May 7, 2020
The SBA issued revised guidance via FAQ #43 extending the “safe harbor” deadline from May 7th until May 14th relating to repayment of any PPP loan already funded. All borrowers were required to reevaluate whether their loan certification was valid based on revised (but unclear) guidance requiring all borrowers to consider other sources of liquidity to fund their operations.
The updated FAQ also states that additional guidance would be issued before May 14th to assist borrowers with their decision as to whether repayment is appropriate or not. Revised guidance has also been issued indicating that if the loan is repaid by the safe harbor date (now May 14th) it will be deemed that the loan never existed for purposes of qualifying for an Employee Retention Credit under section 2301 of the CARES Act. Click here for more information and to monitor developments in PPP guidance moving forward.
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