Guidance promulgated by the Small Business Administration ("SBA") earlier this week created some confusion regarding the accountant’s role and whether accountants are considered "agents" or "authorized representatives" when performing these services.
CPAs who assume the role of an "agent" or an "authorized representative" will create conflict of interest and independence impairment issues. We do not believe the promulgated guidelines are intended to define accountants as agents in all instances when assisting borrowers with the application process.
The AICPA Statement on CPAs as Agents for PPP Loan Applications reinforces CAMICO's best-practices guidance for assisting clients with these applications.
CAMICO has developed the following engagement letter templates and sample response to lenders for your reference:
- CARES Act: Assistance with Paycheck Protection Program
- CARES Act: Consulting Services for Available Employer Relief Provisions
- Business Client Notification — COVID-19 Relief Measure
- Lender Letter Template: Response to Lenders Requesting CPA to Provide Assurances