PPP Loan Forgiveness Guidelines - Quick Summary (5/19/20)

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Subject: PPP Loan Forgiveness Guidelines (5/19/20)

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PPP LOAN FORGIVENESS GUIDELINES

QUICK SUMMARY

The long-awaited view to the PPP Loan Forgiveness Application was released over this past weekend. It provides the application and instructions for loan forgiveness under the Paycheck Protection Program (PPP).

The application has brought some needed clarity around “Payroll Costs,” calculations, and the covered period. The form and instructions include several measures to reduce compliance burdens and simplify the process for borrowers, including:

• Options for borrowers to calculate payroll costs using an “alternative payroll covered period” that aligns with borrowers’ regular payroll cycles

• For administrative convenience, the application allows borrowers with a biweekly (or more frequent) payroll schedule to calculate eligible payroll costs using the 8-week (or 56-day) period beginning on the first day of their first pay period following the loan disbursement date (Alternative Payroll Covered Period). (For example, if the borrower received the PPP loan on April 20, 2020, and the first day of its first payroll period following the disbursement date is April 26, 2020, the first day of the Alternative Payroll Covered Period is April 26, 2020 and the last day of the Alternative Payroll Covered Period is June 20, 2020.)

• If a borrower elects to use the Alternative Payroll Covered Period, it must apply this period wherever the application references “the Covered Period or the Alternative Payroll Covered Period.” (If the application only references Covered Period, the borrower must apply the Covered Period (i.e., the 8-week (or 56-day) period beginning on the disbursement date of the PPP loan.))

• Flexibility to include eligible payroll and non-payroll expenses paid or incurred during the eight-week period after receiving their PPP loan

• Step-by-step instructions on how to perform the calculations required by the CARES Act to confirm eligibility for loan forgiveness

• Borrower-friendly implementation of statutory exemptions from loan forgiveness reduction based on rehiring by June 30

• Addition of a new exemption from the loan forgiveness reduction for borrowers who have made a good-faith, written offer to rehire workers that were declined

HERE ARE YOUR LINKS: (won’t work on my website)

CLICK HERE to access the SBA website

CLICK HERE to access the PPP Loan Forgiveness Application

As always, I hope this information is useful. On another subject, now that we are in election season for the Small Firm Seat on the FINRA Board of Governors, I urge all of you to sign petitions to help the candidate of your choice get their name on the ballot. Then be sure to VOTE for your candidate when the ballots come out.

I know you hear this all the time, but it really is very important that we elect the RIGHT person to fill this seat and be 1 of the 3 small firm people who represent us. (Right now, Linde Murphy and I are the other two.)

Here's my personal truth after being on this board for two years: moving the needle even a little bit with the board on issues of import for small firms is incredibly difficult. Don't get me wrong, it is not for lack of effort (Have you MET me?!), but it is very challenging to be heard and understood on a 24-person board, the majority of whom are public board members.

As we all know, the small firm experience is unique and one that, unless you have been on the front lines with us, working with limited human and financial resources while wearing 10 hats at once and dancing to the tune of multiple regulators, you can't, don't, and won't be able to really relate to or understand. That's fine, there are elements of being Jamie Dimond that I can't and don't fathom; we all have our role to play and ours is different than his. But we at least need a fighting chance to integrate our voice into the chorus of the board, which means we need the right 3 people representing us on the FINRA Board of Governors.

I would like to ask that everyone tune in to the election this year (and every year), take time to learn about the petition candidates who are trying to get their name on the ballot, sign the petition of your choice, and then vote in the election. Your vote can make a difference, these are almost always very close races.

Thanks for listening and, as always, I am here if you have any questions or need assistance with small firm or minority firm matters.

Stay Safe. Stay Strong. Stay in Touch.

Paige

Paige W. Pierce

President, CCO

McLaughlin Ryder Investments, Inc.

(801) 949-5577 m

(703) 684-9222 w

ppierce@mclaughlinryder.com