Update Applications Previous Guidance

Do lenders need to make any changes to their loan applications that were already filed before the updated guidance was released recently?

No, lenders may rely on the previous guidance if the applications have been processed already. You can update the applications if they have not been processed yet.

Linked here and pasted below is the text from the official question and answer document published by the Department of the Treasury on April 10, 2020, which you should reference:

https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

Below is the official question from Q17 as of April 10, 2020

17. Question: I filed or approved a loan application based on the version of the PPP Interim Final Rule published on April 2, 2020. Do I need to take any action based on the updated guidance in these FAQs?

Below is the official answer from Q17 as of April 10, 2020

Answer: No. Borrowers and lenders may rely on the laws, rules, and guidance available at the time of the relevant application. However, borrowers whose previously submitted loan applications have not yet been processed may revise their applications based on clarifications reflected in these FAQs.

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