SBA Caps the Aggregate Amount of PPP Loans Each Corporate Family Can Receive
Client Alert | 1 min read | 05.01.20
On April 30, 2020, the Small Business Administration (SBA) released an interim final rule imposing a $20 million cap on the aggregate amount of loans a single corporate group can receive from the Paycheck Protection Program (PPP). Given the high demand for PPP loans and finite appropriations, the SBA has imposed this limit in order to ensure PPP funds reach the largest possible number of borrowers.
Businesses are part of a single corporate group if they are majority owned, directly or indirectly, by a common parent based on the broad definition in the interim final rule. This cap applies without limitation even to those businesses that are eligible for the otherwise applicable waiver-of-affiliation provisions.
This cap applies to PPP loan funds that have not yet been fully disbursed as of April 30, 2020. This means that the cap applies not only to all PPP loans to be made in the future but also to any loans that have only been partially disbursed. The interim final rule makes it incumbent on PPP recipients and applicants to determine if they will receive PPP loans in excess of the cap and withdraw or request cancellation of any pending PPP loan application or approved PPP loan not in compliance with this rule. The Crowell & Moring Team is closely watching these developments and is standing by to confer with companies about the impact of this new loan ceiling.
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Client Alert | 5 min read | 12.12.25
Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality
On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument.
Client Alert | 8 min read | 12.11.25
Director Squires Revamps the Workings of the U.S. Patent Office
Client Alert | 8 min read | 12.10.25
Creativity You Can Use: CJEU Clarifies Copyright for Applied Art
Client Alert | 4 min read | 12.10.25
Federal Court Strikes Down Interior Order Suspending Wind Energy Development
