SBA Releases PPP Forgiveness Instructions – AICPA Says Questions Still Remain

AICPA PPP Loan Frustration

The Treasury Department and Small Business Administration last night released a loan forgiveness application form for the CARES Act’s Paycheck Protection Program (PPP), which had been urgently sought by CPA firms and their small business clients in recent weeks.

The document and related instructions partially address some outstanding issues but leave others unaddressed and, more importantly, still do not provide enough flexibility for those who receive funds, according to the American Institute of CPAs.

The forgiveness application form does help address some administrative items such as providing additional clarity around “costs incurred but not paid” during the covered period, which is aligned with a recommendation by the AICPA.

However, significant issues remain. In particular, small businesses need flexibility on when the 8-week period should start or need to have the covered period extended to more than eight weeks.

“It’s clear the application form and instructions provided yesterday are not enough. Some of the most pressing issues are not addressed and in other areas it appears new questions have arisen.”


Erik Asgeirsson, president and CEO of, the AICPA’s business and technology arm

AICPA Says More Guidance Needed on PPP Loan Forgiveness

As the AICPA has emphasized throughout this process, questions surrounding guidance make critical decisions unnecessarily challenging and complex for PPP loan recipients and those who are considering applying for the program.

That’s why the AICPA created a loan forgiveness calculator this week that reflected both SBA guidance at the time and additional recommendations from the institute.

Both the calculator and the underlying recommendations were designed to create a commonly accepted approach to PPP loan forgiveness. They were made in consultation with an AICPA-led small business funding coalition whose members provide services and support to businesses that employ more than 75 million people.

“The AICPA loan forgiveness calculator provided more support and details than the SBA loan forgiveness application, and we will continue to encourage Treasury and SBA to leverage our recommendations. We will now reconcile our calculator with this form and publish an updated version with additional recommendations and direction for our 44,000 CPA firms.”


Mark Koziel, CPA, CGMA, the AICPA’s executive vice president of firm services

The updates to the AICPA forgiveness calculator are expected to be available by Monday. The revised calculator will be available at

Also, the AICPA will be reviewing in detail the loan forgiveness application along with our updated recommendations at the AICPA’s weekly Town Hall Meeting this Thursday.

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