Treasury Addresses Industry Questions on PPP Implementation

Posted: Apr 08 2020

The Treasury Department has updated its frequently asked questions on the Small Business Administration’s Paycheck Protection Program to address several questions raised by banks.

Among other topics, the newly added answers clarify:

That lenders may rely on borrower certifications as to the applicability of affiliation rules.
That lenders do not need to re-verify beneficial ownership information for existing customers. (If participating depository institutions have not yet collected beneficial ownership information on existing customers, they are not required to do so for those customers applying for PPP loans.)
How payroll is defined under the CARES Act, including the calculation of non-cash benefits and coverage of paid leave.
Methods for determining payroll to calculate maximum loan amounts.
That lenders who processed applications based on the April 2 interim final rule may rely on the laws, rules and guidance available at the time.

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To read the Treasury FAQs visit: https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequenty-Asked-Questions.pdf