Explains that borrowers and lenders may consider the principal residence rules in Regs.States that the cost of a housing stipend or allowance provided to an employee as part of compensation counts toward payroll costs, subject to the $100,000 annual compensation per employee limitation.The SBA added questions 32–35 on Apand question 36 on Apto the above-mentioned FAQs. However, borrowers whose previously-submitted loan applications have not yet been processed may revise their applications based on clarifications reflected in these FAQs. Borrowers and lenders may rely on the laws, rules, and guidance available at the time of the relevant application. You do not need to take any action based on the updated guidance in the new SBA FAQs dated April 23, 2020. What happens if you applied for a PPP loan based on the version of the PPP Interim Final Rule published on April 2, 2020? The $10 million cap on PPP loans is a limit per franchisee entity, and each franchisee is limited to one PPP loan.

If a franchise brand is listed on the SBA Franchise Directory, each of its franchisees that meets the applicable size standard can apply for a PPP loan. How do the $10 million cap and affiliation rules work for franchises? The lender must make the first disbursement of the loan no later than 10 calendar days from the date your PPP loan was approved. The eight-week period begins on the date the lender makes the first disbursement of the PPP loan to the borrower. When does that eight-week period begin to determine the amount of forgiveness for a PPP Loan? Highlights from the New SBA Frequently Asked Questions (FAQs) On April 28, 2020, after new revelations about big businesses getting money in the first wave, including the Los Angeles Lakers and Shake Shack, Treasury Secretary Steve Mnuchin stated that the SBA would undertake a “full review” of any loan that exceeds $2 million under the PPP. It is unlikely that public companies with substantial market value and access to capital markets will be able to make that good faith certification since they are able to tap into other sources of funding. Remember that borrowers applying for PPP loans must certify that these funds are necessary due to the current economic conditions. These returned loans will go back to the fund to be distributed to those business who need the funding. The SBA indicated that large public companies who received a PPP loan before the rule change can avoid scrutiny by returning the relief loans in two weeks – this is a safe harbor period for those businesses to return the PPP loan. On Apthe SBA issued new guidance that makes it “unlikely” that big publicly traded companies can access the next round of PPP funding. However, the SBA continues to provide new guidelines and rules to define the PPP. The new bill did not introduce any changes to the statutory language in the CARES Act for the PPP. If you applied for unemployment while waiting for the second wave of PPP funds, you must withdraw from unemployment as soon as you receive your PPP funds. You cannot receive both a loan through the PPP and unemployment benefits. Can You Apply for Both PPP & Unemployment? That way you can immediately withdraw your applications with the other lenders. If you decide to apply with more than one lender, make sure to ask for a guarantee that the lenders will contact you before submitting your file. Considering the chaos of the initial round of the PPP along with the fact that different banks have different processes to address the demand of these loans, you might consider applying with multiple lenders. Remember that you cannot get more than one PPP loan, but you are able to apply through different lenders. PayPal, Square, QuickBooks) who are now also participating in the PPP. Look at non-traditional, alternative sources (i.e. We recommend that those business that did not receive PPP funds the first time around go through the entire list of SBA-approved lenders. Expands EIDL eligibility for grants and loans to include agricultural enterprises.$60 billion in additional SBA emergency EIDL relief.$60 billion set aside for smaller lending institutions, which serve minority and women owned businesses.$310 billion of new funding for the SBA PPP loans.The initial funding for the PPP and EIDL programs was exhausted on April 16, 2020. House of Representatives approved the bill on April 23, 2020. Senate approved new funding for two Small Business Administration (SBA) programs that were implemented as part of the CARES Act to help support small businesses in response to the coronavirus pandemic: the Paycheck Protection Program (PPP) and Economic Injury Disaster Loans (EIDL). Note: This is an update to an article originally published on April 24, 2020.

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