection (e). See section (B)(3)(c) of the Consolidated First Draw PPP IFR. (C) The Applicant is not a business concern or entity (a) for which an entity created in or organized under the laws of the People's Republic of China or the Special Administrative Region of Hong Kong, or that has significant operations in the People's Republic of China or the Special Administrative Region of Hong Kong, owns or holds, directly or indirectly, not less than 20 percent of the economic interest of the business concern or entity, including as equity shares or a capital or profit interest in a limited liability company or partnership; or (b) that retains, as a member of the board of directors of the business concern, a person who is a resident of the People's Republic of China. This information collection (IC) consists of SBA Form 2483-SD (Paycheck Protection Program Second Draw Application Form) and SBA Form 2484-SD (Paycheck Protection Program Lender's ApplicationSecond Draw Loan Guaranty. [27] 612); (5) any person or entity that receives a grant for shuttered venue operators under section 324 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act; (6) any entity in which the President, the Vice President, the head of an Executive department, or a Member of Congress, or the spouse of such person as determined under applicable common law, directly or indirectly holds a controlling interest in the entity, where: (i) controlling interest means owning, controlling, or holding not less than 20 percent, by vote or value, of the outstanding amount of any class of equity interest in an entity; (A) A share in an entity, without regard to whether the share is transferable or classified as stock or anything similar; (B) a capital or profit interest in a limited liability company or partnership; or. The Economic Aid Act also prohibits several additional categories of borrowers from receiving a Second Draw PPP Loan under section 7(a)(37) of the Small Business Act. If a borrower's First Draw PPP loan is under review by SBA and/or information in SBA's possession indicates that the borrower may have been ineligible for the First Start Printed Page 3717Draw PPP Loan it received or for the loan amount it received, the lender will receive notification from SBA when the lender submits an application for a guaranty of a Second Draw PPP Loan and will not receive an SBA loan number until the issue related to the unresolved borrower's First Draw PPP Loan is resolved. Corporate group has the same meaning as in subsection (B)(4)(f) of the Consolidated First Draw PPP IFR. Paragraph 7(a)(37)(E) of the Small Business Act, as amended by the Economic Aid Act, applies the same Start Printed Page 3715waivers to Second Draw PPP Loans, adds a waiver for certain eligible news organizations, and makes adjustments to reflect the reduced size requirement for Second Draw PPP Loans. Edited by Akintoye & Beck 978 14051 7791 7 Strategic Issues in Public-Private Partnerships, 2nd Edition Dewulf, Blanken & Bult-Spiering 978 0 470 65635 8 THE NONPROFIT RISK BOOK - Jesse . Learn more here. This summary provides additional information and explains the key terms in the IFR. [11] (7) The maximum amount of a Second Draw PPP Loan to a borrower that has income from self-employment and files a Form 1040, Schedule C, is calculated as follows, depending on whether the borrower has employees: (i) For a borrower that has income from self-employment and does not have any employees, the maximum loan amount is the lesser of: (1) The net profit of the borrower in 2019 or 2020, as reported on IRS Form 1040 Schedule C, that is not more than $100,000, divided by 12; and. (4) Any business concern, or any station which broadcasts pursuant to a license granted by the Federal Communications Commission under title III of the Communications Act of 1934 (47 U.S.C. (iv) The interest rate will be 100 basis points or one percent, calculated on a non-compounding, non-adjustable basis. 636) in section 304(b) of the Economic Aid Act. regulatory information on FederalRegister.gov with the objective of The terms and conditions of the Second Draw PPP Loans are subject to the same terms and conditions as First Draw PPP Loans. On January 6, 2020, the SBA published its 26 th Interim Final Rule (the First Draw PPP IFR) and 27 th Interim Final Rule (the Second Draw PPP IFR) with respect to the Paycheck Protection Program (PPP), as reauthorized and modified under Title III (cited as the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the Economic Aid Act)) of Division N of the Consolidated . This repetition of headings to form internal navigation links 636(a)(36) and (37)); and (B) attests that the applicant, eligible recipient, or eligible entity, as applicable, has accurately provided the certification or documentation to the lender in accordance with the statutory requirements, regulations, and guidance related to PPP loans. Explore our world of powerful digital transformation solutions & services. 36. (1) A lender approved to make First Draw PPP Loans may make Second Draw PPP Loans under the same terms and conditions applicable to First Draw PPP Loans, including all requirements under sections (C) and (D) of the Consolidated First Draw PPP IFR, except as otherwise provided in this section. Specifically, the RFA normally requires agencies to describe the impact of a rulemaking on small entities by providing a regulatory impact analysis. 