As part of a larger relief package, Congress authorised $284.5 billion in new Paycheck Protection Program financing.
The new bill expands the types of businesses and industries that can take advantage of PPP loans.
Additionally, businesses that can prove a 25% decline in gross receipts year over year and meet other criteria may be eligible for a second PPP loan.
The conditions for forgiveness have altered since the programme began, as Congress has eased certain limits to provide small businesses more flexibility during this difficult time.
As a result of these modifications regarding what happens if you acquire two ppp loans, many small business owners are now unclear how to spend the loan revenues in order to qualify for forgiveness.
Unfortunately, fraud opportunities abound, and some small business owners may be unaware that their PPP fund methods are deceptive.
Table of contents
- How to Avoid PPP Loan Fraud
- When someone certifies something in good faith, what does it mean?
- Your Pre-Application Financials Should Be Documented
- Don’t Double-Dip with Tax Credits
- If necessary, return the loan
- Paying your employees in a lawful and regular manner is essential
- Ensure that each company only receives one loan
- Make use of the money you borrowed for working capital
- How PPP Fraud Impacts Lenders?
- Automated Verification Can Significantly Reduce PPP Fraud
- Documentation collection and verification
- Ensure that your reporting is clear and comprehensive
How to Avoid PPP Loan Fraud
Over the last two weeks, millions of small business owners, from independent contractors to CEOs of small businesses, have filed for Paycheck Protection Program loans.
Some of those business owners are now considering returning their PPP loans or hoping that their decision to take one was not fraudulent of what happens if you get two ppp loans.
The vast majority of business owners who will obtain a PPP loan can argue that they required it:
unemployment is at historic lows, demand is low, and restrictions on how firms can operate continue to be imposed in the wake of the coronavirus pandemic.
However, because of the ambiguity surrounding PPP use and forgiveness, many people are wondering if they qualify for one of these low-interest, forgiven loans of what happens if you get two ppp loans.
The Treasury was intended to release official instructions on PPP loan forgiveness 10 days after the CARES Act, which created the PPP, was passed. Instead, the agency has gradually sent out these instructions over several weeks.
The government released SBA Form 3508, the official loan forgiveness application, on May 15, although there are still issues about how the loans were used for what happens if you get two ppp loans.
This lack of information, combined with federal government announcements that the Treasury will audit and hold responsible enterprises who took out extra PPP loans.
It has produced concern and confusion about a programme that was supposed to be simple and uncomplicated for small business owners for what happens if you get two ppp loans.
We can't say for sure at this point what usage of the PPP outside of what was clearly mentioned as acceptable in the CARES Act would prompt an audit due to the lack of established guidelines.
Before and after getting your PPP loan, you should know about what happens if you get two ppp loans.
With the world, and hence the economy, effectively closing down last year, the Paycheck Protection Program ("PPP") proved to be a lifesaver for middle-market and smaller enterprises.
It saved many businesses and kept jobs by injecting cash into the economy for suitable applicants and what happens if you get two ppp loans.
The bulk of the beneficiaries inside these confluences obeyed the law and guidelines, got their money honestly and legally, and continued to operate throughout the pandemic.
Unfortunately, there will always be people who believe they are above the law and attempt to circumvent established norms and restrictions for what happens if you get two ppp loans.
These folks only start apologising once they've been found, typically claiming ignorance despite clearly abusing the loans.
However, there is still a lot of ambiguity around these loans, especially the Paycheck Protection Program for what happens if you get two ppp loans.
The PPP was the largest lending programme offered to businesses as part of the CARES Act.
Many business owners are also concerned about how they would legally distribute the funds and ask for loan forgiveness for what happens if you get two ppp loans.
Though their promise of simplicity was kept for the loan launch, it was not kept with their loan forgiveness rules for what happens if you get two ppp loans.
With over 4.4 million loans totalling over $500 billion to clear up in the following months and years, it will be quite a disaster.
For small business owners, we've put together a list of the best practises for PPP loans and how to make sure they're forgiven in full. Remember to get help from a lawyer as needed to protect your small business.
The Good Faith Certification should be looked at again.
People who want to apply for and get a PPP loan have to say that they need the money because of the current economy and think about what happens if you get two ppp loans.
When someone certifies something in good faith, what does it mean?
