Interim Final Rule – Consolidating Prior Rules and Changes from the Economic Aid Act

Schneider Downs continues to track the evolving landscape of federal financial programs offered in the wake of the business disruption caused by the coronavirus crisis. On December 21, the Consolidated Appropriations Act of 2021 (the Act), which included the Economic Aid to Hard-Hit Businesses, Nonprofits and Venues Act (the Economic Aid Act), was passed by both houses of Congress. As a follow up, on January 19 the Small Business Administration (SBA) issued an Interim Final Rule (IFR) that implements and consolidates changes related to the forgiveness and review of loans under the Paycheck Protection Program (PPP) and incorporates changes made by the Economic Aid Act.

The IFR provides borrowers and lenders guidance on requirements governing forgiveness of PPP loans and informs borrowers of SBA’s process for reviewing loan applications and loan forgiveness applications. It incorporates and restates prior IFRs relating to loan forgiveness and loan reviews, and is divided in the following sections:

  • Amounts eligible for forgiveness
  • Loan forgiveness process
  • Payroll costs eligible for loan forgiveness
  • Nonpayroll costs eligible for loan forgiveness
  • Reductions to loan forgiveness amount
  • Documentation requirements
  • PPP SBA loan review procedures and related borrower and lender responsibilities

For a summary of these updates to PPP loan eligibility, loan forgiveness, eligible costs and limitations on forgiveness, please see our OTO article at:

The actual IFR is located at

If you need more information or assistance regarding your PPP loan, visit our website at, reach out to any of your contacts at Schneider Downs, or contact Joel Rosenthal at [email protected].

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The Schneider Downs Our Thoughts On blog exists to create a dialogue on issues that are important to organizations and individuals. While we enjoy sharing our ideas and insights, we’re especially interested in what you may have to say. If you have a question or a comment about this article – or any article from the Our Thoughts On blog – we hope you’ll share it with us. After all, a dialogue is an exchange of ideas, and we’d like to hear from you. Email us at [email protected].

Material discussed is meant for informational purposes only, and it is not to be construed as investment, tax, or legal advice. Please note that individual situations can vary. Therefore, this information should be relied upon when coordinated with individual professional advice.

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