From Nina Ozlu Tunceli, Executive Director, Arts Action Fund –
On the heels of our comprehensive Payroll Protection Program (PPP) Loan Forgiveness Webinar held on June 22nd, which you can view on our Facebook page, the Treasury/SBA released even more flexible regulations the following day that further clarified key forgiveness rules. There are several GREAT clarifications that will help you qualify to use the EZ Forgiveness Form AND get 100% forgiveness:
- If you plan to use a 24-week coverage period for your PPP loan, Treasury/SBA have now clarified that you do not have to wait for the full 24 weeks to submit your Forgiveness Application EZ Form. You can submit the form as soon as you expend the PPP loan amount. For instance, a self-employed gig worker who secured their PPP loan prior to June 5th can now potentially spend 100% of their loan amount on payroll over 10 to 11 weeks, which would not have been possible to do in 8 weeks. See page 9 of the new regulations.
- Clarification was also provided on the most important, new “safe harbor” to allow full forgiveness and to use the EZ Forgiveness Form even if you couldn’t rehire all your W2 employees because you couldn’t comply with CDC sanitation and social distancing rules. The regulation clarified that this safe harbor rule specifically still applies even if your business couldn’t rehire W2 employees (originally furloughed between 2/15/20-4/26/20) because your state or local government required your business to shutdown. See page 23 of the new regulations.
- Additionally, the Treasury/SBA announced “Enhanced Transparency” of information on awarded PPP Loans. At the request of Congress, Treasury/SBA will now disclose the names, addresses, NAICS codes, zip codes, business type, demographic data, non-profit information, and jobs supported for loans of $150,000 or more.