bet9游戏平台 continues to track the evolving landscape of federal financial programs offered in the wake of the business disruption caused by the coronavirus crisis. 12月21日, 2020, the Consolidated Appropriations Act of 2021 (the Act) was passed by both houses of Congress, 其中包括对遭受重创的企业的经济援助, 非营利组织, 和场地法(经济援助法). 1月6日, 2021, the Small Business Administration (SBA) issued an Interim Final Rule (IFR) regarding the Act’s impact on the 工资保障计划(PPP).
本财务报告的目的是什么?
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总结经济援助法案下购买力平价的变化.
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将先前的指导合并为一份文件.
The IFR is intended to govern new PPP loans made under the Economic Aid Act and applications for forgiveness on existing PPP loans where the loan forgiveness has not been remitted. 然而, the IFR clearly states that it is not intended to substantively alter or affect PPP rules that were not amended by the Economic Aid Act.
另外, rules related to the second round of PPP (PPP2) are addressed in a separate IFR and the SBA intends to issue a consolidated rule governing all aspects of loan forgiveness and the loan review process.
While the IFR does not contain significant new updates that were not in the Economic Aid Act, the main benefit of the IFR is the consolidation of all guidance in one place. Borrowers and their advisors can use this as their “one-stop shop” to PPP guidance without having to reference nearly 25 other IFRs issued by the SBA and Treasury.
大的变化是什么?
如上所述, 在现实中, there is not much new in the IFR that was not addressed in the Economic Aid Act and summarized in our December 23, 2020, OTO文章 对工资保障计划的修订.
然而, there was one change of significance between the Economic Aid Act and the IFR. For PPP loans that were made in 2020, most borrowers used 2019 payroll costs. The IFR allows first draw PPP borrowers to use either 2019 or 2020 payroll amounts to calculate their maximum loan amount. The Economic Aid Act did not change the original guidance for borrowers who were not farmers and ranchers. 因此, this would have resulted in new first draw PPP borrowers who were newly eligible being required to use 2020 payroll to determine their maximum loan amount.
The Act also required farmers and ranchers to calculate their maximum loan amount using 2019 payroll costs.
The SBA made these adjustments in order to allow all borrowers to obtain funding on terms consistent with other new and existing PPP borrowers. 另外, it avoids borrowers having their loan amount reduced if 2020 operations were negatively impacted.
申请PPP贷款
The SBA also announced that the PPP portal for accepting applications will officially reopen on Monday, 1月11日, 但是时间轴很有趣.
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1月11日 – Accept PPP1 loan applications from businesses who have not received a PPP loan. 进一步, it will only be accepting applications from lenders considered “community financial institutions.”
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1月13日-接受PPP2贷款申请, 但这些贷款只能来自“社区金融机构”.”
This appears to be a response to some earlier criticism that certain smaller businesses and lenders initially had difficulty getting PPP loans. PPP应该在不久之后向其他贷方开放.
If you need more information or assistance regarding the PPP, visit our dedicated PPP贷款网站, reach out to any of your contacts at bet9游戏平台 or contact Joel Rosenthal at jrosenthal@freoreport.net.