Yesterday, the SBA released two new interim final rules related to PPP Loan Forgiveness and PPP Loan Review. The two new rules largely track information that was included in the Loan Application released a week ago with some notable additional points:

The PPP Loan Forgiveness Rules clarify the following:

• To the extent a borrower chooses an alternative payroll covered period to align with its next payroll date, non-payroll costs will still be measured during the original eight week covered period following disbursement of the loan.

The PPP Loan Review Rules clarify the following:

• The SBA may review a borrower’s eligibility, loan amount and use of proceeds, and loan forgiveness amounts for any size loan at any time. All documents must be saved for six years after the loan is forgiven or repaid in full;

• SBA may request additional documentation at any time;

• A borrower may appeal the SBA’s determinations. Additional guidance on appeal procedures will be issued at a later date.

A link to Polsinelli’s prior article summarizing all of the application requirements.

See the full PPP Loan Forgiveness Rules here.

See the full PPP Review Rules here.