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Client Alert: Paycheck Protection Program Update: Continued Guidance on “Necessity” Certification – May 14, 2020


On May 13, 2020, the Small Business Administration (SBA) updated the Paycheck Protection Program (PPP) Loans Frequently Asked Questions (FAQs) to provide further guidance regarding PPP loan borrowers’ obligation, in their loan applications, to certify in good faith that their PPP loan request is necessary.  New FAQ 46 poses the question, “How will SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?”  This Alert discusses the SBA’s response, as well as other relevant FAQ’s.  The Alert can be found here.