The SBA released an Interim Final Rule on the PPP last week, though CUNA, the American Association of Credit Union Leagues and Leagues have called for several changes to help credit unions serve members more efficiently.
According to the FAQ document, the U.S. government “will not challenge lender PPP actions that conform to this guidance, and to the PPP Interim Final Rule and any subsequent rulemaking in effect at the time.”
The document answers questions such as:
- Are small business concerns required to have 500 or fewer employees to be eligible borrowers in the PPP?
- Does my business have to qualify as a small business concern in order to participate in the PPP?
- Are lenders required to make an independent determination regarding applicability of affiliation rules under 13 C.F.R. 121.301(f) to borrowers?
- Are borrowers required to apply SBA’s affiliation rules under 13 C.F.R. 121.301(f)?
- Do PPP loans cover paid sick leave?
- What if an eligible borrower contracts with a third-party payer such as a payroll provider or a Professional Employer Organization (PEO) to process payroll and report payroll taxes?
- May lenders accept signatures from a single individual who is authorized to sign on behalf of the borrower?
- Are lenders permitted to use their own online portals and an electronic form that they create to collect the same information and certifications as in the Borrower Application Form, in order to complete implementation of their online portals?
- What time period should borrowers use to determine their number of employees and payroll costs to calculate their maximum loan amounts?
- Are PPP loans for existing customers considered new accounts for FinCEN Rule CDD purposes? Are lenders required to collect, certify, or verify beneficial ownership information in accordance with the rule requirements for existing customers?
The SBA has also posted a FAQ document on participation of faith-based organizations in the PPP.
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