This information is accurate as of April 6, 2020.

On April 6, 2020, the Small Business Administration (SBA), in consultation with the Department of the Treasury, provided additional guidance in the form of Frequently Asked Questions (FAQs) to address borrower and lender questions concerning the implementation of the Paycheck Protection Program (PPP). The SBA has indicated this document will be updated on a regular basis.

Highlights of the guidance are detailed below.

For calculation of the eligible loan amount:

• The $100,000 cap on annual compensation per employee is for gross cash compensation only and the health insurance and retirement benefits can be added to the $100,000 after the cash compensation limit is applied.
• Companies can use either the 2019 calendar year gross wages or the previous 12 months gross wages in the payroll cost calculation.
• Payroll costs include compensation without regard to federal taxes imposed or withheld by the employee (i.e. – gross compensation); however employer payroll taxes are excluded.
• If a company filled the loan application out based upon the information provided in the Interim Final Rule guidance, no action is needed; however, if your loan application has not yet been processed you can revise your application based upon the FAQ guidance and resubmit.

To view the FAQs, please click here to visit the Treasury’s website.

The effects of the coronavirus are evolving rapidly and are unique for each entity’s circumstances. In addition to addressing the serious operational impacts of the coronavirus, it is important that all entities consider how the coronavirus affects their financial reporting.