Latest SBA PPP Guidance

Latest SBA PPP Guidance


Ross Williams

5/14/2020

Dear Treasurers, Finance Chairs and Pastors,

At the bottom of this e-mail is a link to the latest guidance from the Small Business Administration on the Payroll Protection Program.

This guidance, in the form of "Frequently Asked Questions", was updated by the SBA yesterday.

Please note a very important addition to this document regarding the financial necessity of these loans.  It appears in question 46, which I have excerpted below.  This new question and answer clarifies that the SBA will not probe the financial necessity of loans for amounts less than $2.0M.   

Sincerely,

Ross

Question: How will SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?

Answer: When submitting a PPP application, all borrowers must certify in good faith that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” SBA, in consultation with the Department of the Treasury, has determined that the following safe harbor will apply to SBA’s review of PPP loans with respect to this issue: Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.