Planning Ahead for Small Business Loan Relief
Information Requirements for Small Business Loans
The small business loan section of the CARES Act is a valuable provision offering loan forgiveness and favorable terms for amounts subject to repayment. Additional information on the procedural steps to obtain a loan are expected after the Act is signed, which may be as soon as today.

In the meantime, we encourage businesses interested in this loan program to begin putting together the following information as required in the Senate’s version of the Act:
Information which will help you calculate your maximum loan:
  • The following payroll costs* information covering the period of 4/1/19 through current.
  • Salaries, wages, commissions, up to $100,000 per employee
  • Cash tips or equivalent
  • Vacation, parental, family, medical, or sick leave
  • Allowance for dismissal or separation
  • Group health care benefits, including insurance premiums
  • Retirement benefits
  • State or local tax on compensation
  • Payments to independent contractors, up to $100,000 per contractor

Information which will be needed when you go to apply for the loan:
  • The following documents which cover from 2/15/19 through 2/29/20.
  • Payroll tax filings reported to the IRS & state, including unemployment
  • State income tax filings
  • Cancelled checks, payment receipts, transcripts of accounts or other documents verifying:
  • Mortgage obligations
  • Lease (rent) obligations
  • Utility obligations

  • The amount of the following expenses you expect the business to pay during the 8-weeks following obtaining the loan:
  • Payroll costs* (see above)
  • Interest expense on mortgage
  • Rent expense
  • Utilities expense

Information which will be relevant to calculating the amount of loan forgiveness:
  • The average monthly number of full time equivalent employees for the following periods:
  • 2/15/19 – 6/30/19
  • 1/1/20 – 2/29/20

Small Business 500 Employee Requirement
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 may 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.
Contact Us Today with Any Questions
Lauren A. Carnes, CPA
Tax Principal

O'Connor & Drew, P.C.
Ryan J. McDonell, CPA
Tax Manager

O'Connor & Drew, P.C.