Whilst said loans served their purpose in propping up the US economy, they were issued without any clear guidance on some integral elements of their function. It was not clear who was eligible, what would be forgiven or how to calculate the amount that a business was able to apply for. There was, in fairness, an attempt by the SBA to provide answers to some of the most frequently asked questions. However, as evidenced by FAQ 31, these answers only served to provide even more questions (see the next blog post for more detail on this). This was a self-perpetuating cycle, answers continually changed providing an ever increasing workload to the already overloaded lives of accountants. It is our job as accountants to record everything and yet, how could we when the things we were supposed to keep track of were evolving before we could even record the last set of information.
At first, the PPP loans came with an eight week caveat. This is to say that the money had to be spent within eight weeks. However, this changed to become the twenty-four week rule.
There were also questions about employee retention. It is natural for employees to come and go in the course of business. There was no clear guidance provided as to what an employer should do if one or more of their employees moved on after they had applied for a loan.
Additionally, there was no clear guidance as to who one would have to talk to in order to have loans forgiven and what this process would even look like. It was also totally unclear as to when these loans would be forgiven.
Finally, the AICPA decided to draft up some forms in order to document every necessary element of the PPP loans and send these over to the SBA. Whilst this was enormously helpful, it did not stop the clients from calling our phones every day. It did, however, provide us with a neat list of the questions that we could expect from them. For an example of a not-so-neat list, read the following blog for discussion of the ill-fated FAQ sheet released by the SBA.
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