Paycheck Protection Program

May 21, 2020

So you’ve retained funds provided under the SBA Paycheck Protection Program in the CARES Act. What next?

We’ve compiled a checklist to maintain your compliance with the program’s conditions and reduce the risk of audit issues, government investigations and potential civil liability.


Segregate funding received under the Paycheck Protection Program

Consider maintaining the proceeds from the PPP loan in a separate bank account than accounts used for non-COVID-19 relief purposes. This will instill discipline in using the funds only for qualified purposes. Although a separate account is not required under the law, it will make responding to any subsequent audit or government investigation, if one occurs, that much less painful and will also demonstrate strong compliance in using and accounting for the funds.

Download the Paycheck Protection Program Checklist.

Foley Hoag has formed a firm-wide, multi-disciplinary task force dedicated to client matters related to the novel coronavirus (COVID-19).  For more guidance on your COVID-19 issues, visit our Resource Portal or contact your Foley Hoag attorney.