It means that the government wants you to be honest about your business and not take out a loan if you don't need it for what happens if you get two ppp loans.
There are a lot of PPP loan instructions that aren't very clear or easy to understand.
A public company with a lot of money and access to the capital markets, for example, isn't likely to be able to make the required certification in good faith. If the SBA asks, the company should be able to explain why it made the certification, what happens if you get two ppp loans.
As of the Treasury's most recent update to its Q&A, businesses with loans of less than $2 million would be judged to have made good faith efforts to show that they needed the loan.
The assumption is that businesses with this much debt aren't likely to have other sources of money. A lot of people don't get audited if their loan is less than $2 million, so this is why.
In contrast, businesses that take out loans of more than $2 million may be audited by the SBA for what happens if you get two ppp loans.
If the government finds that the borrower doesn't have a good case for a PPP loan, the borrower will have to pay back the money that was given to the business, what happens if you get two ppp loans.
Make sure you understand the language again, even if you've already taken out a PPP loan, to make sure you can say and prove that you need one.
You should pay attention to this phrase if you haven't applied yet but plan to. If you're not sure, go with the flow.
The new restriction prevents larger organisations with alternative sources of liquidity from monopolising the limited pool of funds for what happens if you get two ppp loans.
In response to claims that PPP funding was being awarded to businesses that had access to cash outside of the PPP, such as Shake Shack and the Los Angeles Lakers.
The finance Department emphasised the importance of PPP borrowers demonstrating in good faith that the loan is essential to keep the applicant's business running.
According to the rules, companies with high values and access to capital markets are unlikely to achieve that condition for what happens if you get two ppp loans.
Furthermore, the Justice Department has begun investigating companies to ensure that they did not apply to the programme with false information or what happens if you get two ppp loans.
Treasury Secretary Steven Mnuchin has stated that the Small Business Administration (SBA) will conduct a criminal liability audit on all PPP loans worth more than $2 million.
All loans are subject to scrutiny, although only larger loans are subject to a mandated audit, what happens if you get two ppp loans.
Instead, the good faith request implied that companies should only ask for and receive loans if they were actually in need. This, of course, left a great deal of open for interpretation.
Borrowers of SBA loans were previously needed to have applied for and been denied loans from other sources.
While this component of the application was removed from the requirements, the SBA nonetheless advised businesses to be ready to establish their loan eligibility at a later date for what happens if you get two ppp loans.
In either case, be prepared to provide adequate proof that your company required the financing. If you don't think you have enough proof, be prepared to pay the money back in full.
Your Pre-Application Financials Should Be Documented
According to the good faith certification language, the borrower must feel that present economic uncertainties makes this loan request vital to support the Applicant's ongoing operations.
The terminology is a little confusing here as well. How can you describe concepts like uncertainty and necessity that support you, your employees, and everyone's families in the context of your small business?
Although there is no clear definition, documenting how your finances and attitude changed as the pandemic expanded across the United States will help you demonstrate that the loan was necessary and that your situation was unforeseen.
Of course, a decline in sales or the need to lay off personnel should be documented in your company's bank statements and/or payroll records to avoid what happens if you get two ppp loans.
Emails with vendors or clients revealing decreases in business or material availability, as well as updated financial predictions, are all useful documents.
Similarly, you'll want to have your funds well-documented prior to applying for the loan. The good faith requirement of the PPP means that enterprises must demonstrate that the loan was essential and free from what happens if you get two ppp loans.
Of course, this is painfully ambiguous. What does necessary imply in your company? Is it possible to keep all of your current employees?
Are you planning to expand further? What about providing benefits to employees? Repaying outstanding debts?
As a result, we can only infer that you must be able to demonstrate that the COVID-19 epidemic had a direct financial impact on your company.
As a result, gather documents to document the situation. Bank statements, cancelled transactions, reduced orders from vendors and suppliers, and furloughed employees are examples of these.
Prepare these now so you'll be able to make them quickly if needed.
Create a separate bank account for the proceeds of the loan
There are a lot of questions about how to use a PPP loan to optimise loan forgiveness or even guarantee partial forgiveness.
Open a separate company bank account expressly for your PPP loan earnings, and use that account only for forgivable expenses.
This will make it much easy to keep track of your loan usage. Furthermore, because you cannot deduct expenses incurred with your PPP loan from your business taxes.
