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Alan Gassman, Brandon Ketron and Kevin CameronPPP Loan Update5.24.200:03Hi, this is Alan Gassman, and I'm here with Brandon Ketron and Kevin Cameron, and we're going to talk about the new PPP loan, Interim Regulations.?We welcome you to this presentation.?I'm in my secret quarantined bunker.?Brandon's in his secret quarantine bunker.?Kevin's at home because the power in his in his office just ran out, so we just barely got home in time.0:27We're gonna go a little bit more than 30 minutes, we're going to answer a lot of the questions that we've been getting, although in 30 minutes, we can't answer all of them.?Obviously, this is a dress rehearsal.0:38So any suggestions you have any criticisms will really be appreciated.?We're continuing to work towards this Tuesday 11, 30 presentation.?We'll be doing pretty much the same thing in 60 minutes, but then answering a lot of questions.?for 30 minutes.?We appreciate all the questions you've been sending us, Some free webinars coming up, that anyone here is welcome to attend.?I'm going to talk about what clients need to know about bankruptcy on Thursday the 28th.?And then on Saturday, I'm going to talk about creditor, protection or physicians.?And you can see we have a lot of other topics there.?Those of you who are CPAs and tax lawyers, please join me at the tober 29 to 30 Notre Dame Tax Institute, which will be virtual this year.?This is the first virtual Notre Dame Tax Institute.1:26It's the 46th year for the, For the Institute, if you've never attended, and you'd like to attend virtually, The topics are really, really good, and there's a lot of different tracks to choose from you.?So every hour you can, you can go to one presentation or the other.1:43I have been collecting Mark Twain quotes recently.?I like the one at the top here, be careful about reading health books, you may die of a misprint, I thought that was pretty good.?And then the fourth one, I was gratified to be able to answer promptly, and I did.?I said, I didn't know.2:00And then the third one, This is good for quarantines, Let us make a special effort to stop communicating with each other, so that we can have some conversation, OK??So many people just don't stop talking.2:13Speaking of talking, page nine, for those of you who are somewhat new to these rules, Just a quick review.2:21We're talking about the Sorry about that.?We're talking about the payroll protection program.2:26And first of all, your borrowing was based upon 2.5 times an annualized payroll cost.2:35And if you have an S corp or a C corporation, then that was based upon all your payroll, your state payroll taxes, health insurance, and your retirement plan costs for a whole year.?You multiply divide that by 12.2:50You multiply that by 2.5, and that's your loan amount, and then the big question that you're all here for is, what will be forgiven?3:00I have eight weeks, 56 days, after I get the money more or less, what will be forgiven??And, these are, those same payroll costs, the wages, but not more than $100,000 a year per employee, the health insurance, the retirement plan.3:18Then, there is interest on Mortgages.3:22There are rent, payments, and there are utilities and the amount that you have forgiven will be reduced by up to $10000 of your ideal grant.?If you got any idea all grants, so in the yellow here, and what we're going to concentrate on today, is what are these expenses during that 56 days.3:45And for some people, there'll be two separate, 56 day periods, can be spent or incurred to get maximum forgiveness.3:56Now, on the right column, we show you all the things that you are allowed to spend the money on.?So if you want to spend the money on Principle or you want to spend the money on payroll exceeding $100,000 for somebody, you, can, you're just not going to get the forgiveness on the excess amount.?And that's where a lot of confusion comes in.4:20Another question is, can you use this money for anything on earth after June 30??And the way we read the rules right now, if you wait till June 30, or after June 30, yeah, you can buy a boat or a car.?We don't recommend it necessarily won't look very good, but it looks like you'll be able to.4:39Now, these rules are significantly different.4:43If you file as a Schedule C, independent contractor, or proprietor as we call it, and you may operate under an LLC that's disregarded for income tax purposes.?And therefore, you file under these independent contractor Rules.5:00And under these rules, they simply go to your Schedule C, lines 31 on your form 10, 40, which is the net profit amount.5:11You fill out your Schedule C, you get to that net profit amount, you if it's over 100,000, then you just use 100,000, if it's under 100,000, you divide it by 12, multiply it by 2.5, and that is what your loan is.5:29Then, your repayment is basically that same Schedule C, Line 31 amount, divided by 52, and then multiplied by eight.?So, if you're at 100,000 or more, you borrowed 20,008 33, and you have automatic forgiveness of 15,385.5:52So, if you are at $50,000 of net income, then you're going to be at $10000, 416, approximately is your loan and your forgiveness is about half of 15,385 