Information and Resources

PPP Loan requests that resulted in loans of less than $2 million will be deemed to have been certified by the applicant in good faith

All recipients of PPP Loans of less than $2 million will be deemed to “have made the required certification concerning the necessity of the loan request in good faith.”

May 13, 2020

In a May 13 update of its PPP FAQ (see FAQ 46), the SBA said that all recipients of PPP Loans of less than $2 million will be deemed by the SBA to “have made the required certification concerning the necessity of the loan request in good faith.”

The relevant section of the FAQ is as follows:

46.
Question: How will SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?

Answer: When submitting a PPP application, all borrowers must certify in good faith that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” SBA, in consultation with the Department of the Treasury, has determined that the following safe harbor will apply to SBA’s review of PPP loans with respect to this issue: Any borrower that, together with its affiliates, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.

SBA has determined that this safe harbor is appropriate because borrowers with loans below this threshold are generally less likely to have had access to adequate sources of liquidity in the current economic environment than borrowers that obtained larger loans. This safe harbor will also promote economic certainty as PPP borrowers with more limited resources endeavor to retain and rehire employees. In addition, given the large volume of PPP loans, this approach will enable SBA to conserve its finite audit resources and focus its reviews on larger loans, where the compliance effort may yield higher returns.

Related Links

To Apply for a Second Draw PPP Loan

Your congregation will be required to certify its need for the funds and must have:
  • Received, and have expended or expect to expend, an original PPP loan
  • Experienced a 25% reduction in gross receipts in any quarter in 2020 compared to the same quarter in 2019
  • 300 or fewer employees.

Determining Your Eligibility

To determine if you qualify, please click here to download a worksheet generously made available by diocesan auditors, PKF O’Connor Davies, LLP. Please note that this worksheet is offered “as is” and users use it at their own risk: in particular, please note the disclaimers on the Instructions tab, and review the outcome of your entries to make sure they make sense.


PKF O’Connor Davies COVID-19 Resource Center
Current information from an accounting firm.

SBA Portal with Links to All Documents and Forms

SBA FAQ for Faith-Based Organizations

Finding a Lender

The SBA has set up a web page to match borrowers with lenders.
Please click here to see it.

Application Forms

Informational Documents

Staff Contact

The Rev. Canon John D. Perris
Canon to the Ordinary
jperris@dioceseny.org

Download Documents as PDFs