CPAs as Agents for Small Business Administration Paycheck Protection Program (“PPP”) Loans
April 2, 2020
CAMICO has received numerous inquiries from policyholders regarding assisting clients with Paycheck Protection Program (“PPP”) loans.
Guidance promulgated by the Small Business Administration (“SBA”) earlier this week created some confusion regarding the accountant’s role and whether accountants are considered “agents” or “authorized representatives” when performing these services.
CPAs who assume the role of an “agent” or an “authorized representative” will create conflict of interest and independence impairment issues. We do not believe the promulgated guidelines are intended to define accountants as agents in all instances when assisting borrowers with the application process.
The AICPA Statement on CPAs as Agents for PPP Loan Applications reinforces CAMICO’s best-practices guidance for assisting clients with these applications.
CAMICO has developed the following engagement letter templates and sample response to lenders for your reference:
As always, please contact CAMICO if you have any risk management questions or if you have coverage-related questions were you to assume an “agent” or “authorized representative” role.