Borrowers and lenders may rely on the guidance provided in this FAQ Document, Updated on April 23, 2020, as SBA’s interpretation of the CARES Act and of the Paycheck Protection Program Interim Final Rule (“PPP Interim Final Rule”). The U.S. government will not challenge lender PPP actions that conform to this guidance,1 and to the PPP Interim Final Rule and any subsequent rulemaking in effect at the time.