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Attention PPP Borrowers: Your SBA Audit Is Lurking Just Around the Corner

November 10, 2020

Bryan Johnson will present the webinar "Attention PPP Borrowers: Your SBA Audit Is Lurking Just Around the Corner," hosted by M&R on November 10, 2020 at 11:00AM CT. 

If your company has secured a loan pursuant to the Paycheck Protection Program for $2 million or more, the fact that auditors from the Small Business Administration will be knocking at your door is not an “if,” but a “when” proposition. The SBA in consultation with the U.S. Treasury Department has issued guidance in the form of Frequently Asked Questions explicitly stating that all PPP loans in excess of $2 million will be reviewed following a lender’s submission of a borrower’s loan forgiveness application.

For those that have received south of $2 million in PPP proceeds, now is not the time to be breathing a sigh of relief—you may be in line for audit as well given Treasury’s Interim Final Rule released on June 1 stating, “[f]or a PPP loan of any size, SBA may undertake a review at any time in [its] discretion.”

As PPP loan audits are inevitable for so many borrowers, the time is now to begin preparations. In this webinar—“Attention PPP Borrowers: Your SBA Audit Is Lurking Just Around the Corner”—Bryan Johnson, who leads Michelman & Robinson’s standalone COVID-19 Practice Group, provides the information you need to place your business in the best possible position to respond to and effectively defend against the PPP audits that we all know are on the horizon.


  • The buck stops here: appointing a PPP audit point person
  • P is for payroll: getting your payroll records organized and ready for review
  • Call my lawyer: strategic alignment of professional service providers
  • The proof is in the pudding: preparing your evidence, documentary and otherwise
  • Playing defense: explaining away potentially damaging documents and information