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ARTICLE · 12 NOVEMBER 2020

SBA Issues New Rules For Appeals Of Disputed PPP Audits

Burr & Forman LLP
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PPP loans under the CARES Act are being audited by the SBA. All PPP loans over $2 million will be audited, and many more under $2 million will be audited as well.

United StatesAccounting and Audit
Erik P. Doerring
Erik P. Doerring

PPP loans under the CARES Act are being audited by the SBA.  All PPP loans over $2 million will be audited, and many more under $2 million will be audited as well.  Applying for forgiveness of a PPP loan increases the likelihood of an audit.

An audit or "review" by SBA of a borrower and its PPP loan can result in an SBA determination that the borrower (1) was ineligible for a PPP loan; (2) was ineligible for the PPP loan amount received or used the PPP loan proceeds for unauthorized uses; (3) is ineligible for PPP loan forgiveness in the amount determined by the lender in its full or partial approval decision issued to SBA (except for the deduction of any Economic Injury Disaster Loan advance in accordance with section 1110(e)(6) of the CARES Act); and/or (4) is ineligible for PPP loan forgiveness in any amount when the lender has issued a full denial decision to SBA (each and collectively a "SBA Loan Review Decision").

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