PPP Forgiveness Guidance

Bryan Cave Leighton Paisner
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We are still working on a few specific pieces of guidance for lenders as they process PPP forgiveness applications,  particularly with regard to minimizing the bank’s liability and with regard to EIDL advances. But in the meantime, I thought I would share some of the thought leadership that we’ve published from a PPP borrower perspective, since I suspect banks will also get a lot of questions from their borrowers as well.

In our view, the Paycheck Protection Program Loan Forgiveness Application answered many questions, but certainly not all of them.

The additional Loan Forgiveness And Loan Review regulations answered additional questions (but of course left more questions as well).

Another potential resource is the AICPA Loan Forgiveness Calculator available here. Given the continuing flow of ongoing guidance, the Calculator is updated regulatory. (Note: we have not verified any of the assumptions/calculations made by the AICPA calculator, but believe it can be a useful comparison tool regardless.)

We collectively have had a good laugh at the following language in the latest Interim Final Rule…

By providing a high degree of certainty to PPP borrowers through this interim final rule, PPP borrowers will be able to take immediate steps to maximize their loan forgiveness amounts…

SBA Interim Final Rule on Loan Forgiveness

I don’t know if it’s just that we have a different view of what constitutes a “high degree” of certainty, or a different view of what might constitute “immediate steps” in a program that launched almost 2 months ago, but it does appear to show a disconnect between the regulators and the on-the-ground lenders and borrowers.

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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