Tag Archives: treasury

PPP2 Guidance & Forms Are Here – Program to Open Week of January 11

Three weeks ago today I said it was coming — and it’s here!

Today, SBA and Treasury announced the reopening of the PPP program:

Initially only community financial institutions will be able to make First Draw PPP Loans on Monday, January 11, and Second Draw PPP Loans on Wednesday, January 13.  The PPP will open to all participating lenders shortly thereafter.

Updated PPP guidance outlining Program changes to enhance its effectiveness and accessibility was released on January 6 in accordance with the Economic Aid to Hard-Hit Small Businesses, Non-Profits, and Venues Act.

Key PPP updates include (underlines are mine):

  • PPP borrowers can set their PPP loan’s covered period to be any length between 8 and 24 weeks to best meet their business needs;
  • PPP loans will cover additional expenses, including operations expenditures, property damage costs, supplier costs, and worker protection expenditures;
  • The Program’s eligibility is expanded to include 501(c)(6)s, housing cooperatives, destination marketing organizations, among other types of organizations;
  • The PPP provides greater flexibility for seasonal employees;
  • Certain existing PPP borrowers can request to modify their First Draw PPP Loan amount; and
  • Certain existing PPP borrowers are now eligible to apply for a Second Draw PPP Loan. 

A borrower is generally eligible for a Second Draw PPP Loan if the borrower:

  • Previously received a First Draw PPP Loan and will or has used the full amount only for authorized uses;
  • Has no more than 300 employees; and
  • Can demonstrate at least a 25% reduction in gross receipts between comparable quarters in 2019 and 2020. (Updated since to provide an option for annual comparison for those without quarterly records.)

The guidance included two interim final rules (IFRs).

  • The 82-page IFR “Business Loan Program Temporary Changes; Paycheck Protection Program as Amended” consolidates the rules for PPP forgivable loans for first-time borrowers and outlines changes made by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, P.L. 116-260.
  • The 42-page IFR “Business Loan Program Temporary Changes; Paycheck Protection Program Second Draw Loans” lays out the guidelines for new PPP loans to businesses that previously received a PPP loan.

In addition, the SBA released a three-page “Guidance on Accessing Capital for Minority, Underserved, Veteran and Women-Owned Business Concerns.” That guidance includes a commitment from the SBA to make at least the first two days of the PPP application window open exclusively to applications from community financial institutions that serve minority- and women-owned businesses.

AICPA Firm Services Vice President Lisa Simpson got up at 5 am on the morning the SBA guidance was released, and was ready by 3 pm — slide deck and all — to share it with us on the AICPA Town Hall. The hour-long episode is free and available to the public — it’s all excellent, but her presentation in the first half-hour will give you almost everything you need to know. I’ll attempt to summarize it here, but honestly… you’re doing yourself a favor to sit down and watch it.

Here’s a summary of what I consider to be the highlights:

  • New application Form 2483-SD released Friday night, January 8th!
    (You heard it here first.)
  • SBA program will open January 11, in phases, as outlined above (minority-owned businesses were the last to receive assistance first-time around).
  • March 31st is last day to apply for PPP (first- or second-round).
  • For payroll costs used in calculating the loan amount (x 2.5 months, or x 3.5 for the hospitality industry, including restaurants), one can use:
    a) 2019, b) 2020, or c) 12-months’ prior to application.
  • Borrowers that want a 2nd PPP must show a 25% quarterly revenue loss in any quarter of 2020 compared to the same quarter in 2019 (or annual, see below). The SBA is streamlining this for loans under $150k. It will not require supporting documentation to be submitted with the application but only later, when applying for forgiveness.
  • Businesses trying to show the quarterly 25% revenue drop for 2nd PPP loans can cite an annual reduction of 25% and submit copies of annual tax forms to verify. SBA and Treasury say this will help small borrowers that may not have quarterly revenue information readily available.

