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Late last Thursday, the SBA issued its 31-page Interim Final Rule on the Paycheck Protection Program, most of which comprises Q&As for borrowers and lenders. This rule affects payroll cost calculations by (a) explicitly omitting independent contractors and (b) apparently preferring “the last 12 months” of data – rather than calendar 2019 data – for computing average monthly payroll costs. Yet we are hearing anecdotally that some banks are preferring calendar 2019 data when processing PPP loans.

CNPE has done two things to make this a bit easier for you:

  • We abstracted the borrower-related Q&As from the SBA’s Interim Final Rule in a simpler, 8-page version that is much easier to read and understand. You can see it here.
  • We amended our Excel worksheet for computing average monthly payroll costs and your loan amount. The worksheet now has two tabs at the bottom – one using the last 12 months of data (through March 31, 2020) and one using calendar 2019 data. Ask your banker which 12-month period to use.

Don’t forget our template resolution for your board to approve your loan application.