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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 Since the passage of the legislation a week ago and with only limited preliminary guidance and now-superseded applications from both Treasury and SBA, businesses and lenders have been scrambling to understand loan eligibility, how to apply, as well as key loan terms.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 | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....