(Recorded Webinar) Paycheck Protection Program Flexibility Act
To address some of the specific questions and areas of interest that arose from participants on our 6/11/20 webinar regarding the PPP Flexibility Act, as well as SBA guidance that was issued on June 12, our presenting attorneys recorded an updated version of the webinar for the on-demand offering. This updated and tailored version includes specific examples in those areas of interest and is being made available to all who attended.
On June 5, 2020, the rules of the Paycheck Protection Program (“PPP”) were again changed, this time through the PPP Flexibility Act. As its name suggests, the new law was enacted primarily to make use of PPP funds more flexible and to expand the period during which the funds could be used for expenses that will be eligible for loan forgiveness.
Among other things, the Flexibility Act:
- Expands the period during which PPP loan funds may be used for payroll and nonpayroll costs.
- Expands the “covered period” during which payroll and nonpayroll costs eligible for forgiveness may be incurred or paid.
- Reduces of the “75 percent payroll costs” threshold applicable to loan forgiveness to a 60-percent threshold, and also enhances the negative consequences of not meeting the new threshold.
- Extends the period during which employers may return FTE and salary amounts to their original levels to avoid loan forgiveness penalties.
- Creates a new safe harbor for FTE reductions that permits employers to avoid FTE reduction penalties on loan forgiveness amounts if they are able to show that their business has not returned to pre-February 15, 2020 levels due to compliance with certain federal agency social distancing and sanitization guidelines.
Some of these flexibilities will aid borrowers, while others may be more trouble than they are worth – or even lead to unanticipated negative impacts on overall loan forgiveness. As each borrower’s circumstance differ, strategic decisions must be made based on the best information currently available.
This webinar will offer a brief recap of Loan Forgiveness rules as they stood prior to this statutory change, followed by a detailed discussion of the changes.
- CEOs/Program Directors
- In-house legal counsel
- CFOs and Fiscal Staff
- Compliance Officers and Staff
- Outside counsel
After this webinar, you will be able to:
- Understand the PPP Loan Forgiveness framework, including practical considerations relating to funds use, deconflicting funding streams, and prudent approaches to documentation.
- Understand the changes made to the PPP Loan Forgiveness framework by the PPP Flexibility Act, including impacts to practical considerations of PPP funds use and documentation.
- Evaluate pros and cons of electing to use the flexibilities offered by the PPP Flexibility Act or “stay the course” under the pre-existing framework.
A partner with the firm, Michael practices in the Federal Grants and Health Law groups, and has over three decades of experience advising community-based organizations on a broad range of legal matters. Specifically, he offers guidance to Federally Qualified Health Centers, other federal grantees, and several professional and trade associations on the 340B drug discount program, tax exemption, grants law, and fraud matters. [Full Bio]
A Senior Associate in the firm’s Federal Grants and Health Law practice groups, Joe advises clients on matters of federal grant law, government contract law, and health care law. Prior to joining the firm, Joe served as program counsel with the United States Navy Office of General Counsel at the Naval Sea Systems Command where he provided government contract law and federal fiscal law advice to program leadership and contracting personnel in critical programs. In addition, he also represented the Navy as lead trial attorney on bid protests before the U.S. Government Accountability Office (GAO). [Full Bio]
A Partner with the firm in the Federal Grants and Health Law practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law. Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]
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- 1.25 Certificate of Attendance
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