Although today’s interim final rule is focused on bringing a prior interim final rule into compliance with the changes proposed by the Act, it contains a notable clarification regarding the requirement that 60% of a borrower’s PPP loan amount be spent on eligible payroll costs for the borrower to qualify for loan forgiveness.
The interim final rule clarifies that the new 60% threshold is not to be treated as an all or nothing requirement. Rather, the interim final rule explains that the 60% requirement is “a proportional limit on non-payroll costs as a share of the borrower’s loan forgiveness amount, rather than as a threshold for receiving any loan forgiveness.” Thus, a borrower who spends less than 60% of its total loan amount on eligible payroll costs will still be eligible for loan forgiveness—the total forgiveness amount will just be reduced proportionally.
Today’s interim final rule states that revisions to other interim final rules are forthcoming. Further, although portions of the interim final rule are effective retroactively, the SBA is still soliciting comments from interested members of the public. These comments must be submitted on or before the date that is 30 days after the date of publication in the Federal Register. Comments may be submitted through the Federal eRulemaking Portal.
If you have questions about qualifying for forgiveness of your PPP loan or general questions about navigating workplace issues during the COVID-19 pandemic, please contact Gabrielle Hansen at 503-276-2112 or email@example.com.
Electronic Alerts are written by Barran Liebman attorneys for their clients and friends. Alerts are not intended as legal advice, but as employment law, labor law, and employee benefits announcements. If this has been forwarded to you, and you would like to begin receiving Electronic Alerts directly, please email or call Traci Ray at 503-276-2115. Copyright ©2020 by Barran Liebman LLP.
Las Alertas electrónicas son escritas por abogados de Barran Liebman para sus clientes y amigos. Las Alertas no son proveídas como asesoramiento legal, sino solo como anuncios de leyes de empleo, leyes laborales y beneficios de empleo. Si esto ha sido remetido a usted y quisieras empezar a recibir las Alertas directamente, por favor mándanos un correo electrónico o llama a Traci Ray al 503-276-2115. Derechos de autor ©2020 por Barran Liebman LLP.