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ARTICLE · 05 NOVEMBER 2020

The SBA Releases Two PPP Liquidity Questionnaires

Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
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As you may recall from a previous bulletin, the SBA has stated that it will audit all PPP borrowers, who together with a borrower's "Affiliates" (as determined pursuant to SBA regulations)...

United StatesFinance and Banking
Matthew P. Delguyd
Matthew P. Delguyd
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As you may recall from a previous bulletin, the SBA has stated that it will audit all PPP borrowers, who together with a borrower's "Affiliates" (as determined pursuant to SBA regulations), received PPP loans in excess of two million dollars. Part of the audit is to determine whether a borrower had the "ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to their business".

Many businesses have been asking whether the SBA has clarified or set any bright line rules regarding liquidity. The answer remains that there are no bright line rules. However, this week the SBA released two liquidity questionnaires (one for for-profit PPP borrowers and one for non-profit PPP borrowers), which will give businesses a flavor of the sort of facts the SBA will be reviewing with regard to its liquidity analysis. Most of the questions involve a simple yes or no response, but there are a few

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