SBA Issues Procedural Notice on PPP Loans and Simple Forgiveness Application for Small Loans

Highlights
The Small Business Administration issued its long-awaited procedural notice regarding the treatment of PPP loans in change of ownership transactions
Most transactions will require that the amount of the PPP loan proceeds be placed into escrow with the PPP lender pending a determination on forgiveness
The SBA separately introduced a new, streamlined forgiveness application for PPP loans of $50,000 or less
Lenders of Paycheck Protection Program (PPP) loans have been faced with many questions related to borrowers’ change of ownership transactions and whether the change constituted a default. As a result, on Oct. 2, 2020, the Small Business Administration (SBA) issued a long-awaited procedural notice to PPP lenders that guides them through the process required for consenting to borrowers’ change of ownership transactions.
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