Paycheck Protection Program (PPP) Audit Compliance

The US Treasury and Small Business Administration (SBA) have announced an official campaign to investigate recipients of Paycheck Protection Program (PPP) loans. Given the dollars at stake (over $517 billion in loans approved as of July 15th), these loan applications will be closely scrutinized.

Any borrower (or group of affiliated borrowers) that received loans is subject to review for loan eligibility and economic necessity and those borrowers that received loans in excess of $2 million dollars will automatically be reviewed. While the SBA has released several FAQs hinting at its criteria for the economic necessity of the loans, it has yet to issue clear guidelines. This lack of clarity seems to be by-design, allowing the SBA to evaluate any number of economic and business-specific factors when making its determination. The potential scope of these reviews, coupled with the spotlight on these loans, has borrowers understandably nervous. Fortunately, ZMF is here to help.

Armed with a team of former IRS executives and commissioners, experienced litigators, and tax specialists, ZMF has the expertise and insight necessary to help your business respond to a loan review. By working with ZMF your business will be prepared with the documentation and financial records necessary for such investigation and we will represent you through the investigation process.

ZMF services include:

• A complete review of the basis and related documentation for making the certification of economic uncertainty and need substantiating the application and eligibility for the PPP loan;
• A written deliverable providing a summation justifying the certification along with underlying documentation;
• Assistance with other issues around the application, forgiveness, and future investigation, including:
  • A review of eligibility;
  • A review of the forgiveness application;
  • Assessment of liquidity at the time of the loan;
  • Assistance on discrete legal issues such as affiliation;
  • Provide recommendations for the six (6) year record retention requirement; and
  • Representation before the Inspector General during an investigation.