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**Please note, any articles written below present information known at a specific time. Please consult with us before making any business or personal decisions regarding COVID-19 relief to ensure that you are working with up-to-date information.**
Many business owners applied and received PPP (Paycheck Protection Program) loans in the beginning months of the COVID-19 pandemic to help them face the economic challenges they were facing and protect the livelihoods of their workers. These loans, administered by the Small Business Administration, have a covered period of 24 weeks, which is ending for many businesses who are now able to apply for loan forgiveness. While all guidelines are subject to change, there are several things you as a business owner can do to help them be more prepared to begin the loan forgiveness process.
All loan recipients should be in contact with their PPP lender, who can provide them with all of the updated information and requirements for applying for loan forgiveness. You will likely receive an email or other type of communication inviting you to sign into their portal to begin submitting your information. Once you have access to their portal, you can complete the process by uploading all required information. It helps to be prepared with all of the documentation you are expected to need.
Here is a general list of documents and information you should be prepared to gather:
- Loan information: You will need information from your loan document to star the process such as knowing the date the monies were deposited into your account. If you received any other assistance, such as an EDIL (Economic Injury Disaster Loan), you will need to know the EDIL Application Number and the amount of the advance.
- Payroll and other Payroll Costs: Detailed payroll information and proof of payment will be required for all submissions. This includes worksheets detailing each pay period within the measurement period with employee names, gross wages, pay rates or salary, and full-time equivalent calculations. Proof of payment includes bank statements or EFT receipts. Other payroll costs could include detailed listings of health insurance, employer retirement plan costs paid to employees, and employer paid state and local taxes.
- Additional Qualifying Costs: In most cases, the payroll costs paid during the 24-week period would be sufficient enough to cover the total of the PPP Loan, but if it is not then you can include additional qualifying costs. These include rent or mortgage interest and utilities. Detailed schedules listing all payments made including proof of payment will be required.
An Overview of SBA Forms
After logging into your SBA lender’s portal to begin the loan forgiveness process, you will see several form options that you will need to choose from to input your information into. The form you choose will depend on your business’s specific situation – including how large of a loan you borrowed and also whether or not you have reached the payroll expense threshold. Currently there are 3 forms to choose from:
- Form 3508S: A short, one-page form for borrowers that received under $50,000 of PPP funds.
- Form 3508EZ: For borrowers that received between $50,000 and $2 million AND who did not reduce their salary or hourly wages by more than 25% and did not reduce their number of employees or average paid hours between January 1, 2020 and the end of the covered period.
- Form 3508: For all other borrowers – including those who received more than $2 million.
- For businesses who received more than $2 million, there are additional forms that need to be filled out, including either a 3509 (for-profit) or 3510 (not-for-profit). These forms are a loan necessity questionnaire. Large borrowers should expect more scrutiny as to why they needed the funds and how they were used.
What are PPP Loans and How Can Loan Forgiveness Be Achieved?
By: Samuel J. Catanese, CPA and Christine Scholl, MBA
For small business owners, the COVID-19 pandemic has created a set of financial and operational challenges that could have long-lasting effects on many of their businesses. The CARES Act, passed into law on March 27, 2020, has provisions designed to protect the livelihoods of workers and the survival of these businesses. While no one knows the final regulations and if the loans will be forgiven, the following will help to explain what is known at the present time.
One provision is the administration of what are called Paycheck Protection Program Loans, or “PPP” Loans. Administered by the Small Business Administration through participating financial institutions, these loans offer 100% federally backed loans to employers with less than 500 employees through August 8th, 2020. For-profit businesses, not-for-profit organizations, sole proprietors, independent contractors, and self-employed individuals can apply for these loans.
One of the hallmarks of PPP loans is that if the borrower uses the funds for specific purposes, the loan may be 100% forgiven. To achieve loan forgiveness requires an understanding of specific rules and guidelines set forth by government agencies. While these guidelines are still being developed and are subject to change, there are practical steps that borrowers can take to plan and document their use of the loan. First, borrowers must understand the general rules of the loan and loan forgiveness. Then, they should set up a budget to ensure that they will follow those rules throughout the 24-week time period starting when loan funds are received. Finally, documentation will be prepared and analyzed by the SBA lending institution that facilitated the loan.
