The report (Total Payroll Expense by Month) has been updated so payroll costs do not exclude federal employment taxes or federal income taxes on employees withheld by the employer. We encourage anyone that ran this report before this communication to re-run their report, and to do so as close in time as possible to submitting their application to their lending institution. As a result of this change in the method of calculation, your clients could be eligible for a higher PPP loan amount than if you ran a report before this communication. If any of your clients already filed their loan application, they should work with their lender to determine how they can amend their loan application to submit this updated information.
It is a broad piece of legislation, however there are three important components introduced that impact how you serve your clients: Family and Medical Leave Act (FMLA) expansion, Emergency Paid Sick Leave, and Tax Credits for Paid Sick/FMLA. The legislation takes effect no later than April 2, 2020 and will be sunset on December 31, 2020.
Our intent is to best equip you with the ability to enable these new requirements, however, the Federal government doesn’t consider how it will be implemented, tracked, and reported. It would behoove you to set the expectations with your clients that this legislation is not cut and dry and there likely will be some manual cleanup at some point in the future.
Please keep in mind that the Senate introduced the Coronavirus Aid, Relief, and Economic Security Act (Cares Act) that, if passed, will make changes to the FMLA/Paid Sick leave provisions.