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Exception Tracking Spreadsheet (TicklerTrax™)
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SBA extends deadline again

The Small Business Administration has updated its PPP FAQ yet again, adding question 48 to indicate it has extended the deadline for lenders to file the initial SBA Form 1502 to the later of May 29, 2020, or 10 calendar days after disbursement or cancellation of the PPP loan. The FAQ doesn't say so, but the reason for the extension (from the current deadline of May 22) is that the SBA hasn't yet finalized and published Form 1502.

Starting April 15, 2020, the SBA and Treasury have issued 12 interim final rules implementing the Paycheck Protection Program:

  • 4/15/20: 85 FR 20811 - Adding the PPP to SBA's 7(a) Loan Program (SBA)
  • 4/15/20: 85 FR 20817 - Additional guidance regarding the application of certain affiliate rules (SBA)
  • 4/20/20: 85 FR 21747 - Additional PPP eligibility criteria and requirements for certain pledges of PPP loans.(SBA)
  • 4/28/20: 85 FR 23450 - Information on requirement for promissory notes, authorizations, affiliation and eligibility (SBA)
  • 4/30/20: 85 FR 23917 - Authority for lenders to use alternative criterion for calculating maximum loan amount (seasonal workers) (Treasury)
  • 5/04/20: 85 FR 26324 - Limits on PPP loans to corporate groups and guidance on non-bank lender participation (SBA)
  • 5/04/20: 85 FR 26321 - Requirements on disbursements (SBA)
  • 5/08/20: 85 FR 27287 - Nondiscrimination obligations and additional eligibility criteria (SBA)
  • 5/19/20: 85 FR 29845 - Extending the safe-harbor date by which certain borrowers must repay loans to 5/14/20 (SBA)
  • 5/19/20: 85 FR 29842 - Guidance on the ability to increase certain PPP loans (SBA)
  • 5/19/20: 85 FR 29847 - Guidance on additional eligibility requirements for electric cooperatives (SBA)
  • 5/21/20: 85 FR 30835 - Treatment of entities with foreign affiliates (SBA)
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