For details on both first-draw and second-draw maximum loan amounts and eligible costs, this Journal of Accountancy article is the best summary I have read so far.

The AICPA has been very generous in encouraging us to share its slides from the Town Halls in order to get the word out. Here are a few “best of” from Thursday’s session. Again, I encourage you to watch for yourself to get some clarity.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

SBA Announces Streamlined PPP Forgiveness for Loans Under $50K

Another late-night guidance drop from the SBA — this time, good news for PPP borrowers of $50,000 or less… and somehow managed without the Congressional action we’ve been waiting for that seems to have all but stalled out.

The SBA has released a new, streamlined forgiveness application for these borrowers (and has eased the burden on lenders as well) — but notably, the requirements are exactly the same as prior to this newest Interim Final Rule. It’s just the simplified application and reduced documentation that make it easier. This means that small business owners still have to meet all the forgiveness rules that were in place before this most recent development — and they must certify as such on the application.

So on the one had, it’s great news — on the other, I’m not sure how much this will help anyone… it’s essential to run the numbers and collect the documentation regardless, to confirm compliance, as well as for support should the forgiveness be audited or challenged.

This also is a far cry short of the “under $150,000” floor that has been introduced by numerous members of Congress. Maybe this is just a start, and it will be increased with a legislative act?

Regardless… because the calculations and documentation must be dealt with despite the shorter application (and kept for your permanent records), I still recommend using the free AICPA tool — PPPForgivenessTool.com — as it does an amazing job of taking care of much of the number-crunching behind the scenes, and turns out an application and supporting documentation pdf packet that should be just the thing for your files. It’s the best PPP calculation resource I’ve tested yet (and believe me, I’ve tested quite a few).

Given the slow pace of SBA forgiveness and the likelihood that there will be more relief coming from Congress after the election, the AICPA continues to recommend that borrowers hold off on applying for forgiveness for now — unless they need to because they’re selling a business or have restrictive debt covenants.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Last Chance (For the 3rd Time) for PPP Applications – List of Available Lenders

PPP Application Deadline is August 8th

Saturday, August 8th is the last day to apply for Paycheck Protection Program funding.

As a reminder, the program is open to independent contractors, gig workers, sole proprietorships, partnerships, LLCs, S-Corps, C-Corps, cooperatives, and non-profits, among others.

In the August 6th Town Hall, the AICPA listed the following lenders as still being open for new PPP applications:

This recent Forbes article summarizes the current state of the program. If you need assistance calculating the maximum loan based on your type of entity, see this blog post, which links to the SBA guidelines.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

SBA Releases Long-Awaited PPP Forgiveness FAQ

PPP Forgiveness FAQ released only five days before SBA begins accepting lender applications

I was presuming (in this blog post) that the SBA set an initial date for accepting PPP forgiveness applications of August 10th because surely Congress would have something ironed out before they go on recess, and that these expected legislative changes to the program were the same reason for delaying release of their FAQ (yes, the one they have been promising for the past two months).

Surprise! The SBA FAQ was released late yesterday — I’ll be attending the AICPA Town Hall tomorrow and will post an update afterwards (maybe Friday), but in the meantime, here are the best articles I’ve found on the topic so far.

Journal of Accountancy – New FAQs address PPP loan forgiveness issues
By Jeff Drew

Forbes – SBA Makes Further Changes To PPP Rules In August 4th FAQs
By Alan Gassman

ABA Banking Journal – SBA Releases New PPP Forgiveness FAQs, Lending Data


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

Paycheck Protection Program Application Deadline Extended Through Aug 8

UPDATE 7/4: The PPP Extension has been signed into law.

UPDATE 7/1: It has passed the House as well and is expected to be signed by the President today.

Total shock and surprise… out of nowhere, the Senate unanimously passed a five-week extension to the Paycheck Protection Program application deadline, just a few hours before it was set to expire.

