SBA Issues Interim Final Rules on PPP Loan Forgiveness Requirements, Loan Review Procedures | #employeefraud | #recruitment | #corporatesecurity | #businesssecurity | #

On May 22, 2020, the U.S. Small Business Administration (“SBA”) released two Interim Final Rules (“IFRs”) providing additional guidance on Payment Protection Program (“PPP”) loan forgiveness rules and the procedure by which PPP Loan Forgiveness Applications (“Loan Forgiveness Applications”) will be processed (click here for our alert on the topic). The first IFR (RIN 3245-AH46) primarily addresses loan forgiveness requirements, while the second IFR (RIN 3245-AH47) addresses loan review procedures. This alert summarizes the IFRs and thereby the collective SBA guidance to date on these matters. We expect additional SBA guidance to come in the days ahead.

The CARES Act provides that a borrower is eligible for forgiveness of its PPP loan in an amount equal to the sum of qualified costs incurred and payments made during the eight-consecutive-week period beginning with a borrower’s receipt of PPP loan proceeds (“Covered Period”). For more context, our prior alerts describing the PPP in more detail are here, here, here, and here.

The loan forgiveness rules principally address (a) how to deal with the time gap between when qualified costs were incurred and when those costs were paid; (b) how costs otherwise qualified for loan forgiveness are to be reduced due to a reduction in the number of employees or salary or wage rates (“Haircut”); and (c) situations in which there has been a Haircut-triggering reduction in size of the workforce or the salary or wage rates but there is no Haircut (“Safe Harbor”), so that a borrower is forgiven the entire amount of the qualified costs paid during the Covered Period.

I. Costs Eligible for Forgiveness

A. Payroll Costs

Costs eligible for forgiveness are composed of payroll costs and non-payroll costs. “Payroll Costs” consist of the following compensation to employees whose principal place of residence is the United States, in the form of (1) salary, wages, commissions, or similar compensation (up to an annualized $100,000); (2) cash tips or equivalent (based on employer records of past tips or, in the absence of such records, a reasonable good-faith employer estimate of such tips); (3) payment for vacation, parental, family, medical, or sick leave (excluding payments for emergency paid sick leave or expanded family and medical leave); (4) allowance for separation or dismissal; (5) payment for the provision of employee benefits consisting of group health care coverage, including insurance premiums and retirement; (6) payment of state and local taxes assessed on compensation of employees (but not federal payroll tax). Cash compensation costs (but not other Payroll Costs) are capped at $15,385 per individual (8/52 weeks of $100,000).

Payroll Costs are considered incurred on the day that the employee’s pay is earned—that is, the day on which the employee worked. Payroll Costs are paid on the day on which checks are distributed or an electronic funds transfer is originated. Payroll Costs paid or incurred during the Covered Period are eligible for forgiveness. Payroll Costs paid during the Covered Period are eligible for forgiveness even if they relate to Payroll Costs incurred prior to the start of the Covered Period. Furthermore, Payroll Costs incurred during the Covered Period but paid after the end of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. Generally speaking, most often Payroll Costs are paid on the last day of a payroll period, or particularly where a payroll period is of a short duration, after the end of the payroll period—that is, “in arrears.”

In recognition of the practice of paying Payroll Costs in arrears, the IFRs allow a borrower with a biweekly (every other week) or more-frequent payroll cycle to delay the start of the Covered Period to the first day of the first pay period following the disbursement of the PPP loan (“Alternative Payroll Covered Period” and such Alternative Payroll Covered Period or Covered Period, as applicable, hereinafter the “Payroll Covered Period”). The Payroll Covered Period will apply to any matter involving Payroll Costs and Haircuts, but only the Covered Period will apply to Non-Payroll Costs (defined below).

As with the Covered Period, Payroll Costs paid during the Alternative Payroll Covered Period or incurred during the Alternative Payroll Covered Period and paid no later than the first regular payroll payment date occurring after the end of the Alternative Payroll Covered Period are eligible for forgiveness. Payroll Costs that were both paid and incurred during the Covered Period (or Alternative Payroll Covered Period) may be counted only once.

