AICPA Addresses Ethical Considerations in Covid-19 PPP Program

• Assisting an attest client with a COVID-19 PPP loan application is a nonattest service. If CPAs comply with the interpretations of the Nonattest Services subtopic, independence will not be impaired.
• The majority of the certifications and authorizations  contained in the “Representations, Authorizations and Certifications” section of the PPP loan application are management responsibilities; the signature required on page 2 of the application should be made by the company applying for the loan or its authorized representative.  Accordingly, signing as a client’s authorized representative will impair independence because you have accepted the ability to exercise authority on behalf of a client. This is a management responsibility. Note: Before signing a PPP loan application for your attest client, you may want to consult with your professional liability carrier or legal counsel to understand any legal implications signing the PPP loan application.
• The agent fee arrangement outlined in Treasury’s “Paycheck Protection Information Sheet for Lenders” is not considered a contingent fee because the fee will be determined by Treasury.
• If you obtain a PPP loan from a lender that is an existing attest client, independence will be impaired.

Because the PPP is a new program, we may add updates and additional guidance to this page as we learn further details.  

As of April 1, 2020

• Assisting an attest client with a COVID-19 PPP loan application is a nonattest service. If CPAs comply with the interpretations of the Nonattest Services subtopic, independence will not be impaired.
• The majority of the representations contained in the “Representations and Authorization” section of the PPP loan application are management responsibilities; the two signatures required on page 2 of the application should be made by the company applying for the loan. 
• The agent fee arrangement outlined in Treasury’s “Paycheck Protection Information Sheet for Lenders” is not considered a contingent fee because the fee will be determined by Treasury and SBA.
• If a member obtains a PPP loan from an existing client, independence will be impaired.

Because the PPP is a new program, we may add updates and additional guidance to this page as we learn further details.