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Paycheck Protection Program Round 3 – Frequently Asked Questions

Thank you for your interest in the Paycheck Protection Program (PPP). In partnership with Crowe, LLC, we will be answering questions received regarding the latest round of PPP.

Click below for more information on:



First Draw Loans

Question Answer
Are workers' compensation costs included in the 2.5 months worth of payroll costs? Workers' compensation costs are included in eligible payroll costs if part of state payroll taxes.
Can I include costs to independent contractors in my payroll calculation? No, only payments made to W-2 employees are eligible payroll costs. 1099 payments are ineligible as these individuals are eligible to apply for their own PPP loan.
The new form asks how the funds will be used. Are these cost categories included in payroll costs since the loan is only based payroll? The loan amount is solely based on payroll costs, but the loan funds may be used for the various cost categories listed.
Should amounts paid to employees for an annualized salary greater than $100,000 be excluded from the loan calculation? Yes, only compensation up to an annualized salary of $100,000 should be included in the loan amount calculation. Benefits costs are not included in the $100,000 threshold.
If a business was closed for a few months and just reopened, is the business eligible for a PPP loan? As long as the business is not permanently closed and other program requirements are met, the Borrower would still be eligible for a PPP loan.
If a business purchased another business in late 2020, can the payroll expenditures due to the purchase be used to calculate the loan amount? Payroll costs are evaluated per entity. Thus, if a business acquired another, the additional payroll due to the acquisition would be included in the loan calculation for the months the businesses were under common ownership.
An applicant wants to use 2020 payroll costs because new employees were hired in 2020. However, the owner's income is on a 2019 Schedule C. Can the applicant include both 2020 payroll costs and the owner's 2019 Schedule C income in their loan amount calculation? No. An applicant may choose either 2019 or 2020 to calculate their loan amount, however, payroll from 2020 and owner compensation in 2019 may not be combined to calculate the loan amount. The applicant must choose to provide documentation from either 2019 or 2020, but not both. A Schedule C for 2020 which is not yet filed but which is signed and dated by the Borrower may be used with 2020 employee payroll reports.

Are workers compensation costs included in the 2.5 months worth of payroll costs?

Workers compensation costs are included in eligible payroll costs if part of state payroll taxes.

Can I include costs to independent contractors in my payroll calculation?

No, only payments made to W-2 employees are eligible payroll costs. 1099 payments are ineligible as these individuals are eligible to apply for their own PPP loan.

The new form asks how the funds will be used. Are these cost categories included in payroll costs since the loan is only based payroll?
The loan amount is solely based on payroll costs, but the loan funds may be used for the various cost categories listed.

Should amounts paid to employees for an annualized salary greater than $100,000 be excluded from the loan calculation?
Yes, only compensation up to an annualized salary of $100,000 should be included in the loan amount calculation. Benefits costs are not included in the $100,000 threshold.

If a business was closed for a few months and just reopened, is the business eligible for a PPP loan?
As long as the business is not permanently closed and other program requirements are met, the Borrower would still be eligible for a PPP loan.

If a business purchased another business in late 2020, can the payroll expenditures due to the purchase be used to calculate the loan amount?
Payroll costs are evaluated per entity. Thus, if a business acquired another, the additional payroll due to the acquisition would be included in the loan calculation for the months the businesses were under common ownership.


