Important Paycheck Protection Program Bulletin

Important Paycheck Protection Program Bulletin

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SBA PPP LOAN FORGIVENESS RULES

By Matthew L. Austin, Managing Director | Keiter Advisors

Offer to Re-Hire and Reporting a Rejection of Re-Hire to the State Unemployment Commission

The Treasury specified in its Interim Final Rule that a borrower’s loan forgiveness amount will not be reduced if an employer makes an offer to re-hire an employee during the covered period for the same salary and same number of hours as earned by such employee in the last pay period prior to the separation and that offer is rejected by the employee. There were several additional requirements specified by this interim final rule, including:

  • The borrower has to maintain records documenting the offer and its rejection
  • The borrower must inform the applicable state unemployment insurance office of such employee’s rejected offer of reemployment within 30 days of the employee’s rejection of the offer.

It is this last requirement to notify the state unemployment insurance office which is of note, as it creates additional responsibilities for the employer/borrower in order to obtain the re-hire exemption outlined above. Forms to notify the commission can be found on the Virginia Employment Commission’s site. If an employer has employees in other states, we encourage them to consult with the state unemployment insurance offices as soon as possible.

We believe it is an important requirement to notify the relevant state office(s) if a borrower intends to utilize the benefits of the rejected offer in the calculation of loan forgiveness.

If you have questions, we encourage you to reach out to your Keiter team member, Scott Zickefoose, Zach Webber, or Matt Austin.

 

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About the Author

Matt Austin, Managing Director of Keiter Advisors, brings a desire to help clients through strategic business changes and is passionate about creating new insights that help businesses operate better and financially prosper. He enjoys working with people, is fascinated about data and enjoys rolling up his sleeves in any capacity. Matt began his career as an analyst with BB&T Capital Markets, focusing primarily on mergers & acquisitions. After BB&T Capital Markets, he worked with Virginia Capital Partners, LLC, a small Richmond based private equity firm where he focused on transactions in a variety of sectors including specialty consumer services, traditional media, wireless communications, specialty insurance, and healthcare.

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The information contained within this article is provided for informational purposes only and is current as of the date published. Online readers are advised not to act upon this information without seeking the service of a professional accountant, as this article is not a substitute for obtaining accounting, tax, or financial advice from a professional accountant.

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