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Exception Tracking Spreadsheet (TicklerTrax™)
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SBA issues procedural notice on PPP ownership changes

The SBA has issued a Procedural Notice on "Paycheck Protection Program Loans and Changes of Ownership," effective October 2, 2020. A change of ownership for this purpose occurs when—

  1. at least 20 percent of the common stock or other ownership interest of a PPP borrower (including a publicly traded entity) is sold or otherwise transferred, whether in one or more transactions, including to an affiliate or an existing owner of the entity,
  2. the PPP borrower sells or otherwise transfers at least 50 percent of its assets (measured by fair market value), whether in one or more transactions, or
  3. a PPP borrower is merged with or into another entity.

Prior to the closing of any change of ownership transaction, the PPP borrower must notify the PPP Lender in writing of the contemplated transaction and provide the PPP Lender with a copy of the proposed agreements or other documents that would effectuate the proposed transaction.

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