The SBA added two new questions to their first FAQ on Payroll Protection Loans,[1] dealing with the impact on paying or not paying agent fees on the SBA’s guarantee of a PPP loan or the payment of fees to the lenders and on insurance that qualifies as a health care benefit for forgiveness.

Impact of Payment of Fees on Lenders

The FAQ provides the following assurance to lenders that the payment or nonpayment of fees to an agent or other third party will not impact the SBA guarantee of a PPP loan or payment of fees to lenders:

50. Question: What effect does the payment or nonpayment of fees of an agent or other third party have on SBA’s guarantee of a PPP loan or SBA’s payment of fees to lenders?

Answer: The payment or nonpayment of fees of an agent or other third party is not material to SBA’s guarantee of a PPP loan or to SBA’s payment of fees to lenders. Additional information about such fees can be found in paragraph III.4.c of the initial Paycheck Protection Program interim final rule.[2]

The answer links to the discussion of agent fees at https://www.govinfo.gov/content/pkg/FR-2020-04-15/pdf/2020-07672.pdf.

Health Care Benefits

The final question provides clarification on what is considered a health care benefit that would qualify as a payroll cost for forgiveness:

51. Question: Do payments required for the provision of group health care benefits, including insurance premiums, include vision and dental benefits?

Answer: Yes.[3]

[1] Paycheck Protection Program Loans Frequently Asked Questions (FAQs), Small Business Administration, August 11, 2020 Revision, https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf (retrieved August 12, 2020)

[2] Paycheck Protection Program Loans Frequently Asked Questions (FAQs), Small Business Administration, August 11, 2020 Revision, Question 50

[3] Paycheck Protection Program Loans Frequently Asked Questions (FAQs), Small Business Administration, August 11, 2020 Revision, Question 51