The Small Business Administration (SBA) has released new guidance regarding the good-faith certification for Paycheck Protection Program (PPP) loans.

On May 13th, 2020, the SBA established a “safe harbor” for borrowers receiving PPP loans with an original principal amount of less than $2 million.

The new safe harbor was made by adding “FAQ 46” to the SBA’s previously-issued PPP guidance. FAQ 46 provides that any borrower which, together with affiliated entities, receives PPP loans with an original principal amount of less than $2 million “…will be deemed to have made the required certification concerning the necessity of the loan request in good faith.”


Borrowers whose PPP loans over the $2 million threshold may be subject to review by the SBA for compliance with program requirements, including the certification of economic need.

Please contact John Priola with any questions regarding your organizations PPP loan and the safe harbor rule.


Reynolds + Rowella is a regional accounting firm known for a team approach to financial problem solving. As Certified Public Accountants, our partners foster a personal touch with our clients. As members of DFK International/USA, an association of accountants and advisors, our professional network is international, yet many of our clients have known us for years through the local communities we serve.

The firm has offices at 90 Grove St., Ridgefield, Conn., and 51 Locust Ave., New Canaan, Conn. For more information, give us a call at 203.438.0161 or email us.


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