Insights

When will this be over? PPP FAQ

April 07, 2020

When will this be over?  I wish I had an answer, but what I can tell you is that I am hearing more and more from very influential people is that this has to stop.  By “this,” they are referring to the economic shutdown.  Right, wrong, or indifferent, when I keep hearing the same thing over and over, I know that we are closer to the end of this than not.

Here are some articles that tell me this is the case or at least show a path out.

Other than that, I do remain optimistic because private business is helping us to get through this situation and will be the engine which drives the recovery.

Here are some other things that are important:

  • Questions 2 & 3 hit on general eligibility.

o   Eligible if under 500 employees, or under “small business concerns” standards by NAICS code which we knew

o   Added eligibility if meeting “small business concern test” (max net worth not > $15mm, average net income for last two years not more than $5mm)

o   Clarified that businesses don’t have to meet all other definitions in Section 3 of SBA.

  • Questions 4 – 6 hit on affiliation rules

o   Lenders aren’t required to certify, clarified these rules must be applied.

  • QUESTION 7 – Clarification of $100k compensation cap

o   The $100k Cap applies to only cash compensation – not non-cash benefits like employer contributions to retirement, healthcare, taxes

  • QUESTION 14  – Clarification of time periods for calculating payroll costs & number of employees  

o   Calendar 2019 or preceding 12 months both acceptable

o   Average employment or per pay average for determination of number of employees

  • Question 15 – Again emphasizes that payments to independent contractors are not in the borrowing base
  • QUESTION 16 – Clarification on impact of fed taxes in relation to payroll costs – fed wages withheld do not reduce the wages for purposes of determining the PPP loan amount.

 

  • Upcoming Webinars
    • Lunchspirations, 4/8/2020; I will be chatting about the various programs from 12-1.  If you would like to register to attend, the link is available here.
    • Huntington Bank, COVID-19 SMAR Talk Weekly Webinar, Wednesday April 8, 2020, 1pm-2pm:  The registration link is here.

Please see all of our updates at the following link:  https://mpl-law.com/resource-center/

As always, please don’t hesitate to email myself, Andy Miller (amiller@mpl-law.com) or Christian Miller (cmiller@mpl-law.com) or anyone in our office with any questions or comments. 

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