On August 4, 2020, the Small Business Administration (SBA), in consultation with the Department of the Treasury, provided guidance to address borrower and lender questions concerning forgiveness of Paycheck Protection Program (PPP) loans, as provided for under section 1106 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as amended by the Paycheck Protection Program Flexibility Act (Flexibility Act).
While we still have many questions related to the existing forgiveness applications that we believe need further interpretation, we wanted to alert you that additional guidance exists and to remind you of a few key elements related to this program:
You can gather information now and you can calculate your reference period FTEs, preparing yourself for making those decisions on strategic options as you prepare to file for forgiveness.
You should be gathering information and compiling information during your covered period related to the pool of expenses that qualify for forgiveness such that you have the ability to determine the appropriate expenses for use on your application.
You should be watching the guidance that keeps emerging on this program to make the proper determination of when you may wish to file for forgiveness, this may include future legislative changes to the program, additional FAQs, or additional interpretations.