Paycheck Protection Program: New FAQ Addresses Retroactive “Economic Uncertainty” Certification Requirement and May 7, 2020 Safe Harbor

On April 24, 2020, the Paycheck Protection Program (PPP) and Health Care Enhancement Act were signed into law. The Act includes an additional $310 billion for the PPP, which ran out of funds in mid-April. The additional funds will allow small business an opportunity to obtain potentially forgivable loans.
On April 23, 2020, the Small Business Administration (SBA) and the U.S. Department of Treasury issued further guidance on its PPP, which included adding Question 31 to its Frequently Asked Questions (FAQ), as detailed below.

  1. Question: Do business owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?

Answer: In addition to reviewing applicable affiliation rules to determine eligibility, all borrowers must assess their economic need for a PPP loan under the standard established by the CARES Act and the PPP regulations at the time of the loan application. Although the CARES Act suspends the ordinary requirement that borrowers must be unable to obtain credit elsewhere (as defined in section 3(h) of the Small Business Act), borrowers still must certify in good faith that their PPP loan request is necessary. Specifically, before submitting a PPP application, all borrowers should review carefully the required certification that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” Borrowers must make this certification in good faith, taking into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business. For example, it is unlikely that a public company with substantial market value and access to capital markets will be able to make the required certification in good faith, and such a company should be prepared to demonstrate to SBA, upon request, the basis for its certification.

Lenders may rely on a borrower’s certification regarding the necessity of the loan request. Any borrower that applied for a PPP loan prior to the issuance of this guidance and repays the loan in full by May 7, 2020 will be deemed by the SBA to have made the required certification in good faith.

Pursuant to the new guideline, a borrower must certify that the “economic uncertainty” renders the PPP loan “necessary to support the ongoing operations” of the borrower. In determining if the PPP loan is necessary, a borrower should consider “their ability to access other sources of liquidity,” which is retroactive. In other words, both potential borrowers and borrowers who have already secured funds, must consider alternative sources of funds, especially if the borrower (or potential borrower) is a public company.

Captain Cooks Casino: Canadian Winners and Their Stories

Are you ready to hear about the incredible success stories of Canadian winners at Captain Cooks Casino? This online gambling platform has been making waves in the gaming industry, attracting players from all over Canada with its exciting games and lucrative rewards. From life-changing jackpot wins to impressive cash prizes, Canadian players have been reaping the benefits of their gaming skills and luck at Captain Cooks Casino. In this article, we will delve into the fascinating stories of some of these winners and explore the reasons behind their incredible success.

What if you could turn a small bet into a life-altering fortune? Imagine hitting the jackpot and becoming an instant millionaire. For many Canadian players at Captain Cooks Casino, this dream has become a reality. With a wide range of thrilling games and generous promotions, this online casino has become a hotbed for big wins. But what sets these Canadian winners apart? Is it their strategy, luck, or a combination of both? Join us as we uncover the secrets behind their success and celebrate the triumphs of these lucky players at Captain Cooks Casino.

Uncovering the Success Stories: Real Canadian Winners at Captain Cooks Casino

Captain Cooks casino Canada has been a hub of excitement for Canadian players, with numerous winners and their captivating stories. One such winner is John from Toronto, who struck gold with a massive jackpot of $1 million while playing the popular Mega Moolah slot. John couldn’t believe his luck when the reels aligned, instantly transforming his life and fulfilling his dreams. His story serves as an inspiration to many aspiring players, showcasing the incredible possibilities that Captain Cooks Casino Canada offers.

Another remarkable tale comes from Sarah, a resident of Vancouver, who turned a $50 deposit into an astonishing $100,000 win. Sarah’s dedication and strategic gameplay paid off when she hit a series of impressive wins on various table games, including blackjack and roulette. Her incredible journey at Captain Cooks Casino Canada is a testament to the thrilling experiences and life-changing opportunities that await players.

From Rags to Riches: How Captain Cooks Casino Changed the Lives of Canadian Players

At Captain Cooks Casino, Canadian players have been winning big and creating their own incredible success stories. One such winner is Sarah from Vancouver, who hit the jackpot playing Mega Moolah and walked away with an astonishing $5 million! Sarah couldn’t believe her luck when the reels aligned, and her life was forever changed. With her winnings, she was able to pay off her mortgage, take her dream vacation to Europe, and start her own business. Sarah’s story is a testament to the life-changing opportunities that Captain Cooks Casino provides to its players.

Another Canadian winner who struck it big at Captain Cooks Casino is Mark from Toronto. After playing a few rounds of Blackjack, Mark ended up winning over $100,000 in a single night. The unexpected windfall allowed him to pursue his passion for photography full-time. Mark invested in top-of-the-line camera gear and established his own photography studio, capturing breathtaking images and turning his hobby into a successful career. His remarkable journey from a hobbyist to a professional photographer is a testament to the life-changing experiences that Captain Cooks Casino can offer to its players.

