Deborah A. Hays
Partner
Overview
Representative Experience
Areas of Focus
News & Insights
10.01.2024
In the News
95 Years of Success - One Client, One Community, at a Time
Archer was featured in the SJ Magazine "Iconic Business" profile, "95 Years of Success - One Client, One Community, at a Time."
03.03.2022
Speaking Engagements & Seminars
Deborah Hays to Speak at CCSNJ'S "Family-Owned Business Council" Event
When: Thursday, March 3, 2022 (8:00 AM - 10:00 AM) (EST)
05.09.2020
Client Advisories
Important Notice Regarding Recent SBA Guidance Relative to Paycheck Protection Program Calculation of 500 Employee Limit and Foreign Affiliations
Recent guidance promulgated by the SBA has caused confusion among loan applicants and practitioners with regard to how the Paycheck Protection Program’s (PPP) employee size limitation is determined. The PPP is limited by the CARES Act to those businesses having 500 or fewer employees whose principal place of residence is in the United States, or meeting the SBA employee-based size standards for the industry in which the business operates (if greater). Guidance taking the form of Interim Final Rules and “Frequently Asked Questions” (FAQ) has up to this point offered a consistent interpretation as to how this limitation is calculated. However, a new “FAQ” was promulgated late this week which appears inconsistent with the component of previous guidance dealing with employees “whose principal place of residence is in the United States” and those of “affiliated entities.” Applicants for, and recipients of, PPP loans should carefully review the following information if they have foreign affiliates that could cause the overall combined number of employees to exceed the program’s 500 employee limit.