Given the CARES Act formulation of “costs incurred and payments made,” which we had understood to require both actions to have occurred during the relevant covered period and which we believed was echoed in the Application released a week before the IFRs, the SBA guidance is the more accommodating “costs incurred or payments made,” so a borrower may be tempted to “pre-pay” Payroll Costs before the end of the applicable Payroll Covered Period to maximize the forgiveness amount. Without further SBA guidance on this point, a borrower should tread carefully in this regard. However, we encourage any borrower with a biweekly or more-frequent payroll cycle to consider adopting the Alternative Payroll Covered Period to leverage the practice of paying payroll in arrears to maximize loan forgiveness. This can be illustrated by the following example.


A borrower has a biweekly payroll schedule (every other week). The borrower’s eight-week Covered Period would normally begin on June 1 (the date on which the borrower received the loan proceeds) and end on July 26. The first day of the borrower’s first payroll cycle that starts in the Covered Period is June 7. Instead of the Covered Period, the borrower may elect an Alternative Payroll Covered Period for Payroll Costs which starts on June 7 and ends 55 days later (for a total of 56 days) on August 1. Assume that payroll is paid after the end of each payroll period every other Thursday. Thus, the June 11 payroll will cover the two weeks that run from May 24 through June 6. Assume that a borrower has $1,000 of payroll costs per week, and $2,000 per pay period, then the regular covered period and the alternate periods looks like this:

Payments to Furloughed Workers, Bonuses, and Commissions

Payroll Costs are broadly defined in the CARES Act to include compensation in the form of salary, wages, commissions, or similar compensation. If a borrower pays furloughed employees their salary, wages, or commissions during the Payroll Covered Period, those payments are eligible for forgiveness as long as they do not exceed an annual salary of $100,000, as prorated for the Payroll Covered Period. Similarly, bonuses or hazard pay are properly included in Payroll Costs, as this type of pay is considered supplemental to an employee’s salary or wages.

Limits on Payments to Owner-Employees and Self-Employed Individuals

The amount of loan forgiveness requested in respect of owner-employees and self-employed individuals’ Payroll Costs can be no more than the lesser of (a) 8/52 of 2019 compensation or (b) $15,385 ($100,000 cap multiplied by eight-week covered period divided by 52 weeks in a year) per individual “across all businesses.” While it makes sense to limit owners to the 2019 amounts to prevent them from creating mischief by increasing payments to themselves during the applicable Payroll Covered Period and thereby maximizing forgiveness, we believe applying the $100,000 annualized cap to all forms of Payroll Costs in respect of owners is misguided.

The IFRs, in determining that the $100,000 cap applies with respect to all Payroll Costs for any business owner rather than only to cash compensation, rely on the CARES Act language concerning “sole proprietors or independent contractors.” A “sole proprietor” generally refers to a business conducted in the name of an individual rather than an entity or where the entity owned by an individual is disregarded. Since absent unusual circumstances the law will respect a business entity and not “look through” a business entity to its sole owner, it seems like a stretch to expand the scope of the $100,000 annualized cap to single-owner entities and to entities which have more than one owner. An independent contractor provides services for another business but is not an employee of the business for which it provides services. As the SBA has taken the position that a borrower may not consider payments made to an independent contractor Payroll Costs because the independent contractor can receive its own PPP loan, it also seems a stretch to apply the $100,000 annualized cap so broadly. It is hard to believe that Congress intended to so discriminate against business owners, or to understand what policy is served by denying their businesses the benefit of health care and retirement payments made in respect of the owners. Perhaps the SBA will provide further clarity on this issue or Congress will correct this by further legislation.

B. Non-Payroll Costs

Non-Payroll Costs consist of the following: (1) interest payments on any business mortgage obligation on real or personal property; (2) payments on business rent obligations on real or personal property under a lease agreement; and (3) business utility payments for electricity, gas, water, transportation, telephone, or internet services. In all cases, the obligations and agreements must have been incurred and in force before February 15, 2020.

As with Payroll Costs, Non-Payroll Costs are paid on the day on which checks are mailed or an electronic funds transfer is originated. However, unlike Payroll Costs, which are most often paid “in arrears” (after the work was performed), Non-Payroll Costs are most often paid “in advance” (before the beginning of the period in which the service is provided). For example, rent in respect of a month is usually due on the first day of that month. As with Payroll Costs, Non-Payroll Costs are eligible for forgiveness if they were paid during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if that date is after the Covered Period. Since most Non-Payroll Costs are payable in advance and many borrowers may not have paid their bills while they were closed, such borrowers may be able to obtain forgiveness for certain Non-Payroll Costs covering periods before and after the Covered Period. However, in all such cases the forgiveness amount in respect of Non-Payroll Costs are capped at 25%.


