Webinar Date: June 18, 2020
Thank you for joining Texas Public Charter Schools Association and two of vcfo’s financial experts to discuss all things PPP loans. Jennifer Lennarz and Regina Walters, Consulting CFOs at vcfo, will provide information on understanding the program, the impact of the newest legislation, and navigating loan forgiveness.
Webinar Follow Up Questions
Below are our responses to the questions asked during the webinar:
Nonprofit charter schools can apply if applicant is a private non-profit organization that is a non-governmental agency or entity that currently has an effective ruling letter from the IRS granting tax exemption under sections 501(c),(d), or (e) of the Internal Revenue Code of 1954, or satisfactory evidence from the State that the non-revenue producing organization or entity is a non-profit one organized or doing business under State law, or a faith-based organization. Other SBA eligibility requirements need to be reviewed as well to determine if your charter school can apply for an EIDL.
We recommend that you discuss this single case with your Lender to confirm that use of the EZ form will be acceptable. Please refer to guidance and instructions related to this case regarding what may need to be provided related to an employee who is voluntarily refusing re-employment or resumption of work hours.
Per the Interim Final Rule on Revisions to First Interim Final Rule posted on June 11, 2020 states: to receive full loan forgiveness, a borrower must use at least 60 percent of the PPP loan for payroll costs, and not more than 40 percent of the loan forgiveness amount may be attributable to nonpayroll costs. This interim final rule automatically allows for your 60% requirement.
Per the Interim Final Rule on Paycheck Protection Program posted on April 2, 2020 states: Federal employment taxes imposed or withheld, including the employee’s and employer’s share of FICA (Federal Insurance Contributions Act) and Railroad Retirement Act taxes, is expressly excluded from payroll costs.
We recommend that you run several scenarios to estimate which loan forgiveness model may result in the highest amount of loan forgiveness. For example, if eligible to do so, compare loan forgiveness over an 8 week versus 24 week period. It is possible (not not always a certainty) that having a longer covered period to use the PPP funds for eligible purposes may offset FTE and/or Salary reductions realized. Additionally, determine if alternative seasonal employee periods may apply with higher results. Finally, determine if any reductions can be addressed by salary and/or FTE reductions by the applicable safe harbor dates. Please contact us further if you would like to discuss modeling of these types of scenarios.
Per the Interim Final Rule on Revisions to First Interim Final Rule posted on June 11, 2020 states: to receive full loan forgiveness, a borrower must use at least 60 percent of the PPP loan for payroll costs, and not more than 40 percent of the loan forgiveness amount may be attributable to nonpayroll costs.
First step is to determine if which application is needed to proceed with loan forgiveness. Are you able to use the EZ application or regular application. Once it’s determine, download the proper loan forgiveness application on the SBA website, typically your bank will have this as well on line. Start gathering the required documentation immediately and calculating your loan forgiveness amounts throughout the measurement period. During this process reach out to your lender and see what facilitation they are providing for the submission of the documents. The banks will be able to advise if they will require paper copies or if a portal will be used for the forgiveness process.
When an employee of the borrower is fired for cause, voluntarily resigns, or voluntarily requests a reduced schedule during the covered period or the alternative payroll covered period (FTE reduction event), the borrower may count such employee at the same full-time equivalency level before the FTE reduction event when calculating the section FTE employee reduction penalty.
For additional resources regarding the COVID-19 crisis, please visit our resources page.
Updated as of July 2, 2020
Information presented is subject to further change as additional guidance may be released by the SBA, the US Treasury Department, the Internal Revenue Service or other governmental authorities. Information presented does not include all scenarios or situations that may apply. Information included in this presentation does not represent legal advice. vcfo recommends further discussion with legal counsel regarding legal questions related to the information presented. Please contact us should you have further questions.
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