SBA To No Longer Rely on Economic Necessity Questionnaires in Processing PPP Forgiveness Applications
Client Alert | 1 min read | 08.02.21
On July 29, 2021, the Small Business Administration announced in an FAQ that it is discontinuing any reliance on the Loan Necessity Questionnaires, which the SBA had required of each borrower, that together with its affiliates, received Paycheck Protection Program loans with a principal amount of $2 million or greater. As we’ve previously discussed, in October 2020, the SBA had unexpectedly released SBA Forms 3509 an 3510 to collect information that would purportedly allow SBA loan reviewers to assess PPP borrowers’ certification that economic uncertainty made the PPP loan necessary to support ongoing operations. The SBA explains in the new FAQ that use of the forms have caused delays and do not provide for efficient use of SBA audit resources and as such use of these forms is discontinued. The FAQ also notes that the majority of public comments SBA received on the forms raised objections to their use.
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Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS). Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:
Client Alert | 4 min read | 04.18.24
Client Alert | 6 min read | 04.16.24
Navigating the AI Intellectual Property Maze - Key Points From Congressional Hearing
Client Alert | 5 min read | 04.15.24
Making the EU Courts More Efficient for Trade-Related Decisions
