I have watched in wonder as the SBA has, week-by-week, materially changed the terms of the PPP loan program. I have spoken to many borrowers who diligently read the PPP loan rules in effect at the time they filed their application but are now trying to figure out how and whether they can comply with new sets of rules. They are confused and frustrated. Sometimes they state the obvious: “How can the SBA do this?” It’s what I am thinking too.
But, like it or not, this is where small business owners find themselves.
Choice One: Cross your fingers, hope that nothing but forgiveness comes of your forgiveness application request.
Choice Two: Be proactive, seizing on what clues the SBA has provided and using those to build a solid, documented defense of the necessity of the loan and an analysis of the borrower’s current business activity. The subjective elements of the needs analysis create an opportunity for borrowers to use what only they know about their own business and the markets in which they operate to construct an honest, compelling narrative for their forgiveness application.
We think Choice Two is the only choice, and so do our clients.