Second Draw Loans

Question Answer
If a business received previous PPP funds, EIDL grants, unemployment benefits, or other government grants, are these funds to be included in gross receipts when calculating eligibility for a Second Draw PPP loan? PPP funds and other state and federal government grants are not included in gross receipts.
How should an applicant demonstrate they had a 25% reduction in gross receipts, in order to be eligible for a Second Draw loan? It is not required to provide documentation evidencing the applicant experienced a 25% reduction in gross receipts. This is a certification made by the applicant. The SBA may request documentation supporting this certification during a PPP loan audit. Please refer to the PPP Information webpage to learn about Second Draw documentation requirements.
How should independent contractors and sole proprietors calculate their loan amount? What documentation is required? Independent contractors and sole proprietors may calculate their loan amount based on 2.5 months worth of income from 2019 or 2020, subject to a cap of an annualized salary of $100,000. The 2019 or 2020 Schedule C tax filing should be provided.
Do applicants have the choice of using either 2019 or 2020 payroll documentation to calculate their loan amount? Yes, the loan amount may be based on either 2.5 months worth of payroll from 2019 or 2020.
Must Borrowers have applied for Forgiveness of their first PPP loan before applying for a Second Draw PPP loan? You can receive a Second Draw loan after your first loan has been fully used, and you do not need to have the first loan forgiven before the second loan.
My business began operations in 2019. Our 2020 gross receipts are greater than 2019 due to being in operation in 2019 for only a few months, but still need a PPP loan to support our operations. Do we qualify for a second PPP loan? SBA guidance states that a business is eligible for a Second Draw PPP loan if the business experienced at least a 25% decrease in gross receipts for any quarter in 2020 relative to the same quarter in 2019.
What is included in gross receipts? Per SBA guidance on Second Draw loans, gross receipts includes all revenue in whatever form received or accrued (in accordance with the entity's accounting method) from whatever source, including from the sales of products and services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances.
Would an applicant qualify for a Second Draw PPP loan if employees were laid off or furloughed in 2020? Per SBA guidance on Second Draw loans, gross receipts includes all revenue in whatever form received or accrued (in accordance with the entity's accounting method) from whatever source, including from the sales of products and services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowance
Is a business eligible for a Second Draw PPP loan if the business began in early 2020, prior to February 15, and cannot perform the 2019 gross receipts comparison? SBA guidance states that a business is eligible for a Second Draw loan if the business experienced at least a 25% decrease in gross receipts for any quarter in 2020 relative to the same quarter in 2019. If a business does not have 2019 gross receipts to compare to, they are ineligible for a second draw loan.
Is owner draw also included in eligible payroll costs when calculating the loan amount? Owner draw is included in payroll when calculating the loan amount.
Are owners included in the 300 employee limit for eligibility? Owners are included in the employee count when evaluating eligibility for a PPP loan.
What time period do Second Draw PPP loan funds cover? In order to achieve loan Forgiveness, Second Draw funds must be spent on eligible payroll and non-payroll costs during the Covered Period. The Covered Period will begin for these loans the date the Second Draw loan is disbursed into the Borrower's account.
How do I calculate the 25% reduction in gross receipts? The revenue reduction is calculated by taking 2020 gross receipts/2019 gross receipts. If the calculated value is 0.75 or less, the 25% reduction is met.
Is it correct that NAICS code 72 businesses are eligible for a loan amount of 3.5 months worth of payroll? Yes, industries assigned to NAICS code 72 (lodging and restaurants) may receive loans up to 3.5 months of average monthly payroll costs for their Second Draw PPP loan.
Our business services the restaurant industry, but we are not under the NAICS Code of 72. Are we eligible for a loan of 3.5 months worth of payroll? SBA guidance states that only industries under the NAICS Code of 72 are eligible for a Second Draw loan of 3.5 months worth of payroll costs.
Can the Second Draw PPP loan amount be different than the First Draw loan, or must the amounts be the same? The amounts may be different if an applicant chooses to base the loan amount calculation on 2020 payroll costs versus 2019 payroll costs that were used to calculate the first loan amount.
What documents are required to apply for a Second Draw loan? Please refer to the PPP Information webpage for information on Second Draw documentation requirements.
If a business only experienced a decrease in gross receipts during one quarter of 2020, are they still eligible for a Second Draw PPP loan? Yes, the legislation signed by Congress states that to be eligible for a Second Draw (a new PPP loan), the Borrower must have experienced a decrease in gross receipts in either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.
If payroll documentation was already provided for our first PPP loan, do we need to provide this same documentation to apply for a second PPP loan? Yes. This loan is viewed as a separate loan so all supporting documentation must be provided with the Second Draw loan application.
What is included in the 2.5 months worth of eligible payroll costs? Payroll costs include employee compensation of variety of forms, employee benefits paid by the employer, owner compensation, retirement plan costs paid by the employer, and state or local payroll taxes.
Is the 25% gross receipt reduction based on calendar year or fiscal year calculations? The 25% reduction is based on a calendar quarter calculation, not an annual calculation.
Are workers compensation costs included in the 2.5 months worth of payroll costs? Workers compensation costs are included in eligible payroll costs if part of state payroll taxes.
Can I include costs to independent contractors in my payroll calculation? Only payments made to W-2 employees are eligible payroll costs. 1099 payments are ineligible as these individuals are eligible to apply for their own PPP loan.
If a business experienced a decrease in gross receipts of 20% but a decrease in net income of 50%, do they qualify for a Second Draw PPP loan? Per SBA guidance, the business must have experienced a 25% decrease in gross receipts in either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.
Are donations to charities and non-profits included in gross receipts? Donations received by charities and non-profits are included in gross receipts.
The new form asks how the funds will be used. Are these cost categories included in payroll costs since the loan is only based payroll? The loan amount is solely based on payroll costs, but the loan funds may be used for the various cost categories listed.
What type of documentation is needed to demonstrate that all First Draw PPP loan funds have been used, or will have been used, by the time the Second Draw PPP loan is received? There is no documentation required, however, the Borrower must certify that the first loan (First Draw) has been used or will have been used for eligible expenses. The SBA may request support of this certification in the case of a PPP loan audit.
If a business' First Draw loan was not completely forgiven, does this affect eligibility for a Second Draw loan? Second Draw loan eligibility is not based on the Forgiveness of the first loan (First Draw). However, since the first loan was not fully forgiven, this means that loan funds may not have been fully used for eligible program purposes. The applicant will need to certify that the First Draw loan funds have been fully utilized.
A business opened a second location in 2020, thus, gross receipts are higher than 2019. Does the business qualify for a Second Draw loan since the locations would meet the 25% requirement if evaluated separately? The eligibility requirement is for the legal business entity as a whole, comparing one quarter in 2020 to the same quarter in 2019. You will need to review your results for each quarter to determine if any quarter has a 25% decline. If that is not the case because of the second location, unfortunately the guidance at this point would indicate the business is not eligible.
If a business sold assets to increase cash flow, can the capital gain be excluded from gross receipts when calculating the 25% revenue reduction? Yes. The instructions on the form indicate capital gains are excluded from gross receipts.
Should amounts paid to employees for an annualized salary greater than $100,000 be excluded from the loan calculation? Yes, only compensation up to an annualized salary of $100,000 should be included in the loan amount calculation. Benefits costs are not included in the $100,000 threshold.
If a business experienced a decrease in gross receipts in 2020 but recovered by the end of the year, is the business still eligible for a Second Draw PPP loan? Yes, the legislation signed by Congress states that to be eligible for a Second Draw or new PPP loan, the Borrower must have experienced a decrease in gross receipts in one quarter, either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.

