PPP Forgiveness Guidance 5/23/2020

Howdy y’all. It’s Saturday morning on May 23, 2020 and I wanted to send out a quick update. Last night around 9:30 pm CDT on May 22, 2020, the Treasury dropped a couple new Interim Final Rules on their website related to the Paycheck Protection Program. Yes, you read that correctly, it was on the Friday night of Memorial Day Weekend when all normal people were starting a long three day weekend.

OK, so what are the Interim Final Rules?

First things first, the Interim Final Rules will be referred to as IFRs for simplicity. Plus, putting “Interim” and “Final” together in the title for a government document is like fingernails on a chalkboard.

So, without further adue, here are the IFRs Treasury posted last night:

Loan Forgiveness:

The title of the document is “Business Loan Program Temporary Changes; Paycheck Protection Program – Requirements – Loan Forgiveness” and here is the link:

https://home.treasury.gov/system/files/136/PPP-IFR-Loan-Forgiveness.pdf

SBA Loan Review Procedures & Related Responsibilities

The second document relates the the procedures the SBA will use to review the PPP loans and responsibilities of both the borrowers and the lenders. The title is a long one: “Business Loan Program Temporary Changes; Paycheck Protection Program – SBA Loan Review Procedures and Related Borrower and Lender Responsibilities.” Here is the link:

https://home.treasury.gov/system/files/136/PPP-IFR-SBA-Loan-Review-Procedures-and-Related-Borrower-and-Lender-Responsibilities.pdf

Reviews of the documents

I’m going to follow up with more information but since it’s so new and the documents are hard to find, I thought it would be good to go ahead and post these links to help anyone searching for them. The Treasury is definitely not making this easy for accountants or small businesses to comply with the PPP loan program.

To find some preliminary reviews, try checking out some of these Twitter threads: