Key Considerations For PPP Documentation (Updated 11/5/2020)

Borrowers under the Small Business Administration's ("SBA") Paycheck Protection Program ("PPP") are required to either maintain or submit to lenders and the SBA certain documentation associated with their application for and their use of PPP loan proceeds. In addition, certain documentation is required for an appeal. Because the SBA has provided limited specific guidance to inform borrowers' documentation efforts, we are providing a general summary of considerations a borrower might keep in mind as it aims to comply with the documentation requirements associated with application for, the receipt of, and the use of PPP loan proceeds (for forgiveness or otherwise), and an appeal of an unfavorable forgiveness decision.