You won't have to sort through a single bank account to determine which expenses are deductible and which are not.
PPP loans were dispersed by banks, despite the fact that they were overseen by the SBA. Each small firm, including yours, was required to apply for the loan through their current bank.
So, if you haven't already, open a new business account with your bank to use solely for the money from the PPP loan.
As a result, your finances will be in better order, and you will be able to track every dollar of the loan.
This step will be crucial if you are audited to verify your good faith claim in the future, as it will save you a lot of time and headache.
Currently, businesses are unable to deduct any expenses incurred as a result of a loan from their taxes.
You won't have to go through your expenses one by one when paying your 2020 taxes if you use a separate bank account.
Don’t Double-Dip with Tax Credits
The concept of double-dipping appears to be one area where the government is particularly concerned about either fraud or general theft.
They don't want companies to use both a PPP loan and an employee retention credit to cut payroll costs during the pandemic, what happens if you get two ppp loans.
You are disqualified for a PPP loan if you decided that the employee retention credit, a payroll tax credit, was a better and more immediate source of assistance for your business.
You can accept both a PPP loan and an economic injury disaster loan (EIDL), but you can't use your EIDL to cover payroll costs because that's the main use case for a PPP loan.
If necessary, return the loan
If you've concluded that the PPP loan isn't necessary for your firm for whatever reason perhaps you've had a change of fortune or don't feel comfortable adhering to the present guidelines the government has allowed enterprises to return their loan funds.
Under the safe harbour provision, the time for returning your loan has been extended to May and think about what happens if you get two ppp loans.
If you return your loan proceeds to your lender by that date, you shouldn't have to worry about a call from the federal government regarding your decision to apply in the first place.
This is a tricky situation, made even more complicated by the fact that many of us are stressed out as a result of the pandemic's aftermath, what happens if you get two ppp loans.
If you're unsure how to get the most of your PPP loan, you're not alone ( what happens if you get two ppp loans).
Follow the tips above, examine the resources available, and make the best decisions for your business. The federal government's instructions should make things clearer in the coming days.
Keep a watch on the PPP loan details as they are continually updated and published, and chat to your lender about the best course of action.
In the next few months, small businesses should presumably have greater clarity.
Congress may amend the terms of forgiveness, interest on the loan if it is repaid, the amount that can be used for rent and mortgage payments, the length of time the loan can be utilised for, and other specifics.
Even the tiniest change is worth knowing about. Your bank is most likely to have the most recent information on the subject. Keep in touch with them on a regular basis to stay updated for what happens if you get two ppp loans.
Use banks as a resource to avoid PPP fraud or negligent use. Banks want to protect their clients and are likely to help you reduce your paperwork.
The majority of small firms will be eligible for loan forgiveness. To ensure that the full loan is forgiven, there are a few rules that must be met, including the elements indicated above.
Paying your employees in a lawful and regular manner is essential
Multiple allegations have surfaced of employers paying employees throughout the covered period, or increasing salary and/or working hours during the protected period, only to garnish payments later.
Employees who are worried about their jobs may not feel empowered to speak up and may feel pressured to agree with questionable employer requirements, but make no mistake:
this is not something you should be doing. Ensure that compensation policies are communicated and implemented in a clear, consistent, and lawful manner; do not depart from these in order to access PPP funding.
Ensure that each company only receives one loan
To enhance their chances of securing money, many businesses have applied for a PPP loan with multiple lenders.
You must, however, state in your application that you have not received and will not get another PPP loan.
As a result, you must be careful to accept ONLY ONE loan that corresponds to the tax information you provided (either your employer identification number, Social Security number, or your tax ID).
While this may seem obvious, audits have found that over a billion dollars in PPP funds have gone to enterprises who have taken out several loans.
It can be difficult to apply for PPP loans for many related enterprises. The rules differ depending on the overall number of employees, the industry, and other variables.
Make use of the money you borrowed for working capital
Many PPP applicants are unsure how flexible they can use PPP funding outside of payroll and other CARES Act-defined permissible costs.
While the CARES Act specifies which expenses are eligible for reimbursement, it is less apparent what expenses may be reimbursed if a small business is not seeking reimbursement.
Note that lenders may take different approaches to acceptable use, so check with your specific lender to learn what you can do with your PPP funds besides payroll and other approved expenses.