According to USA Today:

Sen. Ben Cardin, D-Md., the top Democrat on the Small Business Committee, said on the floor that senators picked August 8th because that’s the end of the Senate’s next work period and lawmakers are hoping to pass the next relief package by then.

Additionally, Sen. Susan Collins, R-Maine, who helped negotiate the initial small business portions of the March coronavirus relief legislation, said that the extension would make certain we “don’t see an interruption in this program” while a fifth relief bill is being negotiated in Congress. 

The unanimous agreement Tuesday night was unexpected, as lawmakers have clashed over issues regarding the program, including legislation regarding how to possibly redirect the unused $130 billion.

The deadline had recently been extended for a few specific borrowers who challenged some of the requirements in court and won — but this ruling only applied to those specific instances. However, their challenge pointed out some unfair restrictions in the PPP application requirements regarding criminal records that have since been remedied (though none of the online applications I have seen have incorporated the new rules yet). Given the timing of the recent guidance, there were certainly many would-be applicants that would not have been able to apply, and hopefully this extension will help.

There also is simply a huge amount of money left — $130 billion. There was so much confusion and fear about applying and getting loan forgiveness that the funds didn’t make it to many of the intended recipients; many never even applied. For example, I helped three folks this week who thought the program “didn’t apply to them”. Now that the rules are easier to follow, make more sense, require less work, and are clearer, hopefully small business owners will come out of the woodwork and get some much-needed assistance.

The House is expected to pass the measure and the President is expected to sign it. The bill passed in the Senate by unanimous consent.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

FREE Zoom Webinar On Newest PPP Guidance — June 26, 2020

As promised in my most recent PPP blog post, there’s tons of good news on the PPP front. This past Friday, June 26th, I led a webinar for clients and colleagues to summarize the newest guidance, give tips on next steps, and walk through the newly-updated AICPA forgiveness spreadsheet.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

PPP Updates — *SO MUCH* New PPP News!

So much has happened since my last PPP posts, just a week-and-a-half ago, I hardly know where to begin.

Let’s start with the good news: all of it is good news!

As you may recall, Congress passed the June 5th PPP Flexibility Act, and SBA & Treasury came out with new guidance on June 11th, which I covered extensively. They followed up by reducing the non-financial felony threshold a couple days later. Then the new forgiveness application and EZ-version (thank goodness) were released shortly afterward, on June 17th. However, I held off publishing blog posts or holding webinars on the new applications, since they were released without guidance — and like many of us, waited for the answers to our many outstanding questions.

Well, in the past week that guidance continued to trickle in, culminating in some key answers from the June 22nd Interim Final Rule (IFR) that — believe it or not, after almost three months — actually leave us with most of our concerns answered, and a clear path forward for most small business borrowers.

<This is the part where your blog writer takes her hard-earned glass of wine and raises it in a gesture of cheers.>

The confidence in the piecemeal guidance released since June 5th was evident this morning, when the AICPA decided to re-release their most excellent PPP Forgiveness Calculator Spreadsheet. Mind you, it’s in draft form, and I did find a couple mistakes when I took it on a test-run tonight — but they are quick to incorporate correction requests, and more importantly, this indicates to me that the folks there feel that we’ve gotten most of what we can expect to get from SBA/Treasury on the topic, and we can get back to work on forecasting. (Oh yeah — and tax preparation, as my clients and staff are reminding me.)

Another small win is that the SBA finally agreed to release names of recipients of PPP loans larger than $150,000. SBA loan recipients have always been a matter of public record, so I admit that I was confused by the political angle on this — but in the end, I think the compromise struck is one that will allow single-owner and other closely-held small companies the privacy they need for payroll purposes, while balancing the demands of the public to know where their taxpayer dollars are going. Reportedly, this will account for nearly 75% of the loan dollars approved.

So — what’s new?

