"Accrual-Based" 8 week period

[Edsel]

Bank is telling us the measurement period for PPP loan forgiveness begins the date the proceeds are received.  Not too difficult.

However, they are later telling us the documentation to apply for the forgiveness will need include payrolls that are "accrual based."  Not exactly apples and oranges if I understand accruals but they go on to explain that the documentation will have to be eight weeks of payroll based upon payroll actually paid.  Goes on to state that if payrolls are bi-weekly, they will accept four (4) such payrolls.

Example:  ABC has a period period beginning April 26 and ends May 9th.  Payroll for this period will be paid on May 15th.  Assume Loan Proceeds are received on May 1st - and beginning on that date employees may charge the forgiveness bucket.  However, the May 15th payroll will include some costs incurred prior to May 1st.

When time comes to apply for forgiveness, will they be expecting the entirety of the May 15th payroll to be submitted???

How do you interpret this???

[Lion EA]

The phrase I've been seeing is "incurred and paid" and not "accrued." I think the prohibition is that you can't prepay expenses, can't prepay payroll. But, not sure I've heard. And, the last I did hear the SBA is expected to clarify forgiveness regulations about 15 May. Not a helpful date since companies have been receiving their loans already! Really hard to plan, hard to advise our clients.