2020 borrowers can apply for a second PPP loan, albeit one with more restrictive terms. Second-time borrowers are limited to companies with 300 or fewer employees and a maximum loan amount of $2 million, compared with first-time borrowers, who may employ up to 500 people and borrow up to $10 million this year.

Second-time borrowers must also show a 25% decline in receipts from any quarter of 2020 as compared to the same quarter of 2019.

Collections across the legal industry held steadier than many law firm leaders expected, so many potential borrowers will struggle to show such a decline, said legal consultant Lisa Smith of Fairfax Associates. Indeed, the legal industry was projected to come out of 2020 in relatively good shape, with mid-single-digit revenue growth, according to a report from Citi Private Bank Law Firm Group and Hildebrandt Consulting.

"I can't think of any firms we're working with who saw that kind of revenue slide in a quarter," Smith said in an interview. "It's going to be nowhere close to what we saw in the first round."

Six-lawyer, Miami-based regulatory boutique Spiritus Law last year took a $286,200 PPP loan to retain 10 jobs, according to Small Business Administration records.

But managing partner Steven W. Zelkowitz, who joined the firm in early 2021, told Law.com this week that firm leaders hadn't discussed a second loan. "My initial thought is we would leave those to the businesses that require the assistance," Zelkowitz said in an interview. "I did close some Main Street loans for clients that I have. I know that other firms and large firms have taken government money, but from our perspective, we don't need it. And if we don't need it, we're certainly not going to apply."

John Cashman, president of the legal consultancy Major, Lindsey & Africa, said that firms eligible for secondary loans would likely be small in size. "Anyone who does apply will be a midsize or small firm," Cashman said in an interview. "For large firms, I don't think the optics of it are great but I don't think all lawyers care about that."

Negative coverage of the PPP loans last year became a point of contention at some firms, said law firm management consultant Peter Zeughauser.

"I know that within some firms, there was a difference of opinion on these issues. There will be some 'I told you so's,'" he said, adding that an ultimately robust year for Big Law would also tamp down any thoughts of secondary loans. "If there are voices in firms that say 'hey, we were down one quarter [of 2020], we should take the money,' then very likely leadership is going to say, 'not this time, we'll tough it out.'"

Zeughauser said that some firm leaders didn't expect their 2020 loans to be made public, while others didn't expect the backlash following media coverage of Big Law and midsize law firms taking money meant for small businesses.

The revenue stipulation and reduced loan amount and company size rules only apply to second-time borrowers. Law firms that didn't apply in 2020 can apply in 2021 without having to prove lost revenue last year, although Zeughauser said it's unlikely that many will.

"The basic difference is that now, not very many firms feel they need the money," Zeughauser said in an interview. "They would like the money, but they don't need it and I think last year, at the time they took the money, I think many of them thought they needed the money."

Of the $525 billion made available in the initial round of funding, law firms in states like Florida and New York each received a combined $1 billion or more in PPP funds. And for the initial round of loans, law firm equity partners were allowed to take individual loans (separate from their firm's loan) through their professional associations.

"The reality is it was unwelcome publicity," Smith said.