PPP Loans – To Keep or Not to Keep

We have increasingly heard questions from members about required certifications for the PPP, what disclosures there will be about PPP participation, and as a result, whether members or clients should take advantage of the safe harbor to return PPP funds which closes on May 14.

In order to qualify for a PPP loan, the applicant had to certify in good faith that “current economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” Treasury has recently issued additional guidance on what determines “uncertainty” and “necessary” which has implications for PPP recipients.

There has also been additional information that all PPP borrowers should expect their acceptance of PPP funding to be disclosed publicly. Senator Marco Rubio, an architect of the PPP, and the Chair of the Senate Small Business Committee and the Treasury have both announced a desire to make lists of all businesses who access the PPP program public record.

The SEC has recently released guidelines that may compel Registered Investment Advisors who receive a PPP loan to disclose that information to their clients on their ADV form.

Armstrong Robinson, AALU/GAMA’s Vice President of Legislative Affairs and Bridget McNamara-Fenesy, M Financial’s President and CEO of M Holdings Securities address all of these issues in this webinar to help you determine whether or not you keep it or return it by the May 14 deadline.

Click here to download slide deck.