• Forgiveness reductions when an employer offers to rehire employees who decline employment

• The intersection of the interim final rule issued on April 27, 2020 related to seasonal employers choosing to utilize the alternative seasonal dates for calculation of a PPP loan and the application for a loan.

• The applicability of nonprofit hospitals as “nonprofit organizations” under section 1102 of the CARES Act.

https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

Established as a provision under the CARES Act (the “Act”) and signed into law on March 27, 2020, the Paycheck Protection Program (PPP) loans were created as a measure to place Federal stimulus funds in the hands of the employees of small businesses. Calculated based upon average payroll as defined in the Act times 2.5, these PPP loans, if used for covered purposes and without reduction in workforce, may be forgivable to businesses.

While the guidance continues to evolve through both the issuance of Final Interim Rules and FAQs, Citrin Cooperman is providing the information on this webpage to assist you in determining the potential impact on your business from participating in the PPP.

Citrin Cooperman will continue to update this webpage with clarifications set forth by the SBA and Treasury as this additional guidance is issued. This webpage contains an “updated through date” which will correlate with the most recent updates provided by the regulators and available to you.

While this webpage is intended to help you gain additional insights into the PPP, it is not intended to be all encompassing and does not constitute legal advice. Please contact your Citrin Cooperman partner or any PPP specialist to assist you with guidance as it relates to your specific facts and circumstances. Specific questions regarding your PPP application or loan should be referred to your attorney.

Citrin Cooperman will continue to provide the most up-to-date information on the PPP, new guidance and our interruptive analysis of the potential impacts on the business community.

Updates

April 30, 2020—AICPA releases video and FAQs on Paycheck Protection Program

https://www.aicpa.org/interestareas/privatecompaniespracticesection/qualityservicesdelivery/sba-paycheck-protection-program-resources-for-cpas/sba-payroll-protection-program-faqs.html

April 29, 2020—SBA Updates FAQ through FAQ #39

https://www.sba.gov/sites/default/files/2020-04/Paycheck-Protection-Program-Frequently-Asked-Questions_04%2029%2020_2.pdf

Citrin Cooperman & Company, LLP (“Citrin Cooperman”) provides this Business Stimulus Loans website as a service to the public. Citrin Cooperman is not responsible for, and expressly disclaims all liability for, damages of any kind arising out of use, reference to, or reliance on any information contained within this website. Guidance related to the CARES Act’s Paycheck Protection Program (PPP) loan, the SBA’s Economic Injury Disaster Loan (EIDL) and the related CARES Act EIDL Advance, and the Main Street Loan Programs, is constantly evolving. While the information contained within this website is periodically updated, no guarantee is given that the information provided in this website is correct, complete, and up-to-date.

By using the information or calculations included on this website you acknowledge that you are responsible for all management decisions and responsibilities. You are responsible for evaluating the adequacy and results of any calculations and accepting responsibility for such calculations or use of information resulting in any significant judgments and decisions that are the proper responsibility of management.

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