The borrower had closed its business on March 12 due to the pandemic and had not paid its rent, payable in advance on the first of each month, for the months of March, April, May, and June. The Covered Period begins on June 3 and ends on July 28. On June 10, the borrower reopened its business and paid the delinquent rent for March, April, May, and June. The borrower pays July rent on June 27 and pays the August rent bill on July 28, the last day of the Covered Period. The full six months’ rent (March-August) is eligible for forgiveness if the amount of Non-Payroll Costs does not exceed 25% of the total loan forgiveness amount

Advance Payments of Mortgage Interest

Advance payments of interest on a covered mortgage obligation are not eligible for loan forgiveness because the CARES Act’s loan forgiveness provisions regarding mortgage obligations specifically exclude “prepayments.” Principal on mortgage obligations is not eligible for forgiveness under any circumstances. The limitation on prepaying mortgage interest, which should not capture making a payment a few days before the beginning of a month, is the only limitation on accelerating Non-Payroll Costs. The SBA acknowledges this in the IFRs by noting that “the 25% cap on Non-Payroll Costs will avoid excessive inclusion of Non-Payroll Costs.” Accordingly, a borrower should carefully track its eligible expenses during the applicable periods to ensure that it does not leave any forgiveness “on the table” by having Non-Payroll Costs compose less than 25% of the total loan forgiveness amount.

II. Haircuts and Safe Harbors

The CARES Act also ties loan forgiveness to the extent to which a borrower maintained or restored to pre-pandemic levels the size of its workforce and salary or hourly wage rates of its individual employees.

A. Workforce Size Reduction

A borrower must calculate the average number of “full-time equivalent” employees in the Payroll Covered Period using one of two possible reference periods, as selected by the borrower, and compare the two. Until the release of the Application and the IFRs, however, there has been no specific guidance on the definition of full-time equivalent (“FTE”).

Full-Time Equivalent Employees

Borrowers should select the reference period that yields the lowest FTE.Borrowers seeking forgiveness must document their average weekly number of FTE employees during the applicable Payroll Covered Period and their selected reference period (“FTE Reference Period”), which may be:

  • February 15, 2019, through June 30, 2019;
  • January 1, 2020, through February 29, 2020; or
  • In the case of a seasonal employer, either of the two preceding methods or a consecutive 12-week period between May 1, 2019, and September 15, 2019.

Borrowers should select the reference period that yields the lowest FTE.

When performing an FTE reduction calculation, the borrower divides the average number of hours paid for each employee per week by 40, rounding to the nearest tenth and capping this quotient at 1.0 FTE. For example, an employee who was paid 48 hours per week during the Payroll Covered Period would be considered to be an FTE employee of 1.0. For employees who work less than 40 hours per week, the borrower may calculate the average number of hours paid per week divided by 40 and rounded to the nearest tenth (“Traditional Method”). Alternatively, the borrower assigns 1.0 FTE for each employee who works 40 hours or more per week and 0.5 FTE for each employee who works fewer than 40 hours (“Simple Method”). The chosen method must be applied consistently to all employees in all relevant periods. The FTE for the FTE Reference Period is compared with the FTE for the Payroll Covered Period. If the FTE for the Payroll Covered Period is less than the FTE for the FTE Reference Period, loan forgiveness is reduced proportionately by the percentage reduction in FTE.


If a borrower had 10.0 FTE employees for the FTE Reference Period and this declined to 8.0 FTE employees for the Payroll Covered Period, the percentage of FTE employees declined by 20% and thus only 80% of otherwise eligible expenses are available for forgiveness.

Borrowers may wish to factor these methods into their calculus of the number of employees to bring back and the number of hours they work. In any event, borrowers should calculate the FTE ratio using both the Traditional Method and the Simple Method to determine whether one method yields greater forgiveness than the other.

