Payroll Protection Program Loan Forgiveness
May 22, 2020:
Congress is considering changes to the PPP Loan Forgiveness requirements. We will update clients as we receive further guidance.
May 18, 2020:
Payroll Protection Program Forgiveness: SBA Releases Application
The Treasury Department and Small Business Administration have released the Loan Forgiveness (Form 3245) with instructions. The form and instructions in the link provides borrowers with measures to reduce compliance burdens and simplify the process.
While we continue to evaluate the information provided by the SBA, we ask that you please review this application, so you are aware of documentation that may be requested. The guidance is fluid and subject to updates as details become available.
May 15, 2020:
Payroll Protection Program Loan Forgiveness: What We Are Hearing
The PPP was passed quickly prior to having all the scenarios considered, and the questions asked, and therefore, the guidelines are ambiguous and continue to evolve. As soon as the SBA releases additional guidance, we will share that information with you.
We know that the process can be overwhelming and wanted to provide some helpful tips on what we are hearing from various sources.
What was the Purpose of the PPP Loan?
The Payroll Protection Program was designed to provide small businesses with resources to:
- Maintain their payroll
- Hire back employees who may have been laid off
- Cover certain overhead expenses like rent and utilities within a range
What is Loan Forgiveness?
Forgiveness is up to the full amount of the PPP loan plus interest accrued up to forgiveness decision, for eligible costs.
What are the Dates that Expenses Must be Paid to be Forgiven?
The Forgiveness Covered Period is an eight-week period beginning the first day you receive your funds.
Some Tips for Maximizing your Loan Forgiveness
1. Understand What Costs are Eligible for Forgiveness
Guidance indicates that only certain costs are eligible for forgiveness, mainly payroll, which will require 75% of your funds. Only 25% may go to non-payroll costs - mortgage interest, utilities, rent, certain other interest, and the related agreements must have been established as of February 15, 2020.1 Ineligible expenses will not be forgiven, and misuse of these funds could result in fines or other consequences, so it is important to ensure you understand how to use these funds.
2. Maintain Detailed Payroll Records
The amount of your loan that may be forgiven is based upon the costs you have incurred and payments you have made during the eight-week period. Maintain detailed payroll records for all employees. The same payroll costs that were used to calculate your loan amount will be used for requesting forgiveness.2
3. Keep Employees Paid and Employed
Employ as many full-time employees (average per month) during the eight-week period as was employed during an elected prior period. Pay each employee during the eight-week period at least 75% of the average annual wages paid to each employee during the most recent full quarter prior to eight-week period.3
4. Track and Retain All Documentation of Expenses
Keep records of all your expense receipts and transactions in a loan forgiveness folder to ensure you have the proper documentation when you are applying for loan forgiveness at the end of the eight-week period.
5. Stay in Touch
We are here to help you. Keep in touch with your banker as you progress through this unprecedented situation so we can continue to guide and advise you.
1 Source: Frazier and Deeter
2 Source: CFO Solutions
3 Source: Rivero, Gordimer and Co. CPA and Advisors