One thing that appears to be more obvious than ever is that people and businesses can excuse practically anything if it eventually serves their goals.
The rationalisation for the activities committed is, in general, a fundamental component for individuals who commit fraud.
When motive and opportunity are combined, it's no surprise that PPP fraud has been common, especially given the volatile and uncertain environment since 2020.
Those abusing the system, and frequently society, appear to grossly underestimate the cost of being caught. Both quantitatively and qualitatively, the cost is high.
When the public learns about the abuser, how will they react? It takes a lifetime to build a reputation, but only a moment to destroy it, as the saying goes.
The reputation argument is especially important for those who acquired loans legally but did not require them.
While the aforementioned abusers may be the loud minority, it is indisputable that PPP loans have been critical to the survival of many of the silent majority's businesses.
Despite the fact that some thriving businesses have rejected or returned their loans, believing they could exist without them, others have been saved by the cash infusions.
With the prospect of a second round of PPP forgiveness, applications are surging, and the government is stepping up efforts to combat debt and forgiveness fraud.
Due to the Small Business Administration's decision to discontinue Form 3509/2510, the Liquidity Justification Form, firms are encountering severe difficulty when requesting proof for PPP loans they have received.
Though it might be time consuming, this is an important step in confirming that all loans were spent properly to help prevent further fraud.
How PPP Fraud Impacts Lenders?
Federal law enforcement has identified 500 people, including some organised criminal organisations, who may have scammed the PPP programme as of September 2020.
The amount of money involved in this fraud has not been disclosed by the US government, other than to say that it was substantial.
Lenders are now required to collaborate closely with authorities in order to track down and identify these fraud situations.
Because the Department of Justice takes these fraud cases very seriously, this will be a very expensive process.
Banks and other lenders should be cautious moving forward because if Congress approves the next batch of cash for the PPP, it will likely be the last chance for enterprises to receive this special finance, which could lead to more fraud.
Lenders are being extensively scrutinised by lawmakers to see what they are doing to combat fraud.
The Small Business Administration (SBA) recommends avoiding the following types of PPP fraud.
Loan Agent Fraud
Loan agents help with SBA loan documentation and recommendations.
Lenders should keep track of loan agent participation, loan performance, inquire for references from other lenders, examine public databases for difficulties, and check Better Business Bureau records, according to the SBA.
They should also communicate directly with borrowers about their loans, applications, and loan agency fees, as well as use credible appraisers and title businesses they are familiar with, what happens if you get two ppp loans.
In other words, they shouldn't always follow the loan agent's advice.
When processing PPP loans, lenders must conduct due diligence to verify that borrowers or their loan intermediaries are not attempting to commit fraud.
Lenders can require borrowers to sign a good faith certification and review all bank records at closing to guarantee that the loan is put into accounts that are being used by the firm for the specified purposes.
Although lender fraud is uncommon, the SBA warns that it is something that all lending institutions should be aware of, what happens if you get two ppp loans.
To guarantee that correct lending standards are followed, the federal agency recommended that all lenders implement specific internal controls for what happens if you get two ppp loans.
Any possible fraud will be deterred by such actions. Lenders should thoroughly examine all documentation submitted by applicants or loan agents that appear to indicate fake loan equity to prevent fraud.
Gift letters, gift affidavits, promissory notes, bank statements, cashier checks, and other financial statements are examples of items that have been forged or manipulated, what happens if you get two ppp loans.
Lenders should also keep an eye out for bank statements that show unexplained large dollar deposits or evidence of applicants with poor credit histories declaring huge sums of cash on hand.
Other Red Flags for Fraud
The CARES Act included the PPP and Economic Injury Disaster Loans (EIDL) programmes to assist small companies in surviving the COVID-19 pandemic.
Legitimate businesses that are eligible for PPP funds will be able to demonstrate a need and a history of why they require money to help them stay afloat, remember what happens if you get two ppp loans.
Because PPP loans move swiftly after funds are issued, it's critical to create strong oversight to avoid a repeat of this situation if Congress permits further PPP loans.
Automated Verification Can Significantly Reduce PPP Fraud
To minimise PPP fraud, a lender can use an automated system to reduce the risks of being discovered in the middle of misleading operations and avoid what happens if you get two ppp loans.
The PPP solution from MicroBilt is a method that helps lenders avoid fraud. MicroBilt's purpose, as a consumer reporting agency, is to assist our clients in identifying and resolving risk in their business models.