The language concerning the FTE comparison between the FTE Reference Period and the Payroll Covered Period refers to amounts “paid” and does not address the time gap between when Payroll Costs are incurred and subsequently paid. Absent further SBA guidance to the contrary, it would appear that a borrower would have a principled position for using either the time of incurrence or the time of payment of Payroll Costs if it was used for both relevant periods. In any event, a borrower should benefit from (that is, not be penalized for) any increase in the FTE for the Payroll Covered Period resulting from including Payroll Costs incurred but not paid until the next regular payroll date after the end of the Payroll Covered Period. Another ambiguity that would benefit from additional SBA guidance is how to treat “partial weeks” during the relevant periods.

Safe Harbors

1. Restore FTE Reduction Prior to June 30, 2020

In the event that (a) there is (i) an FTE reduction during the period from February 15, 2020, to April 26, 2020 (30 days after the enactment of the CARES Act) (such period, the “Permitted Reduction Period”), from (ii) the FTE on February 15, 2020; and (b) such FTE reduction is eliminated by June 30, 2020 (“FTE Restored Reduction”), then (c) the FTE Restored Reduction will be ignored.

2. Offers to Rehire Employees

Any reduction in the FTE resulting from layoffs or reduced hours will be waived, even if the reduction occurred outside the Permitted Reduction Period, if:

  • The borrower made a good-faith, written offer to rehire such employee (or, if applicable, restore the reduced hours of such employee) during the Payroll Covered Period;
  • The offer was for the same salary or wages as earned, and same number of hours as worked, by such employee in the last pay period prior to the separation or reduction in hours;
  • The offer was rejected by such employee;
  • The borrower maintained records documenting the offer and its rejection; and
  • The borrower informed the applicable state unemployment insurance office of such employee’s rejected offer of reemployment within 30 days of the employee’s rejection of the offer.

The IFRs state that “borrowers should not be penalized for changes in employee headcount that are the result of employee actions and requests” and accordingly, borrowers will not be penalized and their loan forgiveness will not be reduced for employees who are “fired for cause, voluntarily resign, or voluntarily request a schedule reduction.”

3.Voluntary Reductions or Firing for Cause

The forgiveness amount will not be reduced if an employee voluntarily resigns or requests a reduction of hours, or is fired for cause. In any such instance, the borrower may count the employee at the same full-time equivalency level before the FTE reduction event.

B. Salary/Wage Reductions

For each new employee hired in 2020 and each existing employee who was not paid more than the annualized equivalent of $100,000 in any pay period in 2019, the borrower must reduce the total forgiveness amount by the total dollar amount of the salary or wage reductions during the Payroll Covered Period that is in excess of 25% of base salary or wages between January 1, 2020, and March 31, 2020 (the “Salary Reference Period”). This reduction calculation is performed on a per-employee basis, not in the aggregate.


A borrower reduced a full-time employee’s weekly salary from $1,000 per week during the Salary Reference Period to $700 per week during the Payroll Covered Period. The employee continued to work on a full-time basis during the Payroll Covered Period with an FTE of 1.0. In this case, the first $250 (25% of $1,000) is exempted from the reduction. The borrower in seeking forgiveness would list $400 as the salary/hourly wage reduction for that employee (the extra $50 weekly reduction multiplied by eight weeks).

To ensure that borrowers are not doubly penalized, the salary/wage reduction applies only to the portion of the decline in employee salary and wages that is not attributable to the FTE reduction. To illustrate this point, one of the IFRs provided an example of a salary/wage reduction calculation that does not take into consideration the hours worked in addition to the hourly rate because this would create a double reduction because the reduction in hours would also reduce the average number of FTE employees.


An hourly wage employee had been working 40 hours per week during the borrower’s selected reference period (FTE employee of 1.0), and the borrower reduced the employee’s hours to 20 hours per week during the Payroll Covered Period (FTE employee of 0.5). There was no change to the employee’s hourly wage during the Payroll Covered Period. Because the hourly wage did not change, the reduction in the employee’s total wages is entirely attributable to the FTE employee reduction and the borrower is not required to conduct a salary/wage reduction calculation for that employee.

Same facts except that employee’s hourly rate was reduced from $20 per hour to $12 per hour. The forgiveness reduction is $60 per week (20 hours multiplied by $3 (hourly rate reduction in excess of 25%) or $240 over the eight-week period).

