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Paycheck Protection Program
Interim Final Rule

Updated 4-3-2020


Key provisions for our clients and friends


Paycheck Protection Program – Interim final rule published April 2, 2020


In an effort to release timely information, we would like to point out a few highlights from the Interim Final Rule published by the US Department of the Treasury Thursday evening.


  1. Clarification on proof of eligibility for sole proprietors and independent contractors

    1. The required support to establish eligibility of sole proprietors and independent contracts list additional options/examples of acceptable support:

      1. Payroll processing records, payroll tax filings, Form 1099-Misc, income and expenses from sole proprietor ship, and

      2. If no such documentation is available, other supporting documentation such as bank records, sufficient to demonstrate the qualifying payroll amount.


  1. This publication specifically excludes nannies and housekeepers from eligibility.


  1. The calculation for the monthly payroll cost to calculate how much an entity can borrow has been simplified and includes examples.


  1. Excludes 1099 contractors from the PPP loan calculations as they have the ability to apply on their own.


  1. Interest rate will be 1% - Loan term remains at 2 years.


  1. Limitation on forgiveness – The document specifically states that not more than 25 percent of the loan forgiveness amount may be attributable to non-payroll costs.


  1. There have been some clarifications on the documentation required for the loan – work with your lender to confirm exactly what is expected.


  1. This publication provides additional information on refinancing your EIDL into a PPP.

    1. If your EIDL loan was used for payroll costs, your PPP loan must be used to refinance your EIDL loan.

    2. If your EIDL Loan was not used for payroll costs, the amount refinanced into the PPP must consider that 75% of the PPP loan proceeds must be used for payroll costs.

    3. Proceeds from any advance up to $10,000 on the EIDL loan will be deducted from the loan forgiveness amount on the PPP loan.


Please note that these are a few areas that we believe are substantial changes from initial interpretations of the CARES Act or are most relevant for our clients and friends. We encourage everyone to review the full publication from the Department of the Treasury here.

We at TJ Advisors are committed to bringing you the most relevant and up to date information in an effort to help your business stay on track during this period of uncertainty. Please note that not all provisions, exceptions, exclusions, and special circumstances are included in order to maintain brevity. Please reach out directly so that we can provide the business support you need in these unprecedented times. We are here for you, contact us today at or 972-629-9164.

Refer to Family First Act & CARES Act​ page for additional COVID-19 Related Payroll Tax Credits

Refer to Paycheck Protection Program - Additional Criteria & Requirements page for additional eligibility criteria & requirements for certain pledges of loans

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