If a business received previous PPP funds, EIDL grants, unemployment benefits, or other government grants, are these funds to be included in gross receipts when calculating eligibility for a Second Draw PPP loan?
PPP funds and other state and federal government grants are not included in gross receipts.

How should an applicant demonstrate they had a 25% reduction in gross receipts, in order to be eligible for a Second Draw loan?
It is not required to provide documentation evidencing the applicant experienced a 25% reduction in gross receipts. This is a certification made by the applicant. The SBA may request documentation supporting this certification during a PPP loan audit. Please refer to the Current Customer webpage for information on Second Draw documentation requirements.

How should independent contractors and sole proprietors calculate their loan amount? What documentation is required?
Independent contractors and sole proprietors may calculate their loan amount based on 2.5 months worth of income from 2019 or 2020, subject to a cap of an annualized salary of $100,000. The 2019 or 2020 Schedule C tax filing should be provided.

Do applicants have the choice of using either 2019 or 2020 payroll documentation to calculate their loan amount?
Yes, the loan amount may be based on either 2.5 months worth of payroll from 2019 or 2020.

Must Borrowers have applied for Forgiveness of their first PPP loan before applying for a Second Draw PPP loan?
You can receive a Second Draw loan after your first loan has been fully used, and you do not need to have the first loan forgiven before the second loan.

My business began operations in 2019. Our 2020 gross receipts are greater than 2019 due to being in operation in 2019 for only a few months, but still need a PPP loan to support our operations. Do we qualify for a second PPP loan?
SBA guidance states that a business is eligible for a Second Draw PPP loan if the business experienced at least a 25% decrease in gross receipts for any quarter in 2020 relative to the same quarter in 2019.

What is included in gross receipts?
Per SBA guidance on Second Draw loans, gross receipts includes all revenue in whatever form received or accrued (in accordance with the entity's accounting method) from whatever source, including from the sales of products and services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances.

