Articles by Michael B. Glomb

In an interim final rule (“IFR”) issued on May 22, 2020,[1] the Small Business Administration (“SBA”) clarified the method by which Paycheck Protection Program (“PPP”) Loan Program funds must be expended and documented to support loan forgiveness. This “Loan Forgiveness IFR” is effective immediately but is subject to future modification…

Today, the Small Business Administration (SBA) issued new guidance relaxing anticipated scrutiny that borrowers were expecting under the Paycheck Protection Program.  In connection with a Paycheck Protection Program loan, a borrower must certify that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.”…

On April 24, 2020, the President signed into law the Paycheck Protection Program and Health Care Enhancement Act (“Act”) which, among other things,  provides an additional $321 billion for the Small Business Administration’s (SBA) popular and underfunded Paycheck Protection Program (PPP).  In addition to the Paycheck Protection enhancements, the Act…

This Client Alert is issued as part of a series of related alerts on important loan programs and loan program changes enacted through the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act.[1]  In response to this historic legislation, FTLF issued a Client Alert [found here] where we discussed two important…

Last Friday, April 3, 2020, eligible borrowers began submitting applications for business loans under the newly authorized “Paycheck Protection Program.”  Despite the Small Business Administration’s (“SBA”) final interim rule issued on April 2, 2020, borrowers and lenders were left with many questions.  In response, the SBA and Treasury Department recently…