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On April 2, 2020, the U.S. Small Business Administration (SBA) posted on its website an interim final rule relating to the implementation of sections 1102 and 1106 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act or the Act) (published in the Federal Register on April 15, 2020).  Section 1102 of the Act temporarily adds a new product, titled the "Paycheck Protection Program,” to the SBA’s 7(a) Loan Program.  Subsequently, SBA and Treasury issued additional interim final rules implementing the Paycheck Protection Program.  On June 5, 2020, the Paycheck Protection Program Flexibility Act of 2020 (Flexibility Act) was signed into law, amending the CARES Act.  This interim final rule revised interim final rules posted on SBA’s and the Department of the Treasury’s websites on May 22, 2020 (published in the Federal Register on June 1, 2020), by changing key provisions to conform to the Flexibility Act.  Several of these amendments are retroactive to the date of enactment of the CARES Act, as required by section 3(d) of the Flexibility Act.