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The SBA’s FAQs on the PPP

Here’s the government’s FAQ sheet on the Paycheck Protection Program, current as of today. It may not have all the answers, but it gives relatively simple answers to 47 questions by lenders, borrowers, and others.

Here’s a sampling:

  • Do payments to independent contractors count toward payroll? No. See Question 15.
  • Do part-time employees count? Yes, for eligibility but no, for loan forgiveness. See Question 36.
  • What if I laid someone off? Can I still obtain loan forgiveness if I try to rehire them? Yes. See Question 40.
  • Will the government second-guess whether my loan was necessary? Yes, if it’s more than $2 million but no, otherwise. But don’t get cute. See Question 46.

Finally, here’s a reminder that you have until Monday to repay or return your loan, no questions asked, if you shouldn’t have certified that it’s necessary. It’s not a problem for most people who need these loans to meet payroll and don’t have other sources of liquidity. But it may be a problem for public or private companies with access to capital markets or adequate liquidity to support their operations. See Questions 31, 37, & 43.

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