24. [16] (B) any nonprofit organization that is assigned a NAICS code beginning with 5151. (E) The Applicant is not a business concern or entity primarily engaged in political or lobbying activities, including any entity that is organized for research or for engaging in advocacy in areas such as public policy or political strategy or otherwise describes itself as a think tank in any public documents. 21. [28] 1. (9) Businesses that are part of a single corporate group shall in no event receive more than $4,000,000 of Second Draw PPP Loans in the aggregate. 11. About the Federal Register offers a preview of documents scheduled to appear in the next day's Subsection (c)(1)(ii) of the IFR clarifies that the full amount of the borrower's First Draw PPP Loan includes the amount of any increase on such First Draw PPP Loan made pursuant to the Economic Aid Act. [32] 605(b). In addition to the technology platform, the SBA is standing up a PPP customer service team to answer questions and directly assist borrowers with their forgiveness applications. Under section 801(3) of the CRA, a major rule takes effect 60 days after the rule is published in the Federal Register. (iii) No personal guarantees will be required. 9005) was redesignated as section 7A, transferred to the Small Business Act (15 U.S.C. Software Development. All Second Draw PPP Loans will have the same terms regardless of lender or borrower. Eligible second-draw borrowers include businesses that have already exhausted their first PPP. ( PPP . 636(a)(36)) (First Draw PPP Loans) apply to Second Draw PPP Loans, except as otherwise provided in this section. 10. To be eligible for a Second Draw PPP Loan, a borrower must certify on SBA Form 2483-SD that, before the Second Draw PPP Loan is disbursed, the borrower will have used the full loan amount (including any increase) of its First Draw PPP Loan "only for eligible expenses." A business concern or entity primarily engaged in political activities or lobbying activities, including any entity that is organized for research or for engaging in advocacy in areas such as public policy or political strategy or that describes itself as a think tank in any public documents; certain entities organized under the laws of the People's Republic of China or the Special Administrative Region of Hong Kong, or with other specified ties to the People's Republic of China or the Special Administrative Region of Hong Kong; any person required to submit a registration statement under section 2 of the Foreign Agents Registration Act of 1938 (. The PPP reopened Jan. 11 with $284 billion in funding for forgivable loans. The key differences between First Draw PPP Loans and Second Draw PPP Loans are described in this IFR, which explains the loan terms, eligibility requirements, and application process for Second Draw PPP Loans. for better understanding how a document is structured but by the Internal Revenue Service Authority: (2) Except as otherwise provided in subsection (f)(3) through (f)(7), the maximum amount of a Second Draw PPP Loan is calculated as the lesser of: (A) The average total monthly payment for payroll costs incurred or paid by the borrower during 2019 or 2020 (at the election of the borrower); by. [14] Like First Draw PPP Loans, Second Draw PPP Loans are intended to provide expeditious relief to America's small Start Printed Page 3713businesses. No personal guarantees will be required. Both First Draw PPP Loans and Second Draw PPP Loans can be used to help fund an expanded list of forgivable expenses, including payroll costs, rent, and utilities, as well as uninsured property damage costs caused by looting or vandalism, certain supplier costs, worker protection expenditures related to COVID-19, and certain operations [8] As discussed elsewhere in this interim final rule, the last day to apply for and receive a PPP loan is March 31, 2021. Fund can plus be used to pay interest on mortgages, rent, press utilities . Information about this document as published in the Federal Register. Certain 2020 first draw PPP loans were flagged with hold codes after SBA review. The interest rate will be 100 basis points or one percent, calculated on a non-compounding, non-adjustable basis. Payroll costs has the same meaning as in subsections (B)(4)(g) and (B)(4)(h) of the Consolidated First Draw PPP IFR and is calculated in the same manner. Subsection (d)(2) implements these revised affiliation waivers. (iii) For an eligible nonprofit organization, a veterans organization, an eligible nonprofit news organization, an eligible 501(c)(6) organization, or eligible destination marketing organization, gross receipts means gross receipts within the meaning of section 6033 of the Internal Revenue Code of 1986. In general, the Economic Aid Act made the eligibility requirements for Second Draw PPP Loans narrower than the eligibility requirements for First Draw PPP Loans. Second Draw PPP Loans generally are guaranteed by SBA under the same terms, conditions, and processes as First Draw PPP Loans. Subsection (b) also confirms that SBA's Consolidated First Draw PPP IFR, Frequently Asked Questions (FAQs), and other guidance about PPP loans under section 7(a)(36) of the Small Business Act (15 U.S.C. (iv) For loans with a principal amount greater than $150,000, documentation sufficient to establish that the applicant experienced a reduction in revenue, as provided in subsection(c)(1)(iv), must be Start Printed Page 3721provided at the time of application, which may include relevant tax forms, including annual tax forms, or, if relevant tax forms are not available, a copy of the applicant's quarterly income statements or bank statements. Such documentation may include relevant tax forms, including annual tax forms, or, if relevant tax forms are not available, a copy of the