The information age has been rapidly transforming the way that we consume information. Published articles, social media, network news, and online news sources hit us from various sources. Our cellphones, our computers, our smart watches, all feed us information that we need to sort through, process, and make determinations related to items that impact our businesses. Many of these articles have been focusing in on the Paycheck Protection Program and the forgiveness provisions relating to the same. While the CARES act was signed into law on March 26, 2020, further enhanced by the Paycheck Protection Flexibility Act signed into law on June 5, 2020, and the time in between peppered with FAQs and interim final rules clarifying provisions of the law, the past few weeks have been largely silent to changes in the provisions of the program. The first FAQs related to forgiveness were released on August 4, 2020, but they still leave many unanswered questions. One may interpret this silence to mean that now is the time to file for forgiveness, but based upon this program’s history and uncertain terms, we believe that now is the time to gather your information and document your support, but may not yet be the time to apply for forgiveness on account of the following:
With the release of certain FAQs (FAQ #31 for example regarding necessity), interpretations of the impact of these FAQs on loans and eligibility has been akin to watching a tennis match. While the rules may swing at one time in favor of additional forgiveness on your application, it is quite possible that they could swing to unfavorable and back again to favorable. Only time will tell, but making a decision on filing for forgiveness appears to be a better decision when you are armed with more information.
However, while you wait patiently for guidance that may or may never come, you are running up against the deadline of applying for forgiveness. In order to best arm yourself to make the best decision possible, it is important that you have your forgiveness game plan in place. That is why we are here to coordinate with you an approach that is best for you and your business. Please contact your Citrin Cooperman professional today to find out more.