We thought we could rapidly adapt our existing technology to small business underwriting of PPP loans because our platform has long been widely used in the consumer lending sector, what happens if you get two ppp loans.
The tedious processes associated with small business lending create an atmosphere in which it is difficult to detect fraud for what happens if you get two ppp loans.
Incorporating technology into the equation can dramatically improve the capacity to detect fraud fast for what happens if you get two ppp loans.
As a standalone or easy add-on solution, MicroBilt's technology enables lenders and banks to quickly gather, evaluate, and automate all essential application papers in real-time and prepare for future audits.
Ensure that process and system controls are in place
Return to the beginning and examine the initial PPP loan approval procedure to see if your institution has the proper controls in place for your forgiveness process.
Regardless of which technological solution was implemented, you must demonstrate that you conducted due diligence on your applicants and requests and that permissions were obtained through adequate risk management.
Determine which system and process controls were in place during the first PPP loan application:
Access to data
Which personnel have the authority to modify existing data in the system, as well as data entered by a loan applicant?
Employees cannot override locked fields from applicant data, which is an example of a system control.
To alter applicant information, additional fields can be added to the system, but the original information supplied by the applicant should be kept, what happens if you get two ppp loans.
Management should assess who has access to certain information while adhering to corporate regulations about structured access as the process control.
Field level control
When filling out the application, are the applicable fields compulsory or optional? Is the information in those fields correct?
Certain fields should be required to be filled out before an application may be submitted, according to a system control, what happens if you get two ppp loans.
Fields like EIN should also include logic that checks for the correct number of characters. There is no genuine process control because field control is enabled by a system.
Diligence on the applicant
Were the requirements for ID verification, ownership, and other KYC checks met? If all required entity data was not entered into the application, the system control should have been a hard stop.
The reviewer should have flagged anything missing or entity data that didn't match the type of entity applying for the funds as a process control, what happens if you get two ppp loans.
Documentation collection and verification
Were all of the required documentation acquired, including those demonstrating the usage of funds? And did the entity's appropriate representatives sign off on them?
If the document place holders were not filled, the system control should have been a hard stop, what happens if you get two ppp loans.
When compared to the signature card on file, the process control should have been the reviewer flagging documents signed by people who were not permitted signers for the company.
Approval process granting funds
Was the assessment of KYC information and collected documentation included in the approval procedure to ensure that the organisation qualified for the loan?
The reviewer's attestation that he or she looked at the relevant data and documents and that they were appropriate, as well as the system verifying that the reviewer had the proper degree of power to evaluate and approve, should have been the system control.
The process control should have been a system signoff confirming the loan application had been authorised by the reviewer, what happens if you get two ppp loans.
Additionally, for those institutions examining bigger loan amounts, a dual sign off requirement for loans of a particular magnitude by management level employees or above should have been added as an extra control.
You'll be able to ensure that you have the right controls in place for the forgiveness procedure once you've reviewed the suitability of the controls in place during the first application for PPP funds, what happens if you get two ppp loans.
If it turns out that one or more controls were absent or insufficient during the initial application process, you will need to strengthen controls throughout the forgiveness process to guarantee that funds are not misused.
These controls are similar to those used in the original application in some cases, but there will be some significant variations, what happens if you get two ppp loans.
Forgiveness differences in process and system controls
Documentation collection and verification
Were the correct papers obtained from the borrower to demonstrate/validate how the money were spent? If the document place holders aren't filled, the system control should be a hard stop.
The reviewer should indicate papers that don't match the money amounts and fund utilisation described in the forgiveness application as a procedural control.
Calculation of funds forgiven
Is the correct amount of money forgiven? The system's control is dependent on the system's calculations and math.
The forgiven amount should match what the system calculates based on the borrower's application submissions. There are two parts to the process control.
The first is that legal and/or regulatory approval should be obtained at the time of initial setup for the calculations used to arrive at the forgiveness amount.
Second, if the forgiveness amount is eventually different from what the system calculated, the discrepancy, as well as the explanation for it, must be logged in a separate field in the system.
Approval process for forgiveness
Was there a review of the necessary documents, computation, and verification as part of the approval process?
The reviewer's attestation that they looked at the necessary data and documents and that they were appropriate should be part of the system control, what happens if you get two ppp loans.
