SBA "Payroll Protection Plan"

Last night, April 2 around 9 PM the Small Business Administration (SBA) released 31 pages of the so called "Interim Final Rules" regarding the applicability, availability and processing of the "Payroll Protection Program" (PPP).

Is the PPP “first-come, first-served?”

Yes.

However, we were told by some banks that the rules came in too late to allow applications to start today on April 3, 2020 (Which was the initial start date).

We are tracking which banks known to us are "ready for business" and will update this via twitter @BridgehouseUS - make sure you subscribe to our twitter feed.

"time is of the essence"

The answer "How much?" is detailed below.BridgehouseLaw is reviewing the details and will provide a more detailed update tomorrow. Most important: does your business quality for any relief and how to get it?

How do I calculate the maximum amount I can borrow?

The following methodology, which is one of the methodologies contained in the Act, will be most useful for many applicants.

• Step 1: Aggregate payroll costs (defined in detail below in from the last twelve months for employees whose principal place of residence is the United States.

• Step 2: Subtract any compensation paid to an employee in excess of an annual salary of $100,000 and/or any amounts paid to an independent contractor or sole proprietor in excess of $100,000 per year.

• Step 3: Calculate average monthly payroll costs (divide the amount from Step 2 by 12).

• Step 4: Multiply the average monthly payroll costs from Step 3 by 2.5.

• Step 5: Add the outstanding amount of an Economic Injury Disaster Loan (EIDL) made between January 31, 2020 and April 3, 2020, less the amount of any “advance” under an EIDL COVID-19 loan (because it does not have to be repaid)

Reinhard von Hennigs, Attorney (NC)