PPP Loan Forgiveness: What to Do Next?
This free webinar on Understanding and Managing Your PPP Loan and Forgiveness was held May 13, 2020 at 1pm EDT.
View the recording:
Many companies have received funding under the Paycheck Protection Program. If you’re one of those companies, you may find yourself with a check and plenty of questions about how to use it, how to have it forgiven, and what to do next. Businesses receiving funds through this federal loan/grant program are required to follow certain rules for usage of the funds and meet certain tests related to employment and wage levels. This webinar is intended to assist you through overview of PPP loan forgiveness guidelines and tests, understanding the rules of loan forgiveness, explaining 75/25, integrating loan forgiveness into your broader business planning decisions and explaining what we know today, what we think we know, and what changes we might expect.
UPDATE 1: On May 13, the Treasury and the SBA released FAQ #46. FAQ #46 appears to supersede FAQ #43 and eliminate the May 14 deadline. FAQ #46 provides separate guidance for loans under $2m and above $2m
- Any borrower that, together with its affiliates, received PPP loans totaling less than $2,000,000 is deemed to have made the required certification in good faith and need not be concerned about their necessity being challenged.
- Any borrower with loans greater than $2,000,000 will still be subject to SBA review. If the SBA determines that the borrower lacked an adequate basis to make the certification, the borrower will be informed to repay the loan in full and will not be eligible for any forgiveness. However, provided that the borrower makes the repayment at this time, the SBA will not pursue administrative enforcement or referrals to other agencies.
UPDATE 2: On May 14, the Treasury and the SBA released FAQ #47, extending the repayment date to May 18.
UPDATE 3: Also on May 13, following our presentation, the SBA issued an Interim Final Rule related to loan increases. The guidance in the interim final rule permits borrowers to increase their PPP loan if a partnership did not include any amount for partner compensation in their original PPP application.
The interim final rule also permits seasonal employers to increase their PPP loan if they received a PPP loan before the alternative criterion for such employers was posted and would be eligible for a higher maximum loan amount.
If you believe you are eligible for a loan increase as result of this interim final rule, we urge you to contact your accountant and lender as soon as possible.
Presented by: Raymond Brown and Benjamin Bostic
Moderated by: Jay Goldman