Last night, May 13, 2020, the SBA issued additional guidance through an Interim Final Rule allowing banks to make an additional PPP loan disbursement to partnerships that did not include partner compensation in their original PPP loan application. The guidance stated that your lender may electronically submit a request through SBA’s E-Tran Servicing site to increase the PPP loan amount to include appropriate partner compensation, even if the loan has been fully disbursed, provided that the lender’s first SBA Form 1502 Report to the SBA on the PPP loan has not been submitted. Please note again, that after your lender has submitted the initial SBA Form 1502 Report on the PPP loan, or after the date the first SBA Form 1502 was required to be submitted to SBA, the loan cannot be increased.
From the SBA guidance, it seems that your lender may have until May 22, 2020, to file the SBA Form 1502. Therefore, if you are a partnership that received PPP loan funding but did not include partner compensation, you should immediately contact your banker and request additional PPP loan funding for the originally excluded partner compensation.
If you need advice on how to proceed with PPP loan applications and calculations for partnerships, our team is available to help. To learn more, visit the COVID-19 Business Services section of our website or contact us. Also, be sure to subscribe here to get our news and alerts as they are released as we are committed to keeping you updated on how to navigate financial challenges associated with the COVID-19 pandemic.
Bert Mills, CPA, is the Managing Partner at Moore Colson. In his role, Bert sets the vision and mission of the Firm and works closely with the Firm’s leadership to drive and implement strategies.
Chris Arnone, CPA, is a Partner and Business Assurance Practice Leader at Moore Colson. Chris has over 20 years of experience providing audit, accounting and consulting services for companies in the transportation, manufacturing, distribution, staffing, private equity and venture capital industries.
Andy Starnes, CPA, is a Partner and Tax Services Practice Leader Moore Colson. Andy’s specialties include corporate tax compliance and planning, business consulting and multi-generational planning with a focus on the construction, professional services and staffing industries.
Steven Murphy, CPA, is a Partner in Moore Colson’s Tax Services Practice. He is the Practice Leader for the Transportation Industry and also serves as the Tax Practice Leader for the Retail Industry. Steven has over 20 years of experience leading tax engagements and implementing tax strategies.
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