plus, You will have your interest, rent, and utility expenses, which we'll talk about later.6:15There's an article on the Forbes blog, or a couple of good ones on PPP Loans for independent contractors.6:20If you have questions with that, let me know, page 11.6:27We had the forgiven this application become available about a week ago and the instructions to it.6:34And it was not a pretty sight.6:38There are some difficult to follow instructions, some instructions that don't make sense, or that we think are not correct.6:46But, for the most part, the application and the instructions to the application are liveable.6:55And they are fairly stable, fairly stable.?You probably talk about your marriage that way.?Sometimes, But these rules, we felt that at the end of reviewing them, and ..., trying to understand them, that we were at least 80% of the way there, as far as understanding what the final PPP rules are, and will be.7:20And then, in my opinion, that went from 80% to 90% Friday night, and all day Saturday, as Brandon and Kevin and I looked through, the new interim regulations.7:34So, let me just go through some of these rules.?We're gonna hit every rule, at least twice.?It's easier to learn that way, and it kinda let you know where we are.7:45So here on page 11, number one, act quickly.7:51As soon as your eight weeks is over, fill out the application.?Make sure it's right.?Consult with a with a reputable CPA or tax lawyer.8:01Get it to the lender because you want it there before the rules change For the worse, there may be some loopholes here that we're going to be able to use that will eventually be closed, but they may not be closed before you file your application forgiveness.8:18Number two, there is now an alternate eight week period for payroll.8:23We'll be discussing that, but if your payroll period begins on the first of the month, then you got your PPP payment on the 20th of the month.8:33Then you can wait 10 days to start counting payroll, and Kevin's going to tell us how that works.8:39Number three, the loan has to have been necessary to support the ongoing functioning of your business to keep things and people employed.8:50If it was not necessary.?Because you have a million dollars in your checking account, and it only cost you $20,000 a year to run your business, then you shouldn't have got below.?And you could have issues, so make sure you talk to somebody about the necessity requirement.9:04It was not eliminated by the application, just because the SBA is not going to necessarily review you, because your loan was under $2 million.9:16Doesn't mean that you might not have a friend or spouse or employee blow a whistle on you to get a reward, and then you could be facing the necessity question with the Department of Justice, which would not be a pretty sight number for your pension or retirement contributions.?If you put the money in during the eight weeks, you may be able to count the entire amount you put in, not just annualized.9:43Number five, you may be able to put in rent, that you have deferred pain.?So, if you paid, if you haven't paid rent and a few months, and all of a sudden you pay it late, during the eight weeks, that may be part of your forgiveness.9:58Number six, if you re hire your employees or have the right number of employees on June 30 and presumably a little bit after that, but at least on June 30, then you can save the reduction of forgiveness.?That will occur if your workforce is much smaller during the eight weeks than it was before.10:18Number seven, there's a new rounding rule.10:21Where, if you're measuring your workforce to see if it's been reduced, employees under 20 hours can be measured as exactly 20 on average, if full-time, It is exactly 40 on average.10:33Brandon and Kevin, I'll tell you about that all.10:36Also, non payroll costs can be paid after the eight weeks, as long as they're paid in what I call the normal course of business.10:47The 75% tasks where you're supposed to spend 75% of your forgiving in surmount on payroll is not a class.?You don't have to spend 75% of the entire loan to get forgiveness.?If you just spend $10 on payroll, you'll have $10 of forgiveness will explain what the 75% test is.11:08Rent and mortgages include rental of non real estate and LinkedIn, and loans secured by assets other than real estate as collateral.?Number 11, when you go to that reduced employee fraction, you may not be able to count the owner of the business in the numerator or denominator hashtag 12, you have got to run the numbers.?What Kevin has shown us, looking at different situations is you could say, Yeah, rule of thumb, the one seems to be going that way or that way until you really run the numbers.?You don't know what the cost and benefit is to bringing people back, pain them more, or less, or otherwise.?So I've got a couple of slides here on necessities.?I don't think I need to go over them.?I mentioned them, there is a Forbes article, if you, search, for shorts gassman excessively.?Come up A little bit of an echo there if you hear an echo, Brandon?12:10Nominate: Yeah, Echo, Echo echo, echo, echo echo Echo.12:20Got it, maybe.?Maybe somebody's calling it.?So we have here.?Is what you speak?12:33And Hopefully that