On April 3, 2020, the U.S. Department of the Treasury (Treasury) and U.S. Small Business Administration (SBA) released further guidance on the affiliation rules applicable to the Paycheck Protection Program (PPP), as enacted under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, via the Treasury’s Applicable Affiliation Rules fact sheet and the SBA’s Second Interim Final Rule[1] (collectively, the Updated Affiliation Guidance). The Updated Affiliation Guidance is supplemental to the SBA’s First Interim Final Rule that was issued on April 2, 2020.
Continue Reading Updates on the Affiliation Rules Applicable to the Paycheck Protection Program (Title I of the CARES Act)

Bijal Vira
Bijal Vira is a partner in the corporate and finance practice areas in the firm's New York office.
Updates on the Paycheck Protection Program under the CARES Act: The SBA’s April 2, 2020 Interim Final Rule
On April 2, 2020, the U.S. Small Business Administration (SBA) released its Interim Final Rule[1], which provides further guidance on the Paycheck Protection Program (PPP) as enacted under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. On April 2, 2020 the SBA also issued an updated sample application form.
The SBA’s Interim Final Rule clarifies, contradicts and provides additional interpretative guidance related to the CARES Act. We highlight the following:
Continue Reading Updates on the Paycheck Protection Program under the CARES Act: The SBA’s April 2, 2020 Interim Final Rule
Overview Of The Paycheck Protection Program Under The Cares Act (Title I)
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted, an economic relief package in response to the COVID-19 pandemic. The CARES Act provides economic support at the federal level to the business sector, employees, individuals and families, and specific industries that have been impacted, including air transportation, healthcare, and education.
Summarized below are key aspects of the Paycheck Protection Program, a $349 billion SBA-administered loan and loan forgiveness program described in Division A, Title I – Keeping American Workers Paid and Employed Act of the CARES Act.
Continue Reading Overview Of The Paycheck Protection Program Under The Cares Act (Title I)