Important ethical implications to consider in connection with COVID-19 PPP loan applications.
As of April 1, 2020
- Assisting an attest client with a COVID-19 PPP loan application is a nonattest service. If CPAs comply with the interpretations of the Nonattest Services subtopic, independence will not be impaired.
- The majority of the representations contained in the “Representations and Authorization” section of the PPP loan application are management responsibilities; the two signatures required on page 2 of the application should be made by the company applying for the loan.
- The agent fee arrangement outlined in Treasury’s “Paycheck Protection Information Sheet for Lenders” is not considered a contingent fee because the fee will be determined by Treasury and SBA.
- If a member obtains a PPP loan from an existing client, independence will be impaired.
Because the PPP is a new program, we may add updates and additional guidance to this page as we learn further details.