The Small Business Administration (SBA) has issued additional guidance to address borrower and lender questions concerning the implementation of the Paycheck Protection Program, which was authorized in the CARES Act. Borrowers and lenders may rely on the guidance provided in this document as SBA’s interpretation of the program.
In reviewing the FAQs, note that Question 9 may be especially useful for some employers with a seasonal workforce:
Question: My small business is a seasonal business whose activity increases from April to June. Considering activity from that period would be a more accurate reflection of my business’s operations. However, my small business was not fully ramped up on February 15, 2020. Am I still eligible?
Answer: In evaluating a borrower’s eligibility, a lender may consider whether a seasonal borrower was in operation on February 15, 2020 or for an 8-week period between February 15, 2019 and June 30, 2019.
Click here to access the SBA Paycheck Protection Program Loans FAQs.