On April 29 and April 30, 2020, the Small Business Administration (“SBA”) provided additional guidance on the Paycheck Protection Program (“PPP”) through the issuance of a new PPP Interim Final Rule (the “Corporate Group Rule”), which supplements the first PPP Interim Final Rule, published on April 2, 2020, and the subsequent interim final rules issued since that date, as well as issuing updates to the Frequently Asked Questions document (“FAQs”) originally published on April 2, 2020 and updated regularly thereafter. The PPP is a small business loan program established pursuant to Title I of the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act signed by President Trump on March 27, 2020, and supplemented by the Paycheck Protection Program and Health Care Enhancement Act (the “PPP/HCE Act”), which provided additional funding for the program.
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