Read more about the current Greenbook proposals. ...
This site uses cookies to ensure that we give you the best user experience. Cookies assist in navigation, analyzing traffic and in our marketing efforts as described in our Privacy Policy.
This article was updated on May 1, 2020. Updates to this article will be made as new information becomes available.
Schneider Downs continues to track the evolving landscape of Federal financial programs offered due to the disruption of the coronavirus (COVID-19).
Over the past week or so, there has been additional attention and scrutiny surrounding the required PPP loan certification that states that “"[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” The SBA has since added that “Borrowers must make this certification in good faith, taking into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business.”
These items are specifically addressed in the SBA’s PPP FAQs #31 and #37. The SBA then added FAQ #39 that indicates that all loans above $2 million (and other loans as necessary) will be reviewed.
While detailed guidance surrounding the interpretation of these statements and implementation of the review procedures has not been provided, borrowers should retain solid documentation and consider the following in determining if they can respond in good faith that the loan request is necessary:
The list above is not all-inclusive and borrowers need to consider their facts and circumstances, but companies that are not in compliance may be subject to criminal penalties for falsely certifying the need for funds. Loans can be returned prior to May 7, 2020 and will be deemed by the SBA to have made the required certification in good faith.
If you have any questions regarding the PPP, first reach out to your bank and other lenders. If you need more information, please reach out to any of your contacts at Schneider Downs or contact Joel Rosenthal ([email protected]).
Please visit our Coronavirus Resource Center for related content.
Read more about the current Greenbook proposals. ...
Learn more about the regional and national supply chain implications of the Baltimore Key Bridge collapse. ...
We’d love to hear from you. Drop us a note, and we’ll respond to you as quickly as possible.
Ask us
[email protected]
p:412.261.3644
f:412.261.4876
[email protected]
p:614.621.4060
f:614.621.4062
[email protected]
p:571.380.9003