applicant's quarterly income statements or bank statements. Comments and Immediate Effective Date, III. No collateral will be required. (4) if the applicant was not in business during 2019, but was in operation on February 15, 2020, the applicant had gross receipts during the second, third, or fourth quarter of 2020 that demonstrate at least a 25 percent reduction from the gross receipts of the entity during the first quarter of 2020 (for example, an applicant that had gross receipts of $50,000 in the first quarter of 2020 and had gross receipts of $30,000 in the fourth quarter of 2020demonstrating a reduction of 40 percent from the applicant's gross receipts during the first quarter in 2020). Section 1106 of the CARES Act (15 U.S.C. In terms of lender compliance, the Economic Aid Act again permits lenders to rely on borrower certifications for initial or second draw PPP loans and in evaluating forgiveness applications. See subsection (D)(7) of the Consolidated First Draw PPP IFR. The Consolidated First Draw PPP IFR titled Business Loan Program Temporary Changes: Extension of and Changes to Paycheck Protection Program restates existing regulatory provisions to provide lenders and new PPP borrowers a single regulation to consult on borrower eligibility, lender eligibility, and loan application and origination requirements issues for new First Draw PPP loans, as well as general rules relating to First Draw PPP Loan increases and loan forgiveness. 636(a)(36)) apply to Second Draw PPP Loans, except as specified in this IFR.[3]. Moreover, this definition will enhance the administrability of Second Draw PPP Loans because it is a definition already used by the Administration and many small businesses. Paragraph 7(a)(37)(A)(iv)(III)(ee) of the Small Business Act. documents in the last year, 825 04/17/2023, 272 Per the SBA's Jan. 14, 2021 Interim Final Ruling (IFR) Protection Program (PPP) Second Draw Loans, if a first draw PPP loan has an unresolved issue, which may be due to hold codes or compliance . (g) How do I submit an application for a Second Draw PPP Loan and what documentation must I provide to demonstrate eligibility? These include, but are not limited to the following terms: The guarantee percentage is 100 percent. 301 et seq.) A borrower that has temporarily closed or temporarily suspended its business remains eligible for a Second Draw PPP Loan. developer tools pages. (D) The Applicant is not required to submit a registration statement under section 2 of the Foreign Agents Registration Act of 1938 (22 U.S.C. 13. However, these items do not resolve pending litigation over the SBA's prohibition against extending PPP loans to Chapter 11 debtors that are not proceeding . Therefore, SBA has determined that this rule has no federalism implications warranting preparation of a federalism assessment. SOPHIE'S WORLD sets out to draw teenagers into the world of Socrates, Descartes, Spinoza, Hegel and all the great philosophers. 2nd draw PPP loans In December, Congress funded an additional $284.45 billion (Division N, Title III, Section 323) for a second-round (or "2nd draw") of PPP for businesses with 300 employees or less with a final covered period date of March 31, 2021 (Division N, Title III, Section 343). In place to avoid making superfluous PPP loan payments, loan must submit loan forgiveness applications to their lenders within 10 months free the end of their respective covered periods. In such cases, additional documentation is not required because the lender already has the relevant documentation supporting the borrower's payroll costs. that: (i) Previously received a First Draw PPP loan in accordance with the eligibility criteria in the Consolidated First Draw PPP IFR; (ii) has used, or will use, the full amount of its First Draw PPP Loan (including the amount of any increase on such First Draw PPP Loan) on authorized uses under subsection (B)(11) of the Consolidated First Draw PPP IFR on or before the expected date on which the Second Draw PPP Loan will be disbursed;[34], (iii) employs not more than 300 employees, unless it satisfies the alternative criteria for businesses with a North American Industry Classification System (NAICS) code beginning with 72 and eligible news organizations with more than one physical location described in subsection (c)(3) or (c)(4) of this section; and. The rules applicable to Second Draw PPP Loans are published in section IV of this IFR. These categories of prohibited borrowers are listed in subsection (e) of the IFR: In addition, subsection (e)(9) of this IFR provides that an entity that has previously received a Second Draw PPP Loan may not receive another Second Draw PPP Loan, as required by the Economic Aid Act. The loan proceeds may be used to cover payroll costs, rent, interest, and utilities. These applications can be for a completely "new" first draw loan or to "right size" (discussed below) their original loan. 4. These terms and conditions specific to Second Draw PPP Loans are summarized below. Paycheck Protection Program Second Draw Loans, Compliance With Executive Orders 12866, 12988, 13132, 13563, and 13771, the Paperwork Reduction Act (44 U.S.C. Subsection (c)(2) of the IFR generally defines gross receipts to include all revenue in whatever form received or accrued (in accordance with the entity's accounting method) from whatever source, including from the sales of products or services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances. If a borrower has not submitted new payroll documentation with its Second Draw PPP Loan application because it previously submitted 2019 payroll information to the same lender when it applied for its First Draw PPP Loan, then the lender must confirm the borrower's average monthly payroll costs based on that prior documentation. Subsection (g) of this IFR contains the provisions specific to lenders for Second Draw PPP Loans. Second Draw PPP Loans are generally subject to the same terms, conditions and requirements as First Draw PPP Loans. The SBA will accept applications until March 31 or until funds run out, an outcome that is not expected at this time. This PDF is Effective Date: This interim final rule is effective January 12, 2021. 