those can be read and I've covered them So here I have the May 22nd article the article about these new rules And Kevin, do you want to walk us through the first couple of pages?12:50Sure, Alan.12:51I actually a couple of pages of which IFR the I've got slide 19 up, Which OK, from my.?I don't know, because the connection.?Sorry about that.?OK, so Brendan, why don't you take this, and then we'll put Kevin, Yeah.?one.?Of the things you know, we learned here, and then Alan mentioned it beforehand is time is really of the essence here, were towards the end of that eight week period For a lot of the borrowers that got the loan at the beginning, of the, you know, the cares Act when it was passed, that we're able to get that term approved and out to them.?So they're really near and six weeks here.?So we need to understand these rules and be prepared to advise our clients and, and you know.13:39Other people as to how these are going to apply.?And these regulations and interim final rules that were passed on Friday really help us, you know, work towards that goal.13:49And, you know, one of the things they did is they are they defined, they gave us some more definitions on the payroll costs.?We had the exact language from the footnote.13:57On those payroll costs, this really mimics the statute but again, it's including everything as far as tips.14:07Sick leave, family medical leave, severance pay, group health care coverage, insurance premiums, retirement contributions.?So all that's going to be included as a payroll cost that you can take into account.14:20Now, there is also some stuff on tips here that we have at the bottom.14:23You know, one of the things for a lot of restaurants and a lot of the restaurants have applied for and received this loans, is, you may not think that you can include the tips to your employees as part of payroll costs.?But the statute And this guidance provides that.14:35You can so, you need to keep records of those tips.?If you don't have records, this is the regulations.?So, you can make a good faith reasonable estimates of the amount of tips that have been received and go ahead and include that as the payroll cost.?So, I guess you could take 15% of gross cells or something similar to that to, to get your reasonable estimate if you don't have records of those.14:55They also refer to this cash tips or the equivalent.?So we're not really sure what the equivalent is, but as Alan mentioned here, that might include gift cards or some sort of other value given to your employees.15:05If you had someone come in and and give a nice, you know, gift card, or throw a party for your employees, or something that might be able to count as payroll costs, would be thinking about those additional items.15:17Do you want to touch a little bit here on the retirement plans, and how they have defined that, or the lack of defining it?15:23Right, So for many borrowers, this is my apologize, for the echo, not sure what happened, but for many borrowers, this is going to be the way to get full forgiveness.15:37You can fund your 2019 or your 2020 pension contribution during the eight week period, and if you do that, we believe that that full amount will be forgiven.15:52There's nothing in any of the regulations or any of the FAQs that indicates that this would have to be prorated to 16 of the cost for this year.16:04That may end up being what the rule is.?But for now, even if you don't have a 401 K or a pension plan, there is time to put one in.16:15If you have a week or a week and a half before the end of year 56 day, you do have time to form a plan and to go ahead and get it funded.16:25And what some small businesses are going to do is they're gonna get the plan, They're gonna fund it and then if they have issues, they're going to borrow the money right back out because under the new cares act.16:37If the employer allows, you can borrow 100% of the vested value of your pension plan, up to $100,000 for a married couple, who are both in the business and both have plan balances.?That would be $200,000.?Or under the cares Act, or you could take money out of it.?You could be putting money into a pension plan tax deductible while you're taking money out of an IRA, so you can decide later what to do.17:06There's also less complicated pension plans, which do not give you a tax deduction.17:13These are commonly called a Top Hat plan or a Rabbi Trust, if you want more information on these, just put top hat in the reline.?I'll give them to you, but I think there will be people getting full forgiven us that they otherwise would not have gotten simply by putting away for retirement.?And I think the SBA understands that it's important to put away for retirement, and it's certainly important to the financial services community, to have people investing.17:37So I believe that that's the public policy reason that they are allowing that to occur.17:46Kevin, the next section is interest, rent, and utilities.?Do you want to cover all of that, or any part of it??I know you don't have the skirt.17:55Yeah, well, that's OK.?I'll cover as much of it as you want.?You can cut me off, whenever you'd like, Interest Breton utilities, you've gotten some really good.?I think, better guidance on