Key takeaways from SBA's New Guidance Issued for Self-employed

Key takeaways from SBA's New Guidance Issued for Self-employed

On April 14, 2020, the U.S. Small Business Administration released the Business Loan Program Temporary Changes; Paycheck Protection Program – Additional Eligibility Criteria and Requirements for Certain Pledges of Loans, which provides additional guidance for those who are self-employed. We have highlighted some of the key takeaways from the new guidance below.

For self-employed

  1. Paycheck Protection Program (PPP) Loan is based on 2019 Schedule C net income with a max of $100,000. No amount of SE health or SE retirement is added for a schedule C owner.
  2. In order to get the PPP loan, a 2019 Schedule C is required with the loan application.
  3. If the amount of your 2019 Schedule C is zero (and you have no employees), you do not qualify for PPP.
  4. Partnerships may add the self-employment income of general active partners up to $100,000. Partners do NOT apply for PPP individually.
  5. SBA will issue more guidance for Schedule C businesses operating on 2/15/2020, but not in business for 2019.
  6. You should be aware that participation in the PPP may affect your eligibility for state administered unemployment programs.

Loan forgiveness calculations for self-employed

  1. Forgiveness is based on eight weeks of the 2019 Schedule C for an owner’s “payroll”. Forgiveness has nothing to do with 2020 net income. For example, if the $100,000 limit was reached in 2019, the PPP loan is $20,833 and the owner’s “payroll” is $15,385 to be forgiven automatically. This leaves $5,448 to be covered by rent, mortgage interest, or utilities. 
  2. In addition to the loan principal, accrued interest on the loan can also be forgiven. Interest accrues at a rate of 1%.
  3. Interest on an auto loan qualifies according to this guidance. This clarifies that mortgage interest includes any loan with hard collateral (real or personal property).
  4. The gas you use to drive your business vehicle is considered a utility payment, according to this guidance. 
  5. If expenses were not deducted on 2019 Schedule C, the business owner can’t claim them now for forgiveness.
To read the full guidance, click https://home.treasury.gov/system/files/136/Interim-Final-Rule-Additional-Eligibility-Criteria-and-Requirements-for-Certain-Pledges-of-Loans.pdf.

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