Would an applicant qualify for a Second Draw PPP loan if employees were laid off or furloughed in 2020?
Per SBA guidance on Second Draw loans, gross receipts includes all revenue in whatever form received or accrued (in accordance with the entity's accounting method) from whatever source, including from the sales of products and services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances.

Is a business eligible for a Second Draw PPP loan if the business began in early 2020, prior to February 15, and cannot perform the 2019 gross receipts comparison?
SBA guidance states that a business is eligible for a Second Draw loan if the business experienced at least a 25% decrease in gross receipts for any quarter in 2020 relative to the same quarter in 2019. If a business does not have 2019 gross receipts to compare to, they are ineligible for a second draw loan.

Is owner draw also included in eligible payroll costs when calculating the loan amount?
Owner draw is included in payroll when calculating the loan amount.

Are owners included in the 300 employee limit for eligibility?
Owners are included in the employee count when evaluating eligibility for a PPP loan.

What time period do Second Draw PPP loan funds cover?
In order to achieve loan Forgiveness, Second Draw funds must be spent on eligible payroll and non-payroll costs during the Covered Period. The Covered Period will begin for these loans the date the Second Draw loan is disbursed into the Borrower's account.

How do I calculate the 25% reduction in gross receipts?
The revenue reduction is calculated by taking 2020 gross receipts/2019 gross receipts. If the calculated value is 0.75 or less, the 25% reduction is met.

Is it correct that NAICS code 72 businesses are eligible for a loan amount of 3.5 months worth of payroll?
Yes, industries assigned to NAICS code 72 (lodging and restaurants) may receive loans up to 3.5 months of average monthly payroll costs for their Second Draw PPP loan.

Our business services the restaurant industry, but we are not under the NAICS Code of 72. Are we eligible for a loan of 3.5 months worth of payroll?
SBA guidance states that only industries under the NAICS Code of 72 are eligible for a Second Draw loan of 3.5 months worth of payroll costs.

Can the Second Draw PPP loan amount be different than the First Draw loan, or must the amounts be the same?
The amounts may be different if an applicant chooses to base the loan amount calculation on 2020 payroll costs versus 2019 payroll costs that were used to calculate the first loan amount.

What documents are required to apply for a Second Draw loan?
Please refer to the Current Customer webpage for information on Second Draw documentation requirements.

If a business only experienced a decrease in gross receipts during one quarter of 2020, are they still eligible for a Second Draw PPP loan?
Yes, the legislation signed by Congress states that to be eligible for a Second Draw (a new PPP loan), the Borrower must have experienced a decrease in gross receipts in either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.

If payroll documentation was already provided for our first PPP loan, do we need to provide this same documentation to apply for a second PPP loan?
Yes. This loan is viewed as a separate loan so all supporting documentation must be provided with the Second Draw loan application.

What is included in the 2.5 months worth of eligible payroll costs?
Payroll costs include employee compensation of variety of forms, employee benefits paid by the employer, owner compensation, retirement plan costs paid by the employer, and state or local payroll taxes.

Is the 25% gross receipt reduction based on calendar year or fiscal year calculations?
The 25% reduction is based on a calendar quarter calculation, not an annual calculation.

Are workers compensation costs included in the 2.5 months worth of payroll costs?
Workers compensation costs are included in eligible payroll costs if part of state payroll taxes.

Can I include costs to independent contractors in my payroll calculation?
Only payments made to W-2 employees are eligible payroll costs. 1099 payments are ineligible as these individuals are eligible to apply for their own PPP loan.

If a business experienced a decrease in gross receipts of 20% but a decrease in net income of 50%, do they qualify for a Second Draw PPP loan?
Per SBA guidance, the business must have experienced a 25% decrease in gross receipts in either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.

Are donations to charities and non-profits included in gross receipts?
Donations received by charities and non-profits are included in gross receipts.

The new form asks how the funds will be used. Are these cost categories included in payroll costs since the loan is only based payroll?
The loan amount is solely based on payroll costs, but the loan funds may be used for the various cost categories listed.

What type of documentation is needed to demonstrate that all First Draw PPP loan funds have been used, or will have been used, by the time the Second Draw PPP loan is received?
There is no documentation required, however, the Borrower must certify that the first loan (First Draw) has been used or will have been used for eligible expenses. The SBA may request support of this certification in the case of a PPP loan audit.