Tales of Triumph: Inspiring Stories of Canadian Gamblers Who Struck It Big at Captain Cooks Casino

Captain Cooks Casino is renowned for its thrilling online gambling experience and the opportunity it offers players to win big. Canadian players, in particular, have had their fair share of incredible wins and captivating stories at this popular online casino. One such story is that of Sarah M., a lucky player from Ontario who won an astonishing $1.9 million on the Mega Moolah progressive jackpot slot. Sarah’s life-changing win came as a complete surprise, and she plans to use her newfound fortune to travel the world and fulfill her dreams.

Another remarkable Canadian winner at Captain Cooks Casino is Thomas B., a resident of British Columbia who struck gold with a $1.4 million win on the Treasure Nile slot. Thomas had been a regular player at the casino for years and couldn’t believe his luck when he hit the jackpot. With his winnings, he plans to pay off his mortgage and treat his family to a well-deserved vacation. These stories of Canadian winners at Captain Cooks Casino are just a glimpse of the exciting and rewarding experiences that await players at this top-notch online casino.

Behind the Scenes: Exploring the Strategies and Experiences of Canadian Winners at Captain Cooks Casino

Captain Cooks Casino has been a popular online gambling destination for Canadian players, offering a wide range of exciting games and the opportunity to win big. Over the years, many Canadian players have struck it lucky at the casino, with their stories of success becoming the stuff of legends. One such winner is Sarah from Vancouver, who hit the jackpot on the Mega Moolah slot game, taking home a whopping $5 million. Sarah couldn’t believe her luck and plans to use her winnings to fulfill her lifelong dream of traveling the world.

Another incredible story comes from Mark, a construction worker from Toronto, who turned a small bet into a life-changing win. Playing the progressive slot game Treasure Nile, Mark won an astonishing $2.5 million. With his newfound wealth, Mark plans to invest in his own construction business and secure a better future for his family. These inspiring stories of Canadian winners at Captain Cooks Casino serve as a testament to the thrilling possibilities that await players at this reputable online casino.

Beyond the Jackpot: The Lasting Impact of Captain Cooks Casino on Canadian Winners’ Lives

Captain Cooks Casino has been making headlines in Canada with its impressive roster of winners and their incredible stories. From life-changing jackpot wins to thrilling adventures, these Canadian players have had their lives transformed by the online casino. Let’s take a closer look at some of the remarkable stories that have emerged from Captain Cooks Casino.

One of the most unforgettable tales comes from a player named Sarah, who won a mind-boggling $5.9 million on the popular progressive slot game, Mega Moolah. Sarah, a regular player at Captain Cooks Casino, couldn’t believe her luck when the jackpot symbols aligned on her screen. With her newfound fortune, she was able to fulfill her lifelong dream of traveling the world and even started her own charity to help those in need.

Another lucky Canadian, David, struck gold when he won an impressive $1.5 million playing the popular game, Cash Splash. David had been a loyal player at Captain Cooks Casino for years and his perseverance paid off in a big way. With his winnings, he was able to pay off his mortgage, take his family on a dream vacation, and invest in his children’s education.

And then there’s Mike, a construction worker from Ontario, who hit the jackpot on the game Treasure Nile, winning a staggering $2.3 million. Mike had always dreamed of owning his own business, and with his newfound wealth, he was able to turn that dream into a reality. Today, he runs a successful construction company and credits Captain Cooks Casino for giving him the opportunity to change his life.

As we have explored the stories of Canadian winners at Captain Cooks Casino, it is clear that this online gaming platform has provided countless opportunities for players to strike it big. From the heartwarming tale of Mark, who used his winnings to support his family and pursue his dreams, to the astonishing luck of Lisa, who turned a small bet into a life-changing jackpot, these stories showcase the thrill and excitement that can be found at Captain Cooks Casino. With a wide range of games to choose from and a reputation for fairness and reliability, it’s no wonder that so many Canadians have found success at this popular online casino. Whether you’re a seasoned player or new to the world of online gambling, Captain Cooks Casino offers a chance for everyone to win big and create their own incredible story. So why wait? Join the ranks of Canadian winners today and see where your luck takes you!

The SBA has provided a safe harbor repayment period until May 7, 2020. This means that any borrower that applied for the PPP before April 23, 2020, and the new retroactive guidelines have changed the validity of their application, may repay their loan (in full) by May 7, 2020 to avoid legal consequences for false certifications or statements.

Borrowers and potential borrowers should consider (or reconsider) their applications carefully taking into account the new “economic uncertainty” certification requirement.
Please contact your Ward and Berry lawyer if you need assistance complying with the requirements of the Paycheck Protection Program.