These game-changers:
– Non-owner employee compensation can be forgiven based on their full 24-weeks of pay — up to a $46,154 (24/52 x $100,000) cap — if the 24-week period is elected;
Owner compensation limits increase to 2.5 months of 2019 income capped at $100k (20.833%) if the 24-week period is elected (compared to 15.385% of 2019 if the 8-week period is used);
Borrowers may submit application early — as soon as requirements are met (including FTE calculations, meaning that even if a borrower does not meet either of the FTE Safe Harbors, they can determine the period for which FTEs must be maintained, between 8 and 24 weeks);
– FTE Safe Harbor #1 (business activity limited by government mandate) will apply to the vast majority of borrowers, and frees them from performing the hellish FTE calculations;
– FTE Safe Harbor #2 (the original Safe Harbor) allows choice of December 31st or the date of forgiveness application.

What does this mean?

First-off: any business owner(s) with no employees should elect the 24-week forgiveness period. Instead of the 8/52-week limit x 2019 compensation available for those who stick with the original 8-week period, those who elect the 24-week period will have 2.5 months x 2019 compensation forgiven instead. That’s an increase from 15.384% to 20.833%. And since most of these small business owners received their loan based on 2.5 times their 2019 monthly average, this will clearly earn them full forgiveness. (Furthermore, it eliminates the challenging situation whereby the loan amount was determined in months and the compensation limit was determined in weeks, putting most Schedule C and partnership filers in a position where full forgiveness was impossible.)

Secondly: once you have spent the money consistent with the rules, go ahead and submit your forgiveness application early, regardless of whether you have employees or not. You can elect the 24-week period, allowing for more generous caps, but then end the period early. There are many advantages to this approach:
– having a shorter period over which to meet the FTE test, or an earlier date to qualify for the FTE Safe Harbor #2 (the original FTE safe harbor)
– getting the loan off the Balance Sheet and freeing up any leverage you might need to be able to borrow from other lenders
– avoiding the possibility of straddling a tax year with potentially non-deductible expenses to address
– peace of mind

What don’t we know yet?

One unanswered question is whether or not the owner-compensation limitation applies to spouses or other relatives. So far there are no attribution rules, so presumably they fall under the (more generous) calculations for regular (non-owner) employees (assuming the wages are legitimate compensation for services rendered to the company). 

What happens if the FTEs cannot be maintained due to a limitation on business activity that was not caused by government agency mandate? I am thinking of some professional services, for example, dog-walking, where technically the company was allowed to continue activities at full capacity, but the drop-off in business was precipitous. In this case the FTE rule will not be met, nor Safe Harbor #1 (government mandate). They could aim for the December 31 Safe Harbor #2 (the original safe harbor test), but that would be a gamble, and would presumably delay forgiveness by many months. This is not a large group of borrowers, but the consequences faced by them are certainly inequitable.

Are retirement contributions on behalf of owners allowable? Capped? The guidance makes it clear that these costs are not allowable for Schedule C filers or partners, as any funds earmarked for retirement are already counted in net income before being contributed. For owner-employees, there’s language in the EZ application — but not the main application — that makes it sound like retirement contributions are only allowed to the extent they are included in income, and are capped at 2.5 months x the 2019 amount. Why the discrepancy is unknown. This article discusses that topic in more detail.

There was concern about the announcement that S-Corp owners were suddenly not able to include health insurance in the payroll total — but it turns out that’s because by law those costs are already considered part of the Box 1 W-2 wages. It just means you can’t double-count them. (Schedule C filers and partners were already disallowed health insurance costs for forgiveness, as similarly, they are paid out of net income, which has already been counted for forgiveness purposes.) This article discusses that topic in more detail.

What’s next?

Unquestionably the most comprehensive and accurate FAQ I have read so far is by the AICPA. I strongly encourage all PPP recipients to read through it — especially before contacting your CPA with questions. :)

And for a step-by-step explanation of how to calculate forgiveness, I’ll also point you to the AICPA (no, I do not receive any remuneration from them — I’m just impressed by their resources). This step-by-step guide is quite helpful, and also points you to their greatest contribution to the PPP forgiveness thus far — the AICPA PPP Forgiveness Calculator Spreadsheet. Don’t fill out your forgiveness application or plan accordingly without it!

