[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-306364-105":53,"doc-detail-306364-en":126},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":119,"head_meta":121,"extra_data":123,"updated_unix":125},105,"en","cares-act-update-sba-issues-interim-final-rule-for-paycheck-protection-program-april-3-2020","CARES Act UPDATE: SBA Issues Interim Final Rule for Paycheck Protection Program - April 3, 2020","","April 3, 2020 memorandum updates previously issued guidance on the Paycheck Protection Program (PPP) under the SBA’s Section 7(a) lending program, as expanded by the CARES Act. It summarizes key clarifications from the SBA interim final rule and the revised borrower loan application form, focusing on first-come first-served processing, the 1.00% interest rate, eligibility and certification changes, updated citizenship/residency questions, payroll cost measurement issues, treatment of independent contractors, and exclusions for certain federal employment taxes.",{"@graph":63,"@context":118},[64,80,101],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/cares-act-update-sba-issues-interim-final-rule-for-paycheck-protection-program-april-3-2020/306364/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/cares-act-update-sba-issues-interim-final-rule-for-paycheck-protection-program-april-3-2020/306364.png","ImageObject",442,249,{"name":88,"@type":89},"Lute","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-06","2026-09-19",true,{"@type":98,"interactionType":99,"userInteractionCount":79},"InteractionCounter",{"@type":100},"ViewAction",{"@type":102,"mainEntity":103},"FAQPage",[104,110,114],{"name":105,"@type":106,"acceptedAnswer":107},"How are PPP loans processed under the interim final rule?","Question",{"text":108,"@type":109},"PPP loans are issued on a first-come, first-served basis. 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The IFR and revised application form clarify certain issues raised under the CARES Act and previously issued guidance on the PPP, although in some respects are contrary to previously issued guidance. This memorandum summarizes certain key aspects of the IFR and revised application form as they relate to such prior guidance.  \nBorrower Considerations  \nAmong the key updates arising out of the IFR and revised loan application form pertinent to borrowers are the following:  \n􀂃  First-Come, First-Served. The IFR expressly states that PPP loans will be made on a first-come, first served basis.Given the anticipated high demand for this program, prospective borrowers should submit their loan applications as soon as possible.  \n􀂃  Interest Rate.Contrary to guidance published by the U.S.Treasury earlier this week, all PPP loans will have an interest rate of 1.00%, rather than 0.50%.  \n􀂃  Eligibility Criteria.  \n􀂃 Affiliate Aggregation Requirements.The IFR does not substantively alter previous guidance on the applicability of the SBA’s affiliate aggregation principles, which require a prospective borrower to aggregate its number of employees with those of its affiliates (and their respective affiliates), subject to waivers or different size tests for accommodations and food services businesses (NAICS code beginning with 72), businesses operating as a franchise and businesses receiving financial assistance from a small business investment company licensed by the SBA (additional information is available here). However, the IFR states that the SBA “intends to promptly issue additional  \nguidance with regard to the applicability of affiliation rules at 13 C.F.R. §§ 121.103 and 121.310 to PPP loans,” without providing further insight into what sort of guidance may be forthcoming.  \n􀂃 Application Certifications.The PPP loan application form published by the U.S. Treasury and the SBA earlier this week required applicants and owners of 20% or greater ownership stakes in applicants to make certain certifications regarding the loan and its terms, among other things. While the IFR and revised loan application form have added items that a borrower must certify, the loan application form no longer requires certification by owners of the borrower. The borrower certifies its own eligibility for a PPP loan by making each of these certifications, including to the borrower’s documentation verifying “the number of full-time equivalent employees on the Applicant’s payroll.” Because the onus is on the applicant to verify its eligibility, number of employees and total payroll costs, prospective borrowers and their investors should carefully consider whether affiliate aggregation requirements apply to their circumstances and how that might affect the prospective borrower’s PPP eligibility before making these certifications in the loan application (i.e., prior to applying).  \n􀂃 Citizenship and Residency Requirement.The loan application form published earlier this week also required borrowers and their owners of 20% or greater ownership stakes to respond to three questions, including whether each of them is a U.S. Citizen or Lawful Permanent Resident, and noted that if any such person did not so confirm, the loan would be denied, without providing any guidance on how this question should be a","cbCaibuOJwjX4oFI","https://ap.wps.com/l/cbCaibuOJwjX4oFI","pdf",144019,"English","# Borrower Considerations\n## First-Come, First-Served\n## Interest Rate\n## Eligibility Criteria\n## Affiliate Aggregation Requirements\n## Application Certifications\n## Citizenship and Residency Requirement\n## Measurement Period and Payroll Costs\n## Independent Contractors\n## Federal Employment Taxes\n## Permitted Uses","[{\"question\":\"How are PPP loans processed under the interim final rule?\",\"answer\":\"PPP loans are issued on a first-come, first-served basis. Borrowers are advised to submit applications as soon as possible due to expected high demand.\"},{\"question\":\"What interest rate applies to PPP loans under the update?\",\"answer\":\"All PPP loans have an interest rate of 1.00%, rather than 0.50% as previously suggested by earlier Treasury guidance.\"},{\"question\":\"What changed regarding borrower owner citizenship or residency questions?\",\"answer\":\"The revised application form removed the earlier citizenship or lawful permanent resident confirmation requirement. In its place, it asks borrowers to confirm the U.S. is the principal place of residence for employees included in the average monthly payroll cost calculation.\"}]","CARES Act UPDATE: SBA Issues Interim Final Rule for Paycheck Protection Program - April 3, 2020 | PDF",1789835752]