what the timing is Particularly on that.?Because it certainly sounds like, from the guidance we received on Friday, that if I pay rent within that eight week period And the eight week period is that 50 day period.?Starting on the day we receive our loan proceeds.18:24The alternate payroll covered period as a whole nother 15 day period.18:29So, keep that in mind, don't don't get the 256 day period accidentally confused, but going back to, and for rent and utility on interests.18:41We know that we can pay interest payment.?Not Principal payments, just interest payments during that 15 day period, but it certainly sounds like now.?we can include payment that may have been for a prior month payment or we were in arrears, that interest payment might be able to be included.19:01It also sounds like we can pay interests outside the 50 day period at the end of the cycle.19:07It's a, we have a loan payment that is do 10 days after the date of the 56 day period, but as long as it was incurred during that period.?And we pay it before the next billing cycle, I think we're OK.?The interesting thing on that might be that, some loans now are structured with, like, quarterly interest payments, or principal payments, but not always monthly.19:35So, keep in mind that this next billing date could be an extended period of time that we'll have to pay attention to encourage anybody who has any arrangement like that to maybe go ahead and make the payment a lot sooner than that.?So, you can turn in the the forgiveness application with your backup data, with respect to rent and lease payment.19:57Not too much more guidance there, but we do know that we were following the regular definition of rental and it is commercial property rental as well as personal property rental, copier, leases, car leakers correctly.?Things of that nature.20:14We also believe at this point that if you have costs that are on those rental payments such as sales tax, even common area charges, they likely are included in the total rental cost because they are part of the total rent to keep that in mind.?If you are behind on your rent, you pay my rent in arrears within your 52 day period.?You might also be OK with that now based on the current guidance we have.20:44I don't believe we can pre pay rent.?I think that's still probably not going to be included.20:49Alan, I think one important thing to mention it, if you read the Interim Final Rule on the loan forgiveness.20:58They mentioned in there that we, they realize that the timing issue may work to the benefit of a borrower, specifically mentioned that they're not, they essentially say they're not worried about that because, ultimately, the, the non payroll costs are going to be limited to that 25% of the forgiveness.?The roundabout way of saying, your, your non payroll cost can't exceed one third of your payroll costs.21:27So I think the FBA, it must be thinking, we really don't care too much about what borrowers throw in there, as long as it's fairly legitimate and qualified, a qualified, non payroll cost expense.21:40But I think we've gotten off the hook a little bit there.?And we'll talk maybe a little later on today about what, how the banks are going to review these.21:48I think that's also some important guidance that we've looked at in the most recent IFR, with respect to utilities.21:56I think we're still kind of in the gray area, on transportation.?They just didn't give us any guidance on that.?I'm still leaning towards the fact that transportation costs associated with the transportation of a utility, natural gas, Internet line, something of those, that nature.?I think that's what transportation.22:17As far utilities, utilities go along with any other item paid during the day period, or incurred, and paid during a period, or incurred and paid billing cycles.?We have multiple timeframes to look at, would be expensive.22:36Very good.?So it looks like a lot of borrowers who have not gotten their loan yet will be well advised to not pay their rent, not pay the interest, not pay their utilities, wait, then assuming that the landlord doesn't get all upset and sue them.22:52And assuming that the power company doesn't cut their power off, pay those things during the eight week period.?And they'll get forgiveness for those items, assuming that they have enough payroll costs.?And one of the best ways to get enough payroll costs is to fund a pension plan during the eight weeks, as well.23:10Indeed.?And important to point out here, and Mark, I'm a, I'm a CPA, I'm a business owner, I'm also a landlord, and in March, I was contacted by a few of our tenants.?Can I get some ready to renovate, man??Can I put off paying my rent per month, kind of pay half, you know??So in those circumstances, those people who were able to secure some sort of rental deferral might want to rethink that and go back to the landlord and say, hey, I've got the TPP loan money now.?Can I pay the rent??But, oh, by the way, can we maybe renegotiate for July or August?23:49Is that the profitability?23:53Very good.23:54OK, so then we, I mentioned the 75% task, Kevin mentioned it, This is an SBA requirement.24:02We don't know if it really is going to be something that will hold up in court in