Updates on PPP Safe Harbor Rules and NADA Resources

Dear WANADA Members,

Late last week, the Small Business Administration issued an interim final rule covering the Paycheck Protection Program's safe harbor rule. That provision reaffirms what we reported last week, which is that under Treasury guidelines, any PPP loan recipient who does not need the funds to "support the ongoing operations of the Applicant" may return the funds by May 14 and be held harmless.

The guidance also restates that returning the funds by May 14 would make a business eligible once again for other relief options offered by the CARES Act, including the Employee Retention Tax Credit. 

In addition, NADA has revised their thorough guide to the federal emergency leave provisions created by the Families First Coronavirus Response Act, which went into effect at the beginning of April. The NADA guide has been updated to reflect some additional Department of Labor guidance regarding the mandate, which includes further clarification on employee eligibility for the program. 

Please let me or Joe Koch ( jk@wanada.org) know if you have any questions. And, as always, please continue to use WANADA's COVID-19 Information Library as a resource during this crisis. 

Sincerely,
  
John O'Donnell
WANADA President and CEO