The Treasury Department yesterday updated its frequently asked questions on the Small Business Administration’s Paycheck Protection Program to address several questions raised by ABA and member banks. Bankers should bookmark the Treasury FAQs, which will be regularly updated as Treasury addresses questions.

Among other topics, the newly added answers clarify:

• That lenders may rely on borrower certifications as to the applicability of affiliation rules.
• That lenders do not need to re-verify beneficial ownership information for existing customers. (If participating depository institutions have not yet collected beneficial ownership information on existing customers, they are not required to do so for those customers applying for PPP loans.)
• How payroll is defined under the CARES Act, including the calculation of non-cash benefits and coverage of paid leave.
• Methods for determining payroll to calculate maximum loan amounts.
• That lenders who processed applications based on the April 2 interim final rule may rely on the laws, rules and guidance available at the time.

ABA continues to seek guidance from Treasury and SBA, including on the use of promissory notes and the eligibility of bank directors for PPP loans, and will share updates with members as they become available. ABA has set up a dedicated email address, [email protected], for bankers to submit questions they may have about the PPP that are not addressed in the FAQs, or to report challenges they may be experiencing accessing SBA systems. Read the Treasury FAQs.