the long run, because it was not in the cares Act, But the SBA says that you are going to be able to spend 75% of your forgiven us from the payroll.24:19So you can't have more than 25% of your forgiven us come from elsewhere.24:24So, for example, if your loan was $100,000 and you only had 70,000 payroll, health insurance and retirement plan costs, which is what we call the payroll costs, then, if you had 30,000 other expenses, interest, rates, and utility, you would not be able to have the the forgiveness for that other 30.?It would only be based upon 23,333, which is 25% dollars.24:55So, that's just the way that works, and that was confirmed on the application and confirmed in these interim regulations.25:05Kevin, do you want to talk about the timing of the payroll and the alternate alternative, payroll covered period?25:13Certainly.25:15I think this was this was just a move by the SBA I think to lessen the burden of recordkeeping on business owners or borrowers.25:27Because the original 15 day period meant that virtually every bar would have to prorate payroll for that 56 day period.?SBA recognized that, that's probably a little bit of a burden, quite frankly, people.25:41Many people probably do it all so they said, if you're a biweekly or more frequent payroll payer, you can elect the alternate payroll covered period, a complicated thing, because it creates 258 period, but it definitely makes your life easier For tracking payroll.?I actually ran a calculation with a client on Friday, both with and without it, and it took about four hours for the client to compile that prorated payroll data.?For the beginning and end of their eight week period, we projected out the final period.?It took about 15 minutes to use payroll summary report from their payroll service for the exact, for pay period or biweekly payer.26:29So, it really is an administrative convenience for the, the employer that the borrower and how it works.?Quite simple.?You just pick the first payroll day, starting after your loan funding day, and that becomes the start of your eight week period for that, for measuring your payroll cost, and it is measured for measuring all payroll cost everybody's, so, keep that in mind.26:56That means your retirement plan contributions, your health insurance, your state and local taxes all have to be measured on that day period, Not your regular, 50, 6 day period.?I will point out, Allan, that decide that being a convenient.27:11it might behoove some business owners to critique the two period if they had a change in their payroll within that period.?That might've insignificant example might be, if you had some type of accrued or permissions or bonuses or some type of accrued pay, that would have fallen in the normal day covered period, but not in the alternate by region of preparation.27:40So keep that in mind that you still might want to look at your payroll, maybe run a payroll summary for the icon stub period, the beginning and end of the 50 day period, and just peruse them and keep your total gross.?Payroll was about the same as it normally runs.?If it is, then, you might be better off using alternate payroll period.28:02Yeah.?Very good.28:03And that's something where your spreadsheet comes in really handy to just see the numbers both ways, OK, now, bonuses in Hazard Pay, and furlough expense can be counted as payroll expenses during that 56 day period.28:19So, a lot of clients have come to me and said, can I pay my employees more during the period??They've been great.?Can I give them an advance on their bonus??And the answer is as long as you're giving them the money and they don't have to give it back, they don't have a long term obligation.28:33You're just being nice.?Maybe they recognize, they'll get us a smaller bonus later in the year.?This is a great time to ask employees to work overtime and earn extra money.28:43It's a great time to put your family at work.?There's nothing in this law that says you can't hire new people.?If you had a spouse in the business who's been underpay, there's nothing wrong with increasing that spouse to what they are worth.?Maybe not what they think they're worth.28:57That may be higher, too high, but but you can increase them to what they are worth.?Branden, what the heck did they do to corporate shareholders??That was way out of line, I thought.29:10Yeah, one of the new rules added here as a result of these regulations is that your owner compensation for your own or employees and we think this applies to shareholders of S corporations and C corporations.?We think it applies to self-employed individuals partners because they civically mentioned that this applies to all businesses.29:30But the limitation is that your owner compensation cannot exceed 16 of what you paid yourself in 20 19.?So if you're a sole proprietor or partner, you're looking at your self employment income, your net self employment income, and you can only get a NaN of that amount toward your own or compensation.29:48If you're an S corporation shareholder and you happen to pay yourself a really low salary to do some aggressive tax planning, you're going to be limited to 16 of what you paid yourself last year.?So, there's a lot of people that can be