On April 14, 2020, the SBA posted an interim final rule stating that partnerships could use the self-employment income of general active partners when calculating payroll costs for the PPP loan amount.
On April 28, 2020, the Department of Treasury posted an interim final rule providing an alternative criteria for seasonal employees to calculate their maximum loan amount. A seasonal employer may alternatively elect to calculate its maximum loan amount as the average total monthly payments for payroll during any consecutive 12-week period between May 1, 2019 and September 15, 2019.
Since PPP loans were approved before this additional guidance, some partnerships and seasonal employers may not have received their maximum loan amounts. The SBA, through this new interim final rule, is allowing lenders to increase loan amounts if these changes were not considered in the original calculations.
These changes cannot be made if your lender has already submitted SBA Form 1502, and these changes cannot be made by the lender after May 22, 2020.
If you have any questions, please contact your Kerkering Barberio team member at (941) 365-4617 or visit our website at https://www.kbgrp.com/resources/covid-19-updates.