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ARTICLE · 01 MARCH 2022

An Update Regarding The Paycheck Protection Program

Bailey Cavalieri
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Material Considerations that Should be Evaluated by All Borrowers under the Paycheck Protection Program.

United StatesFinance and Banking
James G. Ryan
James G. Ryan

Material Considerations that Should be Evaluated by All Borrowers under the Paycheck Protection Program

Summary: This week is a very important week for borrowers ("borrower(s)") under the Paycheck Protection Program ("PPP") as the May 14 deadline to return PPP Loan proceeds is quickly approaching and there are still many questions left unanswered. While we expect to receive more guidance on certain of the following subjects this coming week (before May 14), we wanted to share with you what we believe to be the three most material considerations that each borrower under the PPP should be evaluating: (1) potential new rules regarding qualification for a PPP Loan; (2) the IRS guidance to disallow deductions for expenses paid with PPP funds; and (3) the IRS guidance to disallow the Employee Retention Credit to companies that receive PPP loans.

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