Safe Harbor: Restore Salary or Wage Reduction Prior to June 30, 2020

In the event that (a) there is (i) a salary or wage rate reduction in respect of an employee during the Permitted Reduction Period (February 15, 2020, to April 26, 2020) from (ii) the salary or wage rate on February 15, 2020; and (b) such salary or wage rate reduction is eliminated by June 30, 2020 (“Salary or Wage Rate Restored Reduction”), then (c) the Salary or Wage Rate Restored Reduction will be ignored.

III. Loan Review Procedures and Related Borrower and Lender Responsibilities

A. Forgiveness Application

A borrower may apply for loan forgiveness at any time after the Covered Period by completing and submitting to its lender (or the lender servicing its loan) a Loan Forgiveness Application (SBA Form 3508 or lender equivalent).

B. Borrower Obligations

Required Certifications

In the Loan Forgiveness Application, a borrower must certify the following:

  • Non-Payroll Costs do not exceed 25% of the amount requested.
  • Payroll and Non-Payroll Costs for which the borrower seeks loan forgiveness are verified.
  • Borrower understands the government may pursue civil and criminal remedies for knowing misuse of borrowed funds and for false statements and bank fraud. Penalties for false statements on the Loan Forgiveness Application include “[i]mprisonment of not more than five years and/or a fine of up to $250,000, two years and/or a fine of not more than $5,000; and, if submitted to a federally insured institution, by imprisonment of not more than thirty years and/or a fine of not more than $1,000,000.”
  • Borrower has submitted the required documents for loan forgiveness (see below).
  • Borrower has submitted or will submit tax documents to the IRS consistent with those submitted to the SBA.
  • Borrower acknowledges that the SBA can request additional information to evaluate loan forgiveness.

Required Documentation

A Loan Forgiveness Application is composed of a Loan Forgiveness Calculation Form, a PPP Schedule A, a PPP worksheet to Schedule A, and a Demographic Information Form. A borrower must submit with its Loan Forgiveness Application the following:

  • Loan Forgiveness Calculation Form.
  • Loan Forgiveness PPP Schedule A.
  • Documents showing cash compensation and noncash compensation benefit payments comprising Payroll Costs for the Payroll Covered Period, such as third-party payroll service reports, payroll registers, bank or insurance account statements, canceled checks, payment receipts, and tax forms.
  • Documents verifying the FTE for the FTE Reference Period, such as payroll tax filings (IRS Form 941), state quarterly business and individual employee wage reporting, unemployment insurance tax filings, third-party payroll service reports, and payroll registers.
  • Documents detailing Non-Payroll Cost arrangements in place prior to February 15, 2020, and all amounts eligible for forgiveness that were paid or incurred during the Covered Period, such as agreements, canceled checks, amortization schedules, and account statements.

Documents Required to be Maintained

A borrower is not required to submit but must maintain the following:

  • Documentation supporting the listing of each individual employee in PPP Schedule A Worksheet Table 1 (for the Payroll Covered Period), including the “Salary/Hourly Wage Reduction” calculation, if necessary.
  • Documentation supporting the listing of each individual employee in PPP Schedule A Worksheet Table 2; specifically, that each listed employee during the Payroll Covered Period who received during any single pay period in 2019 compensation at an annualized rate of more than $100,000.
  • Documentation regarding any employee job offers and refusals, firings for cause, voluntary resignations, and written requests by any employee for reductions in work schedule.
  • Documentation supporting the PPP Schedule A Worksheet “FTE Reduction Safe Harbor.”

All records relating to the loan, including documentation submitted with its PPP loan application, documentation supporting the borrower’s certifications as to the necessity of the loan request and its eligibility for a PPP loan, documentation necessary to support the Loan Forgiveness Application, and documentation demonstrating the Borrower’s material compliance with PPP requirements. The Borrower must retain all such documentation in its files for six years after the date the loan is forgiven or repaid in full, and permit authorized representatives of the SBA, including representatives of its Office of Inspector General, to access such files upon request.