If a business' First Draw loan was not completely forgiven, does this affect eligibility for a Second Draw loan?
Second Draw loan eligibility is not based on the Forgiveness of the first loan (First Draw). However, since the first loan was not fully forgiven, this means that loan funds may not have been fully used for eligible program purposes. The applicant will need to certify that the First Draw loan funds have been fully utilized.

A business opened a second location in 2020, thus, gross receipts are higher than 2019. Does the business qualify for a Second Draw loan since the locations would meet the 25% requirement if evaluated separately?
The eligibility requirement is for the legal business entity as a whole, comparing one quarter in 2020 to the same quarter in 2019. You will need to review your results for each quarter to determine if any quarter has a 25% decline. If that is not the case because of the second location, unfortunately the guidance at this point would indicate the business is not eligible.

If a business sold assets to increase cash flow, can the capital gain be excluded from gross receipts when calculating the 25% revenue reduction?
Yes. The instructions on the form indicate capital gains are excluded from gross receipts.

Should amounts paid to employees for an annualized salary greater than $100,000 be excluded from the loan calculation?
Yes, only compensation up to an annualized salary of $100,000 should be included in the loan amount calculation. Benefits costs are not included in the $100,000 threshold.

If a business experienced a decrease in gross receipts in 2020 but recovered by the end of the year, is the business still eligible for a Second Draw PPP loan?
Yes, the legislation signed by Congress states that to be eligible for a Second Draw or new PPP loan, the Borrower must have experienced a decrease in gross receipts in one quarter, either quarter 1, quarter 2, quarter 3 or quarter 4 of 2020 relative to the same quarter of 2019.


Forgiveness

Question Answer
How do the new Forgiveness requirements impact non-profit organizations? The rules are the same for non-profit organizations as for for-profit organizations.
Even with additional cost categories eligible for Forgiveness, the loan amount does not change. How is it beneficial to add in new eligible costs incurred? New cost categories allow businesses to use the funds on other expenditures that resulted from the pandemic in case the Borrower was unable to spend the entirety of the loan on payroll.
Will the new requirements affect applications that have already been submitted to the Bank for Forgiveness? Borrowers may adjust their applications to reflect the new program requirements as long as the application has not been submitted to the SBA and Forgiveness has not been received.
If a business already submitted their Forgiveness application for a loan under $150,000, will the Borrower be required to re-apply using the new streamlined application? No. If an application was already submitted to the Bank, the applicant will not be required to resubmit a new application. However, if the application has not been submitted to the SBA and Forgiveness has not been received, the Borrower can resubmit their application to expedite the review process. On January 19, 2021, the SBA released their new Forgiveness application form for loans of $150,000 or less, called the 3508S. This is currently in our online portal and you may complete it at any time for your 2020 PPP loan. 
Can businesses include expenditures that fall under the new cost categories in their Forgiveness request for a loan that was issued in 2020?

Yes. New program requirements apply to new, Second Draw loans and current PPP loans.

How do the new Forgiveness requirements impact non-profit organizations?

The rules are the same for non-profit organizations as for for-profit organizations.


Even with additional cost categories eligible for Forgiveness, the loan amount does not change. How is it beneficial to add in new eligible costs incurred?

New cost categories allow businesses to use the funds on other expenditures that resulted from the pandemic in case the Borrower was unable to spend the entirety of the loan on payroll.

Will the new requirements affect applications that have already been submitted to the Bank for Forgiveness?
Borrowers may adjust their applications to reflect the new program requirements as long as the application has not been submitted to the SBA and Forgiveness has not been received.

If a business already submitted their Forgiveness application for a loan under $150,000, will the Borrower be required to re-apply using the new streamlined application?
No. If an application was already submitted to the Bank, the applicant will not be required to resubmit a new application. However, if the application has not been submitted to the SBA and Forgiveness has not been received, the Borrower can resubmit their application to expedite the review process. On January 19, 2021, the SBA released their new Forgiveness application form for loans of $150,000 or less, called the 3508S. We are currently working with our portal team to implement this into our system.

Can businesses include expenditures that fall under the new cost categories in their Forgiveness request for a loan that was issued in 2020?
Yes. New program requirements apply to new, Second Draw loans and current PPP loans.


