{"content":[{"text":"October 9, 2020","bbox":{"left":0.436634,"top":0.144109,"width":0.12707200000000002,"height":0.020212000000000008}},{"text":"The Honorable Marco Rubio \n Chairman \n Committee on Small Business & \n Entrepreneurship \n U.S. Senate \n Washington, DC 20510","bbox":{"left":0.117686,"top":0.178957,"width":0.256687,"height":0.10751000000000002}},{"text":"The Honorable Nydia M. Velazquez \n Chairwoman \n Small Business Committee \n U.S. House of Representatives \n Washington, DC 20515","bbox":{"left":0.529608,"top":0.178957,"width":0.28582300000000005,"height":0.08993399999999999}},{"text":"The Honorable Benjamin L. Cardin \n Ranking Member \n Committee on Small Business & \n Entrepreneurship \n U.S. Senate \n Washington, DC 20510","bbox":{"left":0.117686,"top":0.301104,"width":0.279432,"height":0.10721900000000001}},{"text":"The Honorable Steve Chabot \n Ranking Member \n Small Business Committee \n U.S. House of Representatives \n Washington, DC 20515","bbox":{"left":0.529608,"top":0.283528,"width":0.24022900000000003,"height":0.08990900000000002}},{"text":"Dear Chairman Rubio, Chairwoman Velazquez, and Ranking Members Cardin and Chabot:","bbox":{"left":0.117686,"top":0.42296,"width":0.719056,"height":0.020212000000000008}},{"text":"I am writing to seek your assistance in correcting a situation involving forgiven Paycheck \n Protection Program loans that could negate the critical assistance provided to engineering firms \n and other industries that contract with government agencies.","bbox":{"left":0.117686,"top":0.457808,"width":0.748533,"height":0.05508599999999997}},{"text":"Thousands of engineering firms have applied for and received a PPP loan, which has been an \n important lifeline during this turbulent economic period. Thank you for your support for this \n vital program. Many of those firms are now planning to apply for loan forgiveness, consistent \n with the CARES Act and the implementing rules from the Small Business Administration and \n the Treasury Department.","bbox":{"left":0.117686,"top":0.52753,"width":0.74002,"height":0.08993499999999999}},{"text":"However, it has come to our attention that a provision of the Federal Acquisition Regulation \n (FAR) for government contractors could substantially undercut the benefits of the loan program \n by requiring firms that qualify for forgiveness to return some portion of the loan as a credit when \n working for a federal agency. Such a policy appears to be contrary to congressional intent and \n the core purpose of the forgivable loan program. We respectfully ask for your assistance to \n clarify that the FAR credits clause (FAR 31.201-5) will not apply to the proceeds of PPP loans \n for small business government contractors who have properly qualified for loan forgiveness.","bbox":{"left":0.117686,"top":0.632101,"width":0.7610560000000001,"height":0.12479499999999999}},{"text":"A strict reading of the FAR could require a firm contracting with the government to calculate a \n credit to their indirect costs (overhead) in the amount of a forgiven PPP loan. If an engineering \n firm has to issue a credit to their indirect cost rate for 2020 for the amount of a forgiven PPP \n loan, they would be billing at a much lower rate in 2021 – and potentially in subsequent years, in \n the case of multi-year contracts. Requiring a credit from a small business government contractor \n who has properly qualified for loan forgiveness essentially requires them to repay the loan \n through such credits. The loan is thus not forgivable, contrary to the intent of the PPP program","bbox":{"left":0.117686,"top":0.771533,"width":0.760458,"height":0.12478500000000003}}],"images_bbox":[{"left":0.358824,"top":0.045455,"width":0.282141,"height":0.082702}],"images_bbox_not_text_overlap":[{"left":0.358824,"top":0.045455,"width":0.282141,"height":0.082702}]}