PPP Seasonal Employers Interim Final Rule Summary

Updated 04/29/2020

On April 28, 2020, this fifth PPP Interim Final Rule (Rule) was issued, this time by the Treasury rather than the SBA. Section 1109(b) of the CARES Act authorizes the Treasury to establish criteria for lenders to participate in the PPP, and the SBA is required to administer the program the Treasury establishes. Through this Rule, the Treasury is exercising its section 1109 authority to address the needs of potential borrowers that are seasonal employers. Overall, this Rule supplements the first PPP Interim Final Rule to support seasonal employers in obtaining PPP loans to maintain their businesses and employees.

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