penalized as a result of this.?Another thing that was to be concerned about is businesses that were written in business for a short period of time of 2019.?There's no mention that they would have to maybe only use like a monthly average to compute this amount.?They just say, it's eight fifty seconds in 20 19.?So, if you had one month, the business in 2019, really low income, it might be limited.?And, this, hopefully, they'll come up with future guidance.?That would correct that issue because it doesn't seem fair or, you know, by the intent of the statute.?But as of right now, that's the current rules.30:31Now, when you're looking at this for your partnerships and your self employment income earners, for them, you are looking at their net income from self employment.?But, you get to increase that if they've taken a 179 deduction, if they have unreimbursed partnership expenses, if they have depletion from oil and gas properties.?So those accelerated depreciation methods, you can add back into their income.?So you're really looking at their true cashflow or more of an accounting type income.30:59You're not going to be penalized if you had $100,000 of income in 20 19, took a, you know, $80,000, 179 deduction for a new piece of equipment you purchased.31:09And only had 20,000, You can count the 100,000.31:12As a result of that, you've taken away that 1 79.31:15The other tricky part is here.?They said you have to multiply this by 92.35% for partnerships and for sole proprietors.?And a lot of people were or anywhere in the world is that percentage come from.?But really what that is, is that it's essentially a reduction for the employer, shared payroll taxes.?That would typically apply.?So it's more akin to gross wages being paid out, because we know we can take into account gross wages, but not the employer's share of payroll taxes, which is 7.65%.?So this is where they came up, with that 92.35%, and that's strictly follows, the Schedule SE to the form 1040.?So that's going to be that net number that you're looking at when you're applying this limitation.31:58Now, we're really running out of time here and I keep echoing.32:04Uh, Brandon or Kevin as far as the reduction of the forgiveness that takes place when you reduce the compensation of an employee below 75% of what they were receiving on a per hour basis, or you reduce the workforce as opposed to covering that??I don't think we should cover that right now.?People can read about it, or if they send us an e-mail with the ...32:28line, reduction rules, we can send them a separate video on that, but what has changed, if anything, under the interim regulation's versus the application?32:41one of the big changes here is they clarified that the headcount reduction and the salad reduction don't work because I don't provide like a double reduction.?So if you're looking at just the headcount versus the salary and you reduce you, keep someone at the same hourly rate, but don't reduce that rate and reduce their hours, you're going to be penalized in your head count abduction, because you're not going to have the same number of full-time equivalence.?But it's not going to also be considered a salary reduction.?Think.?That was one of the big changes, The other change that they added.33:13And I think that stands out as part of this rehire exception, where you make an offer to rehire someone and they reject that offer.?You can include them back and your, your headcount, they've added that you have to report them to the unemployment agency for that reduction to not apply.?So that basically requiring you to knock on your employees and then send, you know, I guess a notification and they're going to provide guidance with how we're going to do that.33:38But that is and a new fifth requirement to meet that exception Narc require very interesting so we have more about those topics and our experiences in our doc in our PowerPoint here.33:54Kevin What are your words of wisdom for a borrower who might want to use the AICP spreadsheet or use your spreadsheet?34:05How much sophistication does it take?34:08What point should a CPA be brought in??What is your, know, best advice?34:13Because a lot of people on this call are business owners who are not financial professionals, but I think they sense that there's a lack of financial professionals available to help them, and they want to know as much as they can and do this as much as they can as they can.34:29Right, Alan, I think that almost everybody who has one of the, except for maybe the most simple form arrangement is going to need an accountant or CPA, or attack the attorney to help them walk through that process.?Not necessarily prepare form, but at least review it and counsel them.?And I encourage it really way before the end of the week period.?Because we now know that there are some strategy here that we've got to start looking at.?You mentioned earlier, starting a retirement plan.?That's probably an option somebody can employ.?I think that they need to look at how they are paying their employee, whether bonuses that are reasonable can be paid, and they're going to pay them.?You gotta remember, for every, for every dollar, a payroll costs, like, Yeah, I can count an additional 25 times