Sean Bryan Authors Article on Additional Draws on PPP Loans

Sean Bryan’s column—entitled “Additional Draws on PPP Loans for Partnerships and Employers with Seasonal Employees"—addresses the new Interim Final Rule on PPP loans.

On May 13, 2020, the Small Business Administration issued a new Interim Final Rule regarding PPP Loans.  The new guidance provides several exceptions to the prior rules.  First, if a partnership received a PPP loan where the compensation to partners was not included, it may make a request for an addition to its PPP loan; this remains subject to the $100,000 cap on annualized partner compensation.  The new guidance also permits a seasonal employer who would have received a higher PPP loan under the alternative criteria posted April 28 to request an additional loan.   

Both of these are restricted, however, to the period before a borrower’s lender first submitted a report to the SBA on Form 1502 that included the initial loan.  This form is generally to be submitted within 20 days after a PPP loan is approved, or for loans approved before the updated reporting process was put in place, by May 22.  So this new guidance may be inapplicable for early borrowers, and interested borrowers are advised to check with their lender as soon as possible.  

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