Sorry to hit you again so soon but this one is actually time sensitive. It appears that the SBA/Treasury dynamic duo is updating its FAQ guidance daily. We would only subject you to this daily drip…drip of information if it has real potential meaning to you. The latest information appears at the end of the document. A summary of the items we feel have real potential impact are:

• #43 – The give back period was now extended from May 7th to May 14th.
• #40 – We believe this is of interest to those of you with a volatile work force such as staffing agencies. If you offer to hire someone back and they refuse, as long as you made a good faith offer they will be excluded when calculating the forgiveness portion.

We are also seeing banks start to issue their guidelines for determining forgiveness. While not in final regulations, (because there are none yet), it appears that the banks are including telephone and internet services in utilities as forgivable expenses.

They are also stating that the payment to sole proprietors up to $15,385 will be forgiven ($100,000 divided by 52 multiplied by 8) during the compliance period.)

As you may recall originally employers were not allowed to have both a PPP Loan and also defer the social security tax until the following two years (50/50). That was changed, but the law is somewhat complicated. Our friend Chris Napoli at ADP provided the following succinct clarification of the requirements:

Example:

• April 19th – I apply for the PPP loan
• May 4th – I hear from my lender/banker that I have been approved for the PPP loan, and should receive the money soon – and do!
• July 15th – I hear from the SBA/gov’t that I have been approved to have the PPP loan forgiven
• All the way up until July 15th, I will be able to defer the ER portion of SS tax. After July 15th, I will be unable to.

Stay safe.  Please contact us with any questions.

LHF