A key aspect of the CARES Act relief package is the now
well-known Paycheck Protection Program (PPP) being administered by
the Small Business Administration (SBA), which provides for loans
of up to $10 million per small business applicant to be used on
payroll, benefits, rent and other authorized costs from February
15, 2020, through June 30, 2020. As many are aware, the first $349
billion has already been allocated and we understand Congress is
voting today (April 23, 2020) to (hopefully) approve substantial
additional funds. The PPP loan application requires, among other
things, that applicants certify that the current "economic
uncertainty makes this loan request necessary to support the
ongoing operations of the Applicant." While this
principles-based certification is consistent with the broad
objectives of the PPP, it does not contain any quantitative metrics
(such as, a specific percentage drop in expected revenue) or other
objective criteria on which boards can
