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This morning the SBA issued an important new FAQ 46 on how it intends to review the good faith necessity certification required for PPP loans. The safe harbor for return of PPP loans expires tomorrow, May 14, and companies should carefully consider the newest guidance as they weigh whether to return loans. View the full FAQs here

For more information and updates on the developing situation, visit GT’s Health Emergency Preparedness Task Force: Coronavirus Disease 2019 or GT’s COVID-19 Economic Stimulus Team.