Paycheck Protection Program ("PPP") — Updated Guidance from the SBAOn Wednesday, May 13th, the Small Business Administration ("SBA") updated their Frequently Asked Questions Document ("FAQ") and added FAQ #46 and FAQ #47.
In FAQ 46, the SBA revised its review threshold and safe-harbor provision and noted that businesses that accepted Paycheck Protection Program (PPP) funds of less than $2 million will be assumed to have made the required certification concerning the necessity of their loan requests in good faith. However, businesses with loans in excess of $2 million will still be subject to review by the SBA. This FAQ further clarified the SBA’s intent to seek repayment of the outstanding loan balance if a business under review is deemed to lack sufficient support for the required certification concerning "necessity" in accordance with the terms of the PPP program, in addition to informing the lender that the PPP loan is not eligible for forgiveness. However, the SBA noted that they will not pursue administrative enforcement or referrals to other agencies with respect to such certification if the business repays the loan in accordance with this provision.
FAQ #47 extends the repayment date for the safe harbor to May 18, 2020, (previously May 14th per FAQ #43) to give businesses some opportunity to review and consider FAQ #46.
For more information on these latest FAQs, please refer to CAMICO's COVID-19 Paycheck Protection Program (“PPP”) Frequently Asked Questions.
Returning to the Office — What Does the "New Normal" Look Like for Firms?As many counties and states loosen COVID 19–related restrictions for employers across the country, more questions than answers arise regarding best practices in return-to-work procedures.
While continuing to allow employees to work in a remote capacity would be ideal, for some firms continuing with a remote work environment might not be feasible. CPA firms are reporting problems such as managing employees who cannot telework; maintaining morale and cohesiveness in a remote environment; overseeing employees and their work; and dealing with unplanned technology costs, connectivity issues, and concerns related to cybersecurity and the safeguarding of client data.
This "new normal" is anything but normal, and information and best practices about how best to structure return to the workplace and how to safely behave in the workplace will likely change frequently. Firms will need to be flexible and responsive as information and best practices regarding the pandemic are updated by local governments, the World Health Organization (WHO), and the Centers for Disease Control (CDC). Now, more than ever, management needs to be thoughtful and compassionate when dealing with the myriad of feelings employees will have as they contemplate returning to the office. Employees may be feeling anxious about being in the office surrounded by others; or due to personal or medical reasons, they may be unable to wear a mask; or perhaps they are considered at risk themselves or have an at-risk family member in their household. These are uncharted waters and trying times for employers and employees alike, and a more delicate approach may be necessary when dealing with employee issues related to this pandemic.
Preparing for employees returning to the office should be a thoughtful and deliberate process and one supported by guidelines set by state and federal health officials. As firms begin the planning process, there are several items for consideration in preparing the office and employees for the eventual return to minimize some of the potential pain points. Read More