On October 2, the SBA released a Procedural Notice regarding PPP Loans regarding transfer guidelines.

For purposes of the PPP, a “change of ownership” will be considered to have occurred when:

(1) at least 20 percent of the common stock or other ownership interest of a PPP borrower (including a publicly-traded entity) is sold or otherwise transferred, whether in one or more transactions, 1 including to an affiliate or an existing owner of the entity

(2) the PPP borrower sell