question.

The bill itself does say, "Paid and Incurred." However, does that mean that you cannot pay a bonus to your employees or pay them hazard pay during this time? Nothing says you can't and nothing says you can.

Most are waiting for interim guidance to come out from the Treasury on this very subject. However, if I were a betting man, I don't think we will see the guidance until after the May 18th safe harbor deadline for returning the PPP.

With that said, it will be interesting to see what will come out for a few reasons:

1. Small banks were massive contributors to the doling out process of the PPP loans. If there is a large reporting requirement on the back end that needs to be reviewed one by one for each loan, you are going to have a lot of banks that will frankly, 1) not have the capacity to do that, and 2) not be willing to do that on many of the smaller loans. Keep in mind that the bank received 5% or $1,000 on a $20k PPP loan. If they used an agent (CPA or attorney) they only received $800. They likely spent a fair amount of time on the front end (depending upon the bank) and if they have to spend a similar amount on the back end, you will have some very unhappy banks.

2. Congress' intent of this program was very clear - quickly disseminate money to businesses to prop them up in order to avoid laying off large amounts of people. In the application process, underwriting was almost completely eliminated based on the rules the Treasury provided (even though some banks just couldn't stop doing bank habits). There is a large push behind the scenes for the back end process to be easier rather than harder.

Good luck.