the non payroll cost, though.35:25That's the driver now, and that's the real strategy.?I think as far as, you know, the other options are tools out there for people to use AI.?TK did publish a worksheet.?It's kind of complicated.?We tried to keep ours much more simplified for the mass market, for the business owner, plain English It, Followed the application, the forgiveness application line by line, or even talking to a couple lenders about the possibility of being able to use our worksheet.35:59And Calculator as an attachment to the application, which would make life a lot easier for the borrower.?I believe if you provide some data like that or not with the backup data, Replete review, page 10 of the Forgiveness Application Instructions.?It tells you what you need to attach.?And I'm convinced, based on reading the interim final rule for the borrower and the lender responsibility, but also came out on Friday.?That more is better, to give to the to the lender, but in good order, I think that you'll get an approval much quicker, and I think that would make your life a little bit easier.36:44Right.36:44So, it will be up to the borrower to provide the lender with.36:52With all the documentation needed, to facilitate getting the loan reduce.36:59So, that's going to be, I think, very, very important.37:04And as those, for those of you who saw the article or read the article, the banks have a lot of responsibility, and they only have 60 days.37:13From the time that you give them the application to approve the application, then they take that to the SBA.37:21Then the SBA only has 30 days to complain or not.?So, during your, I would think that on the last day of your eighth week, on your 56 day, you should have this application done, because you should really do it before you start based on estimates so you can understand how it works.37:40Once you've spent a couple hours working through the the application itself or Kevin spreadsheet or the AICP slash spreadsheet.37:47Then, you'll understand these rules a lot better and then, when you read the instructions, and then when you read our articles, you'll understand them that much better Branden any final words?38:00Yeah, one of the scene in the question panel Here, we're getting a lot of questions about where we can find these rules and read them that they're hard to find online.?If you go to treasury dot gov, there's, that's the homepage for the Treasury website.?They have a banner at the top of their page for all the new rules and regulations.?You can click on that banner and it takes you to everything that's been released as far as the PPP loan.?So that's one source of information.38:21Lot of other questions about whether spreadsheets been updated or not, and will continue to be, and the our spreadsheet is updated for these new rules.38:28We're continuing to do so, as new rules come out in, whenever you get the link that, it would be always be the most up to date version.?In that link, so you continue to go back and refresh If the rules change.?So someone who buys it always gets free.?unlimited refresh.?It refreshed additions.38:46And if you're interested in Kevin Spreadsheet, we'll be glad to send you a PDF version, no charge.?But if you try it out, its money back guarantee, so should be good.38:59Kevin, any final words?39:01I think the final word Alan is be in control of it.?Don't be don't be a spectator.?Get involved, You know, a borrower can control the outcome here.?It's a good strategy.39:19Yeah, and get in line and make sure you have a CPA helping you because it can make a big difference.?You may be amending leases, You may be amending loan agreements.?You may be putting off the payment of rent.?Think these things through so you can get the most forgiven as possible.?And if you have any question about whether the necessity requirement is going to be an issue for you, that could be a criminal issue.?That could be a million dollar fine, see a qualified lawyer to talk about it.?It's better to be able to say that a qualified lawyer told you it wasn't going to be a problem.?That would make it much less of a problem.39:53But the attorney client privilege does it apply, unless you're talking to a lawyer about this, if you talk to your accountant about it, or your best friend, and you send them an e-mail, or a text that could later be evidence against you.?Well, you have our e-mail addresses there.?As I always say, please send the hard questions to Brandon and Kevin, the easy questions to me.?We do answer most of the questions that come in.?And on Tuesday, those of you who are going to be joining us for the lineberger talk, you'll see at least 30 to 45 minutes of questions being answered.?We'll continue to provide topical webinars.?if you're new to this webinar, and you want to see some of the historical webinars, send me an e-mail.?put in the word historical and the reline, and we'll send it to you.40:34I hope you have a fantastic Sunday, I hope you, I hope that you help others get some rest, and make the best of what we have, at least here in Clearwater, Florida, as some beautiful weather and very nice people to spend time with.?Thank you. ................
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