Paycheck Protection Program: Updated FAQs

The SBA and Treasury Department released updated frequently asked questions on the Paycheck Protection Program (PPP). Here are a few noteworthy takeaways.

Non-cash benefits. The $100,000 limit to qualifying payroll costs only applies to an employee’s cash compensation. Non-cash benefits, such as employer contributions to D.B. or D.C. plans, payments for group health care coverage, or payments of state and local taxes on employee compensation, do not count towards the limit.

Changes in guidance. Borrowers and lenders will not be penalized for relying on guidance available when they applied, even if guidance may have later changed. Borrowers can revise their applications if they haven’t been processed.

Beneficial ownership verification. Lenders do not need to collect, certify, or re-verify beneficial ownership information for existing customers.

Forgiveness period. The amount of loan forgiveness depends on the borrower’s payroll costs over an 8‑week period, which begins on the day of the first loan disbursement. The first disbursement must be made within 10 days of loan approval.

We encourage you to work with your professional advisers to determine whether the PPP is the right choice for you. Your lender is also a great place to start. For legal advice specific to the operation of your Minnesota business, please contact us at Dunlap & Seeger, P.A.

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