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Events escalated and unfolded quickly in the wake of the COVID-19 pandemic. Government relief also came quickly in the form of the Paycheck Protection Program (PPP) loan program—and many business owners immediately rushed to apply.

As things begin to calm down and businesses move toward reopening, small business clients must now turn to the question of loan forgiveness. These clients should be advised to pay close attention to the new small business administration (SBA) form loan forgiveness application, as well as the recent Paycheck Protection Program Flexibility Act (which modifies the CARES Act rules and was released after the SBA application). The need to continue monitoring ongoing guidance is also important—as we have recently learned that elements of emerging guidance may be effective retroactively.

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