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On April 2, 2020, the Department of Treasury and the Small Business Administration (SBA) posted the Interim Final Rule implementing Sections 1102 and 1106 of the CARES Act in advance of its publication in the Federal Register.  On April 3, 2020, SBA also released an overhauled Paycheck Protection Program loan application form.

The new Interim Final Rule and SBA Form 2483 reflect significant developments since the promulgation of the CARES Act and our prior guidance.  Updates based on these developments are included below in red text for ease of reference.

In the midst of a global pandemic and the highest unemployment rates the United States has seen since 1933, President Trump signed into law the $2 trillion Coronavirus Aid, Relief and Economic Security Act (the “CARES Act”), providing economic relief to businesses, States and municipalities, and individuals affected by COVID-19. While the scope of the CARES Act is wide-ranging, this alert is limited to providing a high-level overview of the relief available for qualifying business concerns (generally small businesses with certain limited exceptions).  We will publish additional alerts as the SBA issues implementing regulations over the next 15 days.

Which businesses will be eligible for relief under the CARES Act?

Read the full GT Alert, “Congress Passes CARES Act: Overview of the Relief Available to Small and Other Business Concerns

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Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is a member of the firm’s Global Securities practice group and serves as Co-Chair of the firm’s interdisciplinary Blockchain & Cryptocurrency practice group. She is also co-coordinator of the firm’s interdisciplinary Conflict Minerals Compliance Initiative. Barbara maintains a diverse corporate

Barbara A. Jones is a member of the firm’s Global Securities practice group and serves as Co-Chair of the firm’s interdisciplinary Blockchain & Cryptocurrency practice group. She is also co-coordinator of the firm’s interdisciplinary Conflict Minerals Compliance Initiative. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including blockchain and cryptocurrency transactions, private and public financings (including token offerings), dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. Her practice includes serving as a trusted advisor to public and private company boards of directors on governance and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and companies in blockchain, life sciences and biotechnology, information technology, energy (traditional and renewable), mining, defense and security, telecommunications, media, entertainment and sports. Barbara is also active in the representation of Olympic athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 2003, and headed the international capital markets practice of a major U.S. law firm from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters and strategic alternatives.

Photo of Brett A. Castellat Brett A. Castellat

Brett A. Castellat represents government contractors on a multitude of matters dealing with federal and state-level procurements. Brett handles protests before the Government Accountability Office (GAO), Small Business Administration (SBA), and Court of Federal Claims in bid-related disputes involving primarily firms dealing with

Brett A. Castellat represents government contractors on a multitude of matters dealing with federal and state-level procurements. Brett handles protests before the Government Accountability Office (GAO), Small Business Administration (SBA), and Court of Federal Claims in bid-related disputes involving primarily firms dealing with the Department of Defense, Department of Homeland Security, Department of State, and other federal agencies. Brett also handles matters related to the Contracts Disputes Act and disputes between prime contractors and subcontractors. Brett has also assisted in matters related to issues regarding restrictive covenants, such as non-solicitation clauses, between contractors. Brett has also assisted in representation involving regulatory compliance under various regulatory frameworks, including the International Traffic in Arms Regulations, the General Data Protection Regulations, and various ethics related regulatory frameworks, such as those dealing with organizational conflicts of interest and post-employment restrictions, including at the state-level.

Photo of Peter H. Lieberman Peter H. Lieberman

Peter H. Lieberman is Co-Chair of the Global Corporate Practice. He has more than 30 years of broad experience in mergers and acquisitions, private equity, public company and hedge fund transactions, start-up and venture capital financings, and complex securities trading and structuring matters.

Peter H. Lieberman is Co-Chair of the Global Corporate Practice. He has more than 30 years of broad experience in mergers and acquisitions, private equity, public company and hedge fund transactions, start-up and venture capital financings, and complex securities trading and structuring matters. Throughout his career, Peter has been involved in advising boards of directors, special committees, and controlling interest holders on conflict, governance, change of control, and similar matters. Peter brings to his work a diverse transactional background and trained at the New York law firm of Wachtell, Lipton, Rosen & Katz, where he was involved in both hostile and negotiated transactions (including proxy contests and the implementation of takeover defenses).

Photo of Daniel D. Straus Daniel D. Straus

Daniel D. Straus is an associate in the firm’s Washington, D.C. office. He is a member of the Government Contracts & Projects Group. Prior to joining the firm, he served as an Attorney for the United States Nuclear Regulatory Commission (NRC). At the…

Daniel D. Straus is an associate in the firm’s Washington, D.C. office. He is a member of the Government Contracts & Projects Group. Prior to joining the firm, he served as an Attorney for the United States Nuclear Regulatory Commission (NRC). At the NRC, he represented the Agency in bid protests and advised the Staff on a variety of contracting and procurement issues.

Photo of Jennifer S. Zucker Jennifer S. Zucker

Jennifer S. Zucker is a shareholder in the Washington, D.C. office of Greenberg Traurig. Her practice includes a broad range of litigation, counselling and transactional matters for clients that work with federal, state, and local governments. She represents contractors in bid protests, contract

Jennifer S. Zucker is a shareholder in the Washington, D.C. office of Greenberg Traurig. Her practice includes a broad range of litigation, counselling and transactional matters for clients that work with federal, state, and local governments. She represents contractors in bid protests, contract claims and disputes, mergers and acquisitions, False Claims Act matters, and suspension and debarment proceedings. She also counsels contractors on regulatory requirements under government contracts, ethics and compliance issues, and government investigations and audits.

Jennifer’s experience extends across multiple industries, including defense, aerospace, intelligence, information technology, finance, public assistance and management consulting. She maintains an active security clearance and has deep experience advising clients on national security compliance issues and representing clients in investigations and litigation involving classified programs.

Jennifer serves on the board of directors of SRC Energy, Inc., where she is chair of the Compensation Committee and serves on the Governance and Nominating Committee. She is also a Colonel in the U.S. Army Reserve.