C. Lender Obligations

In processing a borrower’s Loan Forgiveness Application, a lender is obligated to confirm the following:

  • Receipt of borrower certifications in the Loan Forgiveness Application.
  • Receipt of documents verifying Payroll Costs and Non-Payroll Costs required to be submitted with the Loan Forgiveness Application.
  • Review of documents submitted with the Loan Forgiveness Application.
  • Borrower’s calculations on the Loan Forgiveness Application are accurate (including with respect to cash compensation, noncash compensation, and compensation to owners, as well as Non-Payroll Costs). Lenders are expected to perform a good-faith review, in a reasonable time, of the borrower’s calculations and supporting documents concerning amounts eligible for loan forgiveness. The lender is not required to independently verify the borrower’s reported information, since the borrower attests to the fact that it has provided the appropriate documentation supporting its request.
  • Non-Payroll Costs did not exceed 25% of the loan forgiveness amount requested.

A lender must issue a decision within 60 days of the receipt of a completed Loan Forgiveness Application to the SBA either approving the forgiveness amount (in whole or in part), denying the forgiveness amount (in which case it must notify the borrower as well), or if directed by the SBA, denying the forgiveness amount without prejudice due to a pending SBA review. A borrower whose application has been denied may request SBA review of the lender’s decision within 30 days of receiving notice from the lender. Although the CARES Act requires a lender to render a decision within 60 days of the submission of an application, it is silent as to whether such notice is required to be given to the borrower. The timing of when a lender is required to notify the borrower in cases other than a denial of the entire forgiveness amount requested, remains unknown and requires further SBA guidance.

The following applies for Loan Forgiveness Applications that are not reviewed by the SBA prior to a lender’s decision regarding forgiveness:

  • If the lender determines that the borrower is entitled to forgiveness of some or all of the borrowed amount, it must notify the SBA of its decision and include in such notice (1) the PPP Loan Forgiveness Calculation Form; (2) PPP Schedule A; and (3) the optional PPP Borrower Demographic Information Form (if submitted to the lender). In such notice to the SBA, the lender must confirm that the information provided by the lender to the SBA accurately reflects the lender’s records for the loan, and that the lender has made its decision in accordance with the applicable requirements.
  • The lender must request payment from the SBA at the time the lender issues its decision to the SBA.
  • The SBA will remit the appropriate forgiveness amount, plus any accrued interest, to the lender within 90 days thereafter.
  • If applicable, the SBA will deduct from the forgiveness amount remitted to the lender any Economic Injury Disaster Loan (“EIDL”) advance amounts, which are capped at $10,000 in total, if such EIDL advance amounts were “refinanced” in connection with the PPP loan as required by Section 1110(e)(6) of the CARES Act.
  • If the SBA determines that a borrower was ineligible for the PPP loan based on the guidance available at the time of the borrower’s application, the borrower’s loan will no longer be eligible for loan forgiveness. If the forgiveness request is denied, or if only part of the loan is deemed forgivable, the borrower must repay any remaining balance due on the loan within the loan’s two-year maturity window.

D. SBA Review of Loans

The SBA may review at its discretion any PPP loan of any size at any time, which review may involve whether a borrower (a) was eligible for a PPP loan; (b) calculated the loan amount correctly; and (c) used loan proceeds for allowable purposes. In addition, the SBA can review a borrower’s eligibility for loan forgiveness. The SBA can require lenders to obtain additional information from the borrower, or request information directly from the borrower, and will consider all additional information from the borrower in completing its review. Failure to respond to SBA’s inquiries can result in a determination that the borrower was ineligible for a PPP loan or a loan forgiveness amount.

The lender is required to do the following within five business days of notice that SBA is reviewing a loan:

  • Submit the PPP loan application, all supporting documentation, the loan forgiveness application, and all supporting documentation to the SBA.
  • Request the borrower submit the Schedule A Worksheet (and the lender must submit the worksheet to the SBA within five days of receipt of the request).
  • Submit a signed and certified transcript of account, a copy of the PPP note, and any other related documents requested by the SBA.

If the SBA in its review determines that a borrower is not eligible for a PPP loan, it will instruct the lender to deny the borrower’s Loan Forgiveness Application. The SBA may also determine that a borrower is not eligible for loan forgiveness; in that case, it will instruct the lender to deny the loan forgiveness application in whole or in part, depending on the SBA’s determination. If the SBA determines that the borrower was not eligible to receive the loan, the lender will have to return its processing fees within one year after the loan was disbursed. However, this will not invalidate the SBA guarantee as long as the lender complied with its obligations.

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