Understanding Loan Guidelines
Small businesses that have applied for a PPP loan have begun to receive their funding through their SBA lender. Once that pool of eligible dollars is issued and delivered to the business, it is up to the business to budget and use those dollars in the correct way.
For full forgiveness, at least 60% of funds must be dedicated towards payroll purposes, and only a maximum of 40% can be used to pay for other expenses such as rent, utilities, and interest on mortgage debt. The money can only be used on expenses paid for within the 24-week period after the origination of the loan. For example, loan dollars cannot be used to pre-pay expenses like rent that would be incurred outside of the 24-week time period of the loan.
How Is the Loan Forgiveness Percentage Determined?
There are two main factors that are taken into consideration when determining the percentage of loan forgiveness that can be achieved with an individual PPP loan.
1. As one of the purposes of these loans is for small businesses to retain their workforce, 100% of their pre-loan workforce (determined as full-time equivalents, or FTE’s) must be employed by December 31st, 2020 for them to achieve full loan forgiveness. A full-time equivalent employee is determined using the definition created under the Affordable Care Act. For example, if a business initially applied for the loan with 20 FTE’s on their payroll, then they must still have 20 or more FTE’s employed when they are ready to apply for 100% loan forgiveness. Alternatively, if that business went from 20 FTE’s down to 16 FTE’s by the end of the loan period, then only 80% of the loan could be forgiven.
Another incentive for small businesses to retain their workforce is the requirement to meet the 75% threshold for payroll expenses within the loan period in order to achieve loan forgiveness. Payroll expenses include gross compensation and employer-paid state and local taxes, and employer paid expenses such as retirement and health insurance. There is a gross compensation cap of $100,000 (on an annualized basis) per employee.
2. Only the loan money that a business actually used during the 24-week loan period for compensation and eligible expenses can be forgiven. For example, if a PPP loan was issued for $500,000 and the business only used $450,000 of that money, then only $450,000 is eligible for forgiveness.
Developing a Plan
Small business owners must determine how to maximize their debt forgiveness in a way that makes economic and business sense. Individual priorities may differ between businesses. For example, one business may prioritize loan forgiveness, while another may have the priority of financial survival (liquidity needs) over a specific time period. No matter what individual goals a business may have, a budget and proper monitoring is essential.
A business should develop a loan forgiveness template that tracks employee and firm-wide expenses over the 24-week period. A baseline budget would apply to a situation where there are no changes to the current operations over the span of the loan. However, with rapidly changing economic conditions and an unpredictable outcome of the COVID-19 pandemic, “what-if” scenarios should also be explored. Explore scenarios in alternate budgets such as delays in reopening, unstable levels of sales and operations with safety restrictions in place, and employee sick-time. Prepare for the possibility of the FTE count to be affected.
With changing circumstances, it is essential to start with an optimal budget but also perform a “budget to actual” on a regular basis, at least weekly. Then, assumptions can be adjusted based on the actual performance of the business. Also, Catanese Group will be monitoring regulatory changes put out by government agencies regarding guidelines for the loan program, which could change over time.
Documentation and Application for Loan Forgiveness
To achieve loan forgiveness, good-faith certification must be achieved through proper documentation and a full-accounting of how the loan money was used during the loan period. It is recommended that the business owner discuss with the lender what will be required upon application for loan forgiveness.
Once the 24-week loan period is over, borrowers must submit the following to their lender:
· – Documentation verifying the employees on the payroll and their pay rates
· – Documentation on expenses paid during the period with proof of payments
· – Any other documentation required that is specifically requested by the lender
There are things that a business owner can do to make the documentation process easier. Setting up a separate chart of accounts is recommended to keep track of all expenses being paid using loan funds. Using a separate bank account can also make reporting easier. The more prepared the business is, the easier it will be to make it through the process of loan forgiveness.
For businesses that have received $2 million dollars or more in a PPP loan, it is understood that they will be audited. The details of this requirement have not been finalized and will be subject to change.
For small businesses who cannot achieve forgiveness, or who may simply want a low-interest loan, payments will be deferred for a minimum of 6 months to a year, and then the loan will have a 2-year maturity at only 1%.