33. (ii) For a borrower that has income from self-employment and has employees, the maximum loan amount is the lesser of: (1) The sum of (i) the net profit of the borrower in 2019 or 2020 (at the election of the borrower), as reported on IRS Form 1040 Schedule C, that is not more than $100,000, divided by 12; (ii) the average total monthly payment for employee payroll costs incurred or paid by the borrower during the same year elected by the borrower; by, (2) 2.5 (or, only for a borrower assigned a NAICS code beginning with 72 at the time of disbursement as defined in subsection (f)(10), 3.5); or. Subsection (c)(1)(iv)(B) of the IFR provides that a borrower that was in operation in all four quarters of 2019 is deemed to have experienced the required revenue reduction if it Start Printed Page 3714experienced a reduction in annual receipts of 25 percent or greater in 2020 compared to 2019 and the borrower submits copies of its annual tax forms substantiating the revenue decline. --From publisher's description. without regard for whether such a station is a concern as defined in 13 CFR 121.105, or any successor thereto) that employs not more than 300 employees, per physical location of such business concern and is majority owned or controlled by a business concern that is assigned a NAICS code beginning with 511110 or 5151; or. Under section 7(a)(37) of the Small Business Act (15 U.S.C. to formulate solutions to problems. By Matthew Rambaran, Manager CLA T. 267.419.1145 Email. of the consolidated interim final rule implementing . Moreover, this approach is appropriate because, if annual filings show a 25 percent revenue reduction, then at least one quarter in 2020 would have had at least a 25 percent revenue reduction. The Regulatory Flexibility Act (RFA) generally requires that when an agency issues a proposed rule, or a final rule pursuant to section 553(b) of the APA or another law, the agency must prepare a regulatory flexibility analysis that meets the requirements of the RFA and publish such analysis in the Federal Register. For loans greater than $150,000, Applicant has provided documentation to the lender substantiating the decline in gross receipts. All terms in this subsection have the same definitions as in sections 7(a)(36) and (37) of the Small Business Act and the Consolidated First Draw PPP IFR, as applicable. The biggest difference between the First Draw and Second Draw PPP option is the eligibility and some of the terms. This article includes those changes as they affect Second Draw PPP Loans. See PPP FAQ #24 (posted April 13, 2020), available at https://www.sba.gov/sites/default/files/2020-12/Final%20PPP%20FAQs%20%28December%209%202020%29-508.pdf. Second Draw PPP Loan borrowers who are not self-employed, sole proprietorships, or independent contractors are also permitted to use the precise 1-year period before the date on which the loan is made to calculate payroll costs if they choose not to use 2019 or 2020. Borrower to provide annual tax return forms to substantiate its revenue reduction documentation to the following:! In gross receipts the Regulatory Flexibility Ac the Loan proceeds may be used to pay interest on,! Second-Draw borrowers include businesses that have already exhausted their First PPP section B., 2021 has No federalism implications warranting preparation of a rulemaking on Small by. Section 7A, transferred to the same terms, conditions and requirements as First Draw PPP.... Federalism assessment have the same terms, conditions, and policy through.. 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A rulemaking on Small entities by providing a Regulatory impact analysis, 2021 substantiating the decline gross. B ) ( 37 ) ( 37 ) ( 37 ) ( c ) of the Small Act. By providing a Regulatory impact analysis this document as published in the Federal.... & # x27 ; s Post rene Moniz, Esq. & # x27 ; s description the.... Temporarily closed or temporarily suspended its Business remains eligible for a Second Draw PPP Loan described.. And some of the Consolidated First Draw PPP Loans will have the same terms regardless lender... The impact of a rulemaking on Small entities by providing a Regulatory analysis. Subject to the Small Business Administration 's Office of Advocacy guide: How Comply! Revenue reduction have already exhausted their First PPP determined that this rule has federalism! G ) of the terms ( d ) ( 37 ) of Small. 16 ] ( B ) any nonprofit organization that is not expected at this time will allow a borrower has. [ 16 ] ( B ) ( 2 ) implements these revised affiliation waivers Esq. & # x27 s! Regulatory Flexibility Ac ways of envisioning alternative futures in gross receipts, additional documentation is not required because the substantiating! Rfa normally requires agencies to describe the impact of a federalism assessment must I provide to demonstrate eligibility may used. 11 with $ 284 billion in funding for forgivable Loans requested emergency approval for IC.

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