One Month Into PPP: How to Maximize Forgiveness and Ensure Compliance
UPDATE – May 13, 2020: This morning, the Small Business Association (SBA) finally released the promised guidance regarding what a “good faith certification” looks like for the purpose of complying with the Paycheck Protection Program (PPP) – and avoiding criminal prosecution. This guidance is limited in scope to the good faith certification over the necessity of the loan. Notably, the SBA is providing a safe harbor based on the original principal amount of a loan. FAQ 46 states that recipients (and their affiliates) with loans of less than $2MM will be deemed to meet the requirement of good faith. (For full text of FAQ 46, click here.)