Small Business Roundtable Sends Letter to the Treasury Department and SBA on PPP Guidance

The Honorable Steven T. Mnuchin 
Secretary of the Treasury
U.S. Department of the Treasury 
1500 Pennsylvania Ave NW
Washington, DC 20220

The Honorable Jovita Carranza
Administrator
U.S. Small Business Administration
409 3rd Street, SW
Washington, DC 20416



Dear Secretary Mnuchin, Administrator Carranza:

On behalf of the organizations representing this nation’s 30 million small businesses we write to
you today with an urgent request for clarity around the Paycheck Protection Program, as detailed
by your guidance released yesterday. We ask for consideration or clarification of the following
points (listed in no particular order):

These Funds May Not Prove Enough
While the amount provided to the Small Business Administration is limited by statute, we are
immediately concerned that this may not be enough funding to support American small businesses
during this time. We have seen in some states an extension well into June of conditions that
effectively prevent business operation. In the guidance, the Department alludes to this challenge,
indeed, suggesting a new limitation on the program (more below).

Chairman Rubio has already acknowledged that additional funds may be necessary, but that this
will likely remain the structure to do so. We will take these concerns to Congress in hopes that
additional resources may be made available.

Arbitrary Loan Terms May Harm Businesses by Limiting Bank Participation
While the legislation set broad caps on loan terms (4% interest rate and 10 year loan maturity), we
are seeking clarity on the Department’s decision to set the rate at 0.5% (50 basis points) and a loan
term of two (2) years.

The Role of Minority and Community Lenders
We are asking for additional clarity on the eligibility for minority-owned and community banks.
Are these banks deemed eligible for the program, but must receive delegated authority from SBA?
Is additional guidance from SBA expected prior to the program launch date of April 3, 2020? Are
existing 7(a) Community Advantage, 504 and microlenders deemed eligible or should they also
pursue delegated authority? Can CDFI be included in this section as they are a major link to other
lenders in LMI communities? Does the SBA need minority asset managers to help lenders in
deploying these funds? We believe minority asset managers need to be included.

The Speedy Approval of Non-SBA Lenders
The guidance provided limited details on the inclusion of non-SBA and non-bank lenders. We urge
additional guidance for the swift inclusion of these entities to maximize the opportunities for small
business borrowers.

The Prioritization of Disadvantaged Communities
The legislation (p.30) requires the prioritization of certain communities as detailed in the below
text. Many of these communities are underbanked and face pre-existing capital challenges. With
Treasury’s notes that funding will potentially expire quickly, how is the program intending to
fulfill this requirement?

  • SENSE OF THE SENATE.—It is the sense of the Senate that the Administrator should issue guidance to lenders and agents to ensure that the processing and disbursement of covered loans prioritizes small business concerns and entities in underserved and rural markets, including veterans and members of the military community, small business concerns owned and controlled by socially and economically disadvantaged individuals (as defined in section 8(d)(3)(C)), women, and businesses in operation for less than 2 years.

Clarity for Equity-Backed Businesses
As many in the small business community have noted, there is concern around the affiliation rules
for companies that have received venture capital or private equity funding. Does Treasury or SBA
have guidance on if these businesses can apply for the funding?

Clarity on Non-Profit Entities
The legislation limits non-profit participation, generally speaking, to 501(c)(3) organizations (as
well as veteran and tribal organizations). It did not include (c)4 or (c)6 organizations. The
guidance, however, does not have any limitation or details on non-profits. We are concerned
ineligible organizations may be confused by the Treasury guidance—or if Treasury has deemed
these organizations now eligible additional clarification is needed.

Representations of Borrowers
Could the Treasury provide additional explanation on the representations of the borrower found in
the application? In particular, the requirement to purchase American-made equipment and
products.

New 25% Limitation on non-payroll costs
In the guidance, Treasury has noted a new 25% maximum for non-payroll costs that would be
eligible for loan forgiveness. We are concerned that without additional guidance for independent
contractors, this could limit the utility of the program for certain businesses. If self-employed
individuals have not been able to pay themselves because of a lack of revenue, this suggests they
also cannot be forgiven their rent or utility expenses. This also harms retail businesses and
restaurants that may have significantly larger expenses – such as rent and utilities – that will be
precluded from forgiveness under the arbitrary 25% maximum.

Limitation to $100,000 maximum per employee
In guidance payroll costs are capped per employee at $100,000. But does that include health
insurance and other benefits? The law as passed includes salary only in this calculation, but the Treasury guidance says in a few places “payroll costs capped at $100,000” per employee, suggesting the $100,000 may be inclusive of non-salary benefits.

Allowable loan costs after February 15th, 2020
The legislation allows the loan for mortgage interest, rent, and utilities incurred after February
15th, though these would not be eligible for forgiveness. The guidance suggests that these are not
allowed costs. Could the Treasury please clarify?

Possible Safe Harbor for Benefits Election
To expedite the loan application and simplify calculations, would Treasury consider creating a safe
harbor election for total benefits to employees? This could be a percentage of payroll that
businesses could select instead of calculating (and possibly pro-rating) benefits from 2019. We
would defer to Treasury and SBA on an appropriate percentage but believe this could simplify the
loan for many business owners.

Additional Guidance Needed on 1099s and the Self-Employed
Can a business count independent contractors in payroll costs as envisioned on page 12 and 22 of
the legislation? It is our understanding that small businesses may include the 1099-MISC payments
toward 2019 payroll costs and loan forgiveness.

Actions Businesses Have Already Taken
What about reductions to salary that employers have already put in place? The bill seemed to say
that if the employees were re-hired by June 30 that was okay (but for what pay cycle?).

Impact of other lending programs, specifically EIDL
The legislation allows for the refinancing of EIDL loans into the PPP loan. This also requires an
increase in loan size. The guidