we will be with you shortly. - stambaugh ness...apr 20, 2020 · ppp loans forgiveness: overview...
TRANSCRIPT
… we will be with you shortly.
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QUESTIONBUCKETS
WORKFORCE
TECHNOLOGY
REGULATORY
CASH FLOW
HUMAN RESOURCES
AGENDA
INTRODUCTION
COVID-19 UPDATE REGULATORY WORKFORCE CASH FLOW PPP
HILLMANN CONSULTING – COVID-19 FACILITIES
COVID-19 ROUND TABLE: THE NEXT 30-60 DAYS
Q&A PORTION
INTRODUCTION
TOM MOUL, CPA
COVID-19 UPDATE:REGULATORY
TOM MOUL, CPA
COVID-19 UPDATE:WORKFORCE
KRISTI WEIERBACH, Ph.D., SPHR, SHRM-SCP
COVID-19 UPDATE:CASH FLOW
STEVE SNYDER, CPA, CCIFP
COVID-19 UPDATE:PPP
CHAD BUMBAUGH, CPA
DISCLAIMER
This presentation is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although we have made every effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this presentation. Some of those modifications may be significant. As such, be aware that this not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to your or your business with respect to the matters addressed.
PPP LOANS FORGIVENESS: OVERVIEW
Potential for up to 100% Loan Forgiveness (including accrued interest) Determined based on how PPP funds spent during 8-week covered
period Expenses must be incurred and paid during the 8-week period to be
eligible for forgiveness *
8-week covered period begins upon date PPP funds received Forgiveness subject to various determinants that are measured
throughout 8-week covered period Lenders will ultimately make forgiveness determination
* - CARES act Section 1106 Loan Forgiveness items (b)
PPP LOANS FORGIVENESS: OVERVIEWCONTINUED
Covered Expenses* U.S. based cash employee compensation up to $100k (ex. wages,
salaries, commissions, bonuses, as well as leave time - vacation, medical, parental, sick**, etc.) Group Healthcare (including self-insurance) & Retirement benefits Employer paid State & Local payroll taxes on compensation Rent – if lease or agreement in place before February 15, 2020
Related party rentals are not specifically disallowed but rent agreements prior to February 15, 2020 required
Utilities – if service in place before February 15, 2020 CARES act defined as: Electricity, gas, water, transportation (?), telephone,
internet. Transportation utility = fuel for business vehicles?
Mortgage and other Interest – for debt in existence before February 15, 2020 Although there is some debate about conflicting wording in guidance it
appears intent is to allow interest on any debts in place February 15, 2020 (not just those secured by a mortgage)
* - Interim final rule item 2(r) - How can PPP loans be used? ** - unless claiming a credit under Families First Coronavirus Response Act (FFCRA)
PPP LOAN FORGIVENESS:DETERMINANTS
75% Payroll Costs / 25% Other Costs Usage Requirement *
FTE Requirements during 8-week covered period ** Forgiveness is reduced if you decrease full-time equivalent
headcount during covered period FTE believed to be defined as employee working > 30 hours (“ACA
method” *** with a twist – measured per pay period as opposed to per month – not yet definitively defined in context of CARES act)
Compensation Requirement during 8-week covered period ** Compensation cannot be reduced by more than 25% per employee
during covered period compared to the most recent full quarter during which employee was employed prior to covered period Only applies to employees under $100k wage cap
* - Interim final rule item 2(o) - Can my PPP loan be forgiven in whole or in part?
** - CARES act Section 1106 Loan Forgiveness items (d)(2) and (d)(3)
*** - ACA method detail in IRC Section 4980H
PPP LOANS FORGIVENESS: DETERMINANTSCONTINUED
June 30th “restoration” – grace period for FTE & compensation requirements during 8-week covered period * Loan forgiveness determined “without regard to reduction in
number of full-time equivalent employees of an eligible recipient or a reduction in salary of employees during the period beginning on February 15, 2020 through April 26, 2020 (30 days after enactment of CARES Act in original text)” if, by June 30th, the employer has eliminated the reduction in the number of FTE’s or wages of such employees.
* - CARES act Section 1106 Loan Forgiveness items (d)(5)
ORDERING OF PPP LOAN FORGIVENESS MECHANICS
Some debate about “ordering” of Determinants of Forgiveness
Our opinion is that ordering of determinants is as follows:
1. 75% / 25% rule – to determine maximum possible forgiveness2. June 30th Restoration – have FTE & Salary reductions been
mitigated? 3. 8-week covered period FTE & Salary limitations
PPP LOAN FORGIVENESS MECHANICSCONTINUED
75% / 25% At least 75% of the loan forgiveness amount must be spent on
payroll costs *
PPP LOAN FORGIVENESS MECHANICSCONTINUED
FTE’S & JUNE 30TH GRACE PERIOD
FTE reductions mitigated? Much to consider here in terms of how to staff business Who & how brought back matters!
1. Employee working 30 hours counts as one for FTE reduction purposes 2. Employee working either 40 or even 60 hours will still only count as one for
FTE reduction purposes – no “credit” for additional hours (although additional compensation would likely reduce any limitation based on salary)
3. Two employees working 30 hours each are more favorable for FTE reduction purposes even if compensation paid, in total, is the same as the one individual working 60 hours.
4. Four Part-Time employees working 15 hours each (same 60 hours) count as 2 FTE’s
5. One employee working 10 hours per week = 0.33 FTE (10/30 hours)
Importance of scheduling (already vital in many industries) just ramped up significantly.
Choices around FTE measurement periods and seasonal business considerations
Numerous unknowns remain - Can I hire family members? Temps? What about rehires new/modified positions? What about replacements for employees who left the organization?
PPP LOAN FORGIVENESS MECHANICSCONTINUED
FTE’S & JUNE 30TH GRACE PERIOD
BASIC EXAMPLE
PPP LOAN FORGIVENESS MECHANICSCONTINUED
SALARY & JUNE 30TH
GRACE PERIOD
Salary Reductions Mitigated? Important to note this calculation is employee specificOnly applies to employees under $100k annualized
compensation cap As written guidance is comparing a quarter (roughly 12-
week period) to 8-week forgiveness period – inherent reduction > 25% if pay not increased Seen as flaw in the guidance which hopefully will be corrected
Key thresholds:
PPP LOAN FORGIVENESS MECHANICSCONTINUED
WAGES & JUNE 30TH GRACE PERIOD
BASIC EXAMPLE
PPP LOAN FORGIVENESS MECHANICSCONTINUED
SALARY & JUNE 30TH
GRACE PERIOD
WHAT ABOUT BONUSES?
Under current guidance can pay bonuses and have these count toward meeting payroll requirements Bonuses can’t exceed $100,000 annualized in
determining forgiveness
PPP LOAN FORGIVENESS:FINAL TALLY
TIPS FOR PREPARING FOR FORGIVENESS
Schedule personnel with intentionality
Calculate FTE’s for the applicable periods – do what you can now
Work on forgiveness modeling –early & often; particularly FTE’s We can help!
Look at how timing of payrolls fall – adjustment needed?
Gather documentation to support forgiveness calculation
Plan for potential repayment if not fully forgiven Repay after forgiveness determination or take the 1% / two-year
loan?
FORGIVENESSMEASUREMENTMECHANICS
Lenders will have 60 days once information provided to determine forgiveness
Remaining balance will convert to 2-year term loan / 1% interest Payments on PPP loan are deferred for 6 months (interest continues
to accrue during deferral period)
Lenders may differ in their request for information / interpretations of guidance even after final regulations on forgiveness issued – discussions with lenders throughout process highly encouraged! We are seeing lenders ask for bank statements of the account PPP
funds deposited into to view activity
SUBJECT TO CHANGE!
Final word of caution – the items discussed in this presentation are pending Treasury’s further guidance on forgiveness which is anticipated any day.
HILLMANN CONSULTING -FACILITIES
CHRIS BAKER, HILLMANN CONSULTING
COVID-19 ROUND TABLE
THE NEXT 30 DAYS
OPERATIONS/FACILITIES
CASH FLOW/FINANCE
CLIENT/SUPPLIER
PERSONNEL
QUESTION & ANSWER
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APRIL 28, 2020 @ 2:00pm – 4:00pm