Other

Question Answer
Is an entity that applied for a First Draw or Second Draw PPP loan on or after Dec. 27, 2020, eligible to apply for an a Shuttered Venue grant (SVOG)? Yes. While entities originally were prohibited from receiving both forms of SBA assistance, the American Rescue Plan Act, which became law on March 11, 2021, removed this restriction. However, under the law, entities will be ineligible for a PPP loan AFTER they receive an SVOG.
Are expenses used to support Forgiveness tax deductible from the First Draw or Second Draw loan? Expenses for forgiven PPP loans are tax deductible, regardless of whether the funds were from a First Draw or Second Draw loan.
Will Borrowers be notified in the event of an audit request? Yes. The Bank has five business days to notify the Borrower of an audit request. The Borrower must provide the Bank with the required documentation within 10 business days of notification. Once the Borrower has submitted all documentation requested by the SBA to the Bank, the Bank has five business days to upload all documentation to the SBA.
Should seasonal employers wait until the beginning of their busy season to apply for a PPP loan to allow more time to accumulate eligible costs? It is up to the Borrower to determine the best time to apply for a PPP loan. The Borrower has up to 24-weeks after loan disbursement to accumulate enough eligible costs to maximize Forgiveness.
Are Borrowers still required to pay back an EIDL? Yes. Economic Injury Disaster Loan (EIDL) recipients must repay the loan in full. EIDL grants are automatically forgiven and no longer reduce the recipients PPP loan Forgiveness amount.
If a business received a Shuttered Venue grant, can the funds be returned to be eligible for a PPP loan?
SBA guidance does not specifically address this situation, however, guidance does state that if a Borrower received a Shuttered Venue grant, they are ineligible for a PPP loan.

Are expenses used to support Forgiveness tax deductible from the First Draw or Second Draw loan?
Expenses for forgiven PPP loans are tax deductible, regardless of whether the funds were from a First Draw or Second Draw loan.

Will Borrowers be notified in the event of an audit request?
Yes. The Bank has five business days to notify the Borrower of an audit request. The Borrower must provide the Bank with the required documentation within 10 business days of notification. Once the Borrower has submitted all documentation requested by the SBA to the Bank, the Bank has five business days to upload all documentation to the SBA.

Should seasonal employers wait until the beginning of their busy season to apply for a PPP loan to allow more time to accumulate eligible costs?
It is up to the Borrower to determine the best time to apply for a PPP loan. The Borrower has up to 24-weeks after loan disbursement to accumulate enough eligible costs to maximize Forgiveness.

Are Borrowers still required to pay back an EIDL?
Yes. Economic Injury Disaster Loan (EIDL) recipients must repay the loan in full. EIDL grants are automatically forgiven and no longer reduce the recipients PPP loan Forgiveness amount.


We plan to update this webpage with more information as questions are received.

For more information regarding the latest Paycheck Protection Program round, we encourage you to visit our PPP webpage often. If you have further questions, please reach out to your relationship manager or call our Customer Information Center at 508.732.3826.

Thank you for working with Rockland Trust. Your relationship is truly important to us.


Important Note:

As a Borrower under the Paycheck Protection Program, it is your sole legal responsibility to comply with all laws and regulations applicable to Borrowers under the Small Business Administration Paycheck Protection Program (SBA PPP).

Rockland Trust urges SBA PPP Borrowers to closely review the latest SBA PPP law, regulations and guidelines (Guidelines). The Guidelines can be found on the Small Business Administration and the Department of Treasury websites: www.SBA.gov and www.Treasury.gov. Rockland Trust cautions you that the Guidelines are evolving.  The Small Business Administration periodically updates the Guidelines. Some updates modify prior Guidelines, other updates provide further clarification. 

Rockland Trust does not provide legal, tax, or accounting advice. Individual facts and circumstances vary from Borrower to Borrower which will impact any answers regarding any interpretation of questions. You should consult with your legal, tax, and accounting advisors to obtain advice regarding your specific situation. Our education materials and communications should be considered in connection with, and are not intended to replace or serve as a substitute for, your close review of the Guidelines, and legal, tax or accounting advice you are urged to obtain from your tax, accounting and legal advisors

Our communications are summaries or excerpts of the Guidelines, and may contain our opinions or interpretations of the Guidelines. There may be interpretations that are valid that differ from our interpretations and opinions. You are cautioned against placing undue reliance on our views and our educational materials.


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