On Friday, May 15th, the Small Business Administration (SBA) released the application borrowers of a Paycheck Protection Program (PPP) loan must use to determine the amount of the loan that may be “forgiven” by their lender. While the application included instruction, the SBA failed to provide two additional items that would have greatly benefited borrowers:
1. Narrative-based guidance, similar to previously issued interim final rules, which ideally would clear up much of the confusion surrounding critical definitions, from what items are included in payroll costs to the treatment of guaranteed payments or self-rental payments.
2. Detailed blueprints for constructing a fully functioning time machine, so nearly two million small business owners could magically transport back to a time when this forgiveness guidance would actually be useful.