The Small Business Administration (SBA) has consistently applied its traditional small business lending qualification criteria to Paycheck Protection Program (PPP) loans — likely because the CARES Act grafted the PPP onto the SBA’s Section 7(a) loan program. But the CARES Act also contemplated that the purpose of the PPP was different from traditional SBA lending programs; the PPP is part economic stimulus and part inducement for businesses to continue to pay employees, landlords and banks notwithstanding the fear that COVID-19 would bring them economic hardship.

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