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JohnH

PPP / EIDL Disclaimer - Any thoughts?

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I've become very circumspect about giving advice or opinions about PPP loan forgiveness compliance.  I even accidentally posted a rumor on another site in the midst of warning about internet advice based on rumors.  😊  

Anyhow, I'm beginning to think it might be a good idea to come up with a special disclaimer when discussing PPP with clients.  I don't want someone's PPP loan forgiveness to fail in part or in total because they acted on something I said (or something they thought I said).

There's just too much at stake with this PPP loan forgiveness.  Does anyone here share those concerns and do you have any thoughts on what a special disclaimer may look like? 

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"Since the Treasury Department and the Small Business Administration is making this up as they go along,

any advice that I give you is subject to change and should not be used to make any decisions."

🤐This is tongue in check, unfortunately it's also reflects the situation that we are in.

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Yes, I'm concerned about it.  I have one that is constantly bugging me with questions that I continue to tell him I don't have the answers and that guidance and clarifications haven't been issued for the specific questions he is asking.

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I did have one humorous conversation with a friend (not a client).  We were discussing an issue of his which is similar to an issue of mine.  I finally said something to this effect:

 "I'm telling you what I'm doing, but I'm not telling you that you should be doing what I'm doing.  I may suddenly change what I'm doing if I get different info from the SBA. And I can't promise I'll remember to tell you I changed what I'm doing because I may not even remember this conversation a week or more from now.  So take this conversation for what it's worth." 

He responded "I get it and I appreciate your honesty"    (I'm sure in the back of his head he was thinking "I need to keep asking John what he's doing about this.")

 

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My short answer (or the final words in any longer answer) seem to be, "Ask your banker." I tell people (clients and non) that their banker/lender will interpret the SBA regulations re their specific loan. I remind people we do not expect SBA guidance until the middle of May. And, of how many, many times things have changed so far this year!

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