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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.

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....