No matter how you choose to take advantage of the PPP Loan program, it is good practice to be fully informed of how your lender administers the loan. You also need to develop accounting practices that will make it easier to track and document how your funding is being used within your organization. This will make the process easier and allow you to receive the full benefits of the program.
Catanese Group is here to serve as a trusted advisor, helping small businesses navigate the complexities and regulations of PPP Loans, develop strategies for achieving loan forgiveness, plan and develop a budget, and fulfill documentation requirements. Please contact us using the information below if you would like updates on the constantly changing rules and regulations.
Please note, again, that the above recommendations are based upon information made available by the SBA We recommend that you confirm if additional rules or regulations have been issued.
Samuel J. Catanese, CPA, is the leading partner of Catanese Group, a certified public accounting and business management firm located in Western Pennsylvania. Mr. Catanese has worked with clients across the country on consulting and planning engagements. For more information, call (814) 255-8400 or email him at firstname.lastname@example.org.
Christine Scholl, MBA is the Marketing Director of Catanese Group, and is a specialist in content marketing, information design, and business consulting. She helps design educational and practical content for clients on a variety of timely topics. For more information, call (814) 255-8400 or email her at email@example.com
Nonprofit Accounting for the Paycheck Protection Program (PPP)
By: Dustin Sherry, CPA
After the CARES Act was passed into law on March 27, 2020, many organizations, including nonprofits, received federally backed funds through the Paycheck Protection Program (PPP) to protect the livelihoods of workers and the survival of their organizations. While these funds are viewed as loans that have the potential to be forgiven if certain criteria are met, nonprofit organizations have some unique circumstances that need to be considered when going through that process.
Though many organizations are primarily concerned with the forgiveness rules and applications, few have considered how these funds should be accounted for. If your nonprofit organization is subject to audit or maintains accounting records in accordance with U.S. Generally Accepted Accounting Principles (GAAP), there are several items to consider.
We have received our PPP funds! Now what?
Initially, the funds received from the program should be recorded as a loan. It is possible that the loan could be forgiven if certain criteria are met, and you will not have to repay the government, but until those criteria are met, you should consider the funds to be a loan.
We are spending the PPP proceeds on allowable expenses, is it still a loan?
Technically, your loan is not forgiven until you have applied for and received forgiveness from the government through the Small Business Administration (SBA). The loan period, as outlined by the PPP, is now 24 weeks. This creates a unique circumstance for many nonprofits as many have a fiscal year that ends on June 30, falling in the middle of the loan period. There are some accounting options you can use to deal with the issue.
For organizations with a fiscal year-end that falls within the 24-week period, the following option could be helpful:
If you are using the funds for allowable costs, you can assume that those costs will be forgiven at a future time. Therefore, you may reduce the loan throughout the 24-week coverage period as you record those allowable costs. As you reduce the loan, you would record grant income. The grant income should be classified as “conditional” until it is eventually forgiven.
For organizations that do not have year-ends that fall within the 24-week period, this option is simpler and preferred:
Wait until you apply for and receive forgiveness and record the entirety of the loan as grant revenue at that time. The grant would be “unconditional” since it has already been forgiven.
What happens if the loan or part of the loan is not forgiven? Will I have interest expenses?
You should record interest expense on the loan only for any amount that is not expected to be forgiven. Since changes have been made to make it easier for these loans to be forgiven, such as the change from the initial 8-week period to a 24-week period, it is unlikely that organizations will have difficulty with forgiveness. This is assuming that employment levels did not change, and all other criteria have been carefully met.
Do we now need to have a compliance audit?
Governmental audit guidelines states that any organization receiving federal assistance totaling greater than $750,000 will require the organization to be subject to a compliance audit. However, the Small Business Administration has clarified that PPP Loans made to nonprofit organizations will not be subject to the compliance audit requirements.
Catanese Group is here to serve as a trusted advisor, helping organizations navigate the complexities and regulations of PPP Loans, develop strategies for achieving loan forgiveness and proper accounting, and fulfill documentation requirements. Please contact us using the information below if you would like further assistance with the process
Dustin P. Sherry, CPA, is Audit Partner at Catanese Group. Mr. Sherry works with nonprofit clients on consulting and compliance engagements. For more information, call (814) 255-8400 or email him at firstname.lastname@example.org.