The SBA recently released question #46 in the frequently asked questions in regards to PPP. Loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith and will be safe harbored from SBA review.
Borrowers in excess of $2 million may still have adequate basis in making the good faith certification but will be subject to review as previously stated by the SBA. If the SBA determines that the borrower did not have reasonable basis to receive the funds, the SBA will seek repayment and the borrower will not be eligible for loan forgiveness. The SBA will not pursue administrative enforcement if the funds are returned based on its determination of the certification.
Please click here to view the full Q&A.