If you haven’t applied yet, please do. There are only a few days left in which to do so, and $130 Billion still available. The SBA has recently relaunched its Lender Match site, which connects small businesses with SBA-approved PPP lenders to get their loans approved before the June 30th deadline. I’ve had excellent luck with Cross River Bank, which has provided approximately 70% of my clients’ PPP loans, either directly or through various FinTech companies — and there was a great article in the New York Times about them recently. (Nope, those links aren’t monetized and I receive nothing from them. Just hoping to help out some small businesses.)

After a few more webinars on the topic — see the most recent one here — I plan to take a break from PPP planning for a short while and focus on tax preparation. I can’t begin to express my relief that we finally have a comprehensive PPP rule book that takes the real world into account.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

PPP Applicant Non-Financial Felony Threshold Reduced

From the June 14th SBA E-Newsletter :

The eligibility threshold for those with felony criminal histories has been changed. The look-back period has been reduced from 5 years to 1 year to determine eligibility for applicants, or owners of applicants, who, for non-financial felonies, have (1) been convicted, (2) pleaded guilty, (3) pleaded nolo contendere, or (4) been placed on any form of parole or probation (including probation before judgment).

The period remains 5 years for felonies involving fraud, bribery, embezzlement, or a false statement in a loan application or an application for federal financial assistance. The application also eliminates pre-trial diversion status as a criterion affecting eligibility.

SBA issued revised PPP application forms to conform to these changes. The guidance and revised application forms are available on SBA’s and Treasury’s websites. SBA will issue additional guidance regarding loan forgiveness and a revised forgiveness application to implement the PPPFA in the near future.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.

SBA & Treasury Release Initial PPP Flexibility Act Guidance – FREE Zoom Recording

Late night on June 10th, the SBA and Treasury released the 17th interim final rule to reflect changes made by the Paycheck Protection Program Flexibility Act. SBA also published updated application forms to use for loans made on or after June 5, 2020.

The new IFR is mostly a restating and clarification of what we already knew from the statute, its accompanying statement, and the recent Treasury statement.

We are still waiting for guidance for most of our questions, which is especially frustrating given that many PPP loan borrowers have reached or are nearing the end of the original eight-week covered period. As has been a consistent theme, the SBA and the Treasury have promised additional regulations and guidance soon. The concern over the constantly-changing, difficult-to-understand rules — which have been impossible to plan around thus far — has caused a big slow-down in applications. As of now, PPP loans must be approved by June 30th (not applied-for, but approved-by).

(For those who haven’t yet applied: these days I’m finding Funding Circle to have the quickest turnaround and easiest application process for new borrowers. No, I do not receive any benefits from them.)

The biggest problem with the PPP is that you will likely need an accountant (or you could possibly get away with an advanced degree in mathematics) to figure out how to calculate the forgivable portion of the loan — which is hard enough on its own, but even harder when trying to plan, as the rules keep changing. The government did not — in any of the three Acts that involve these loans — realize the administrative burden these rules place on business owners… especially at a time when they’re trying to figure out how to survive the coronavirus shutdown and cautious reopening of our economy.

That said, it may no longer be “free” money, but in most cases, it is definitely still worth it. I’ve been attending the weekly AICPA Town Hall meetings and reporting on them to my clients and colleagues, and making some of those recordings available for the public, in hopes that it will help guide you (or your clients) to making better decisions about how to use the funds.


Here are my notes from the above zoom session, in case it’s easier to read than to listen/watch, or in case you’d like to follow along.

I have taken three webinars on the new PPP forgiveness rules in the past week — and gotten three different interpretations, and a lot of misinformation. So please keep in mind that I am only AN expert, not THE expert.

