By Thomas E. Rutledge
Stoll Keenon Ogden, PLLC
Recently there have been a number of new developments in the Paycheck Protection Program (“PPP”); not surprisingly unresolved questions remain. A crucial one is whether and how a borrower may submit a loan forgiveness application before the end of the new 24-week period in which loan funds may be disbursed.
The PPP continues to challenge and sometimes befuddle borrowers who now seek forgiveness of their loans. While we may lament the complexity of the forgiveness process, it is what it is, and it is necessary for borrowers to carefully consider and apply the applicable rules. This article considers and explains a number of the limitations imposed upon loan forgiveness, particularly limitations imposed by changes in the borrower’s total number of employees as compared to the pre-loan period, or changes in employee compensation since that same period. This article also explains a number of regulatory safe harbors that have been created with respect to those limitations.
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