The process control should be a system signoff confirming the loan forgiveness application was authorised by the reviewer, what happens if you get two ppp loans.
This process, like the one before it, should include dual sign-off for loans of a specific magnitude.
Loan forgiveness amount decision
Is it being decided whether a portion or all of the loan will be forgiven? Any application that isn't being forgiven completely should be flagged by the system control for what happens if you get two ppp loans.
If these applications are highlighted, they should go through a different flow inside the system to be examined by a more senior member of the team, with dual signoff required.
Is the system generating standardised communications at crucial moments during the application process?
This communication should be sent to the correct contact in the system who is a liable party to the loan, according to the system control, what happens if you get two ppp loans.
Borrowers should receive emails when the application is completed/submitted, when papers are approved or refused, when the decision is made, and when the SBA forgiveness application is sent for what happens if you get two ppp loans.
Designing a communication flow that covers critical stages, such as password resets, submission confirmations, review, and confirmations, is the process control for this.
Is information delivered immediately to the SBA from your loan application system, or is it re-entered manually by team members?
To dramatically eliminate human error, the system control should build up integration with the SBA, what happens if you get two ppp loans.
Before delivering application data to the SBA, the process control should be a review of information and documentation.
Ensure that your reporting is clear and comprehensive
Once you've got the necessary controls in place, your institution needs to think about how it can make the most of the system's reporting capabilities.
This reporting should be conducted on a regular basis and utilised to communicate the volume of applications being filed and processed, as well as the monetary amounts being forgiven, to the appropriate teams and leadership for what happens if you get two ppp loans.
Reports can also be used to reduce risk by examining abnormalities in applications and/or owners, as well as fund destinations for what happens if you get two ppp loans.
By the time you've reviewed and implemented controls and reporting functionality, what happens if you get two ppp loans.
You should be able to sit across from an examiner and explain your institution's methodology for granting loans and forgiveness, as well as the controls in place to prevent fraud, and provide reports to back up your claims.
These reports will also serve as important evidence during an audit or examination for what happens if you get two ppp loans.
They can be used to demonstrate the bank's consistent handling of borrowers, demonstrate audit trails, and display the portfolio as a whole.
While reporting is typically used to respond to events, it can also be used as a detective control to warn you when anything is going on that shouldn't be.
Be aware that achieving the above has an impact that extends beyond reputational risk and fraud loss. For the first time, regulatory examinations will contain questions about PPP initiatives.
Use system reporting to make this easier and offer your examiners with concise and consistent information, what happens if you get two ppp loans.
Make a methodology statement that explains how you approached PPP lending and forgiveness.
Also, make sure that client data is properly housed so that when a sample of customer data is requested.
It can be quickly accessible and demonstrates the PPP process from start to finish as well as how it fits into the entire customer relationship.
When the PPP programme is through, the banks who have used the system controls, processes, and reporting that are available to them will have been the most successful in preventing fraud and passing tests.
It's the most efficient approach to control PPP risks while still staying out of the news.
To manage your costs and expenses you can use many available online accounting software.
- Many small business owners are now unsure how to spend the loan profits in order to qualify for forgiveness as a result of these changes for what happens if you get two ppp loans.
- Over the last two weeks, millions of small business owners, from independent contractors to CEOs of small businesses, have filed for Paycheck Protection Program loans.
- Emails with vendors or clients revealing decreases in business or material availability, as well as updated financial predictions, are all useful documents.
- People who want to apply for and get a PPP loan have to say that they need the money because of the current economy and think about what happens if you get two ppp loans.
- Of course, a decline in sales or the need to lay off personnel should be documented in your company's bank statements and/or payroll records to avoid what happens if you get two ppp loans.
- Furthermore, the Justice Department has begun investigating companies to ensure that they did not apply to the programme with false information or what happens if you get two ppp loans.
- Those abusing the system, and frequently society, appear to grossly underestimate the cost of being caught. Both quantitatively and qualitatively, the cost is high.
- Legitimate businesses that are eligible for PPP funds will be able to demonstrate a need and a history of why they require money to help them stay afloat, remember what happens if you get two ppp loans.
- Reports can also be used to reduce risk by examining abnormalities in applications and/or owners, as well as fund destinations.
- Make a methodology statement that explains how you approached PPP lending and forgiveness