One requirement for an employer to participate in the small business loan program is that an employer does not have more than 500 employees. This brings up the question, for example, of whether employers with multiple locations must combine the employees from each location for the purposes of the 500 employee count, under the “affiliation rules.”
Based on bill-text interpretations by AICPA, we believe that employers with no more than 500 employees per physical location
still be able to participate in the small business loan program even if employee count across all locations exceeds 500. O’Connor & Drew continues to review the exceptions to the 500 employee count rule and has reached out for clarification. We will keep you updated on this issue.