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CARES Act Small Business Loans Move Forward but with Significant Revisions

Client Alert | 1 min read | 04.03.20

In the early morning hours of April 3, 2020, SBA has released an overhauled Paycheck Protection Program (PPP) loan application form (SBA Form 2483) and Treasury has posted a draft temporary Interim Final Rule implementing Sections 1102 and 1106 of the CARES Act. Since the passage of the legislation a week ago and with only limited preliminary guidance and now-superseded applications from both Treasury and SBA, businesses and lenders have been scrambling to understand loan eligibility, how to apply, as well as key loan terms. The new SBA Form 2483 and the draft Interim Final Rule reflect significant developments since the legislation and prior guidance, and, SBA has cautioned that additional guidance is still forthcoming on such essential issues as affiliation analysis, loan forgiveness, advance purchase for loans sold in the secondary market, and religious liberty protections under the PPP. As soon as possible, we will be issuing a client alert with a summary of the most significant changes or guidance. In the days ahead, we will be providing a revised, detailed summary of the PPP and eligibility questionnaire as well as scheduling another webinar so companies can stay current. The Crowell & Moring team is working with clients across many industries, and we hope you will reach out with questions.

Insights

Client Alert | 5 min read | 06.04.26

EU Pay Transparency Directive: The Transposition Deadline is Looming — What Now?

Three years have passed since the EU Pay Transparency Directive ("PTD") came into existence, and it now appears highly likely that very few EU Member States will have fully transposed its provisions into national law by the 7 June 2026 deadline.  For employers operating across the EU, this creates a deeply uncomfortable question: what are your obligations right now?...