AICPA Town Hall 6/11 – WHAT WE KNOW

  • Treasury statement came out 6/8 and more guidance released 6/10.
  • 60% cliff fixed!
  • Extension to 24 weeks is automatic; can elect 8-wk period on forgiveness application.
  • The Interim Final Rule released today does not address FTEs. As-written, we’ll have to keep FTEs up for 24 weeks.
    Alternatives: expansion of FTE reduction exemptions AND/OR Safe Harbor of 12/31/20.
  • May not use the old application… wait for new one.
  • Simplified application expected for those with no employees — at the very least, AICPA will release simplified spreadsheet.
  • You do not have to wait until the end of the 24 weeks to apply for forgiveness if you meet the requirements.
  • If you use the 8-week period, the new 60% rule applies – you do not still need to meet the 75% rule.
  • They are trying to get every loan forgiven as much as possible – guidance will be lenient; more relief may come.
  • Treasury referred to ACIPA forgiveness spreadsheet as the gold standard (yay!)
  • You can reapply for PPP if you returned the money or didn’t get full funding.
  • RECOMMENDATION — OPT IN TO PAYROLL TAX DEFERRALS!
  • June 10: Sec. Carranza indicated new EIDL applications will be accepted starting next week!

WHAT WE DON’T KNOW

1) Owner compensation limits – extended to 24/52 of 2019… or remain at 8/52? Waiting for guidance.

2) Will the FTE reduction rule remain in place as-is? It was hard enough for clients to keep average FTE at 100% of their comparison period for 8 weeks, but 24 weeks will render this new “flexibility” useless. Currently, for clients in this situation who cannot use expansion of FTE reduction exemptions or Safe Harbor of 12/31/20, we are encouraging sticking with original 8-week covered period.
(Compass Tax agrees this is the largest remaining concern.)

3) FTE reduction flexibility — the examples I’m seeing are when companies don’t have the same level of activity due to agency standards. But what if you’re “allowed” to open at 100% capacity, but you just don’t have enough business anymore? Currently “too bad” as-written… will this change with SBA interpretation?

4) FTEs – the 1.0 vs 0.5 shortcut calculation… do we still have to calculate this on a weekly basis? I have two colleagues who say you can just count any PT staff who worked at any point during the forgiveness period as 0.5, and similarly for FT, but none of the FTE calculators or case-studies I’ve seen have used this approach. This would make passing the FTE test SO MUCH EASIER.

5) Our clients who (for various reasons) did not apply for PPP beforehand, we had them take the ERTC instead. So now that the forgiveness rules have changed, they want to apply for PPP; but they are disqualified because you can’t do both. Best solutions here? Backing out the credits before filing the 941? Amending the 941?
AICPA response: “If they receive the ERC, they are ineligible for PPP per the CARES act.”

6) EIDL advance grant — subtract from PPP forgiveness or not?
Some folks are saying you have to deduct EIDL advance grant from PPP forgiveness — some say you only do this if you spent it on same costs as PPP.
It looks like on the PPP application you have to deduct it… BUT it says “if applicable”. Since the CARES Act is clear about the fact that it does NOT have to be deducted if taken after April 6 and not used for the same costs, many are saying the “if applicable” means only if pre-April 6th or if used on the same costs as PPP. It sounds like you’re saying that’s not your interpretation, even though it’s in the CARES Act?
AICPA had previously said on their FAQ that we’re waiting for SBA guidance on this. Now they’re saying it has to be subtracted. “If an advance is received, it will reduce PPP forgiveness. If they are used for different purposes, a borrower is able to take loans from both programs but it does not impact the reduction of the advance from the PPP forgiveness.”

The most up-to-date AICPA Summary of the PPP Flexibility Act can be downloaded here.


If this or any other posts on the website were useful to you, and your financial situation permits it, please consider contributing to my tip jar. This allows me to continue to provide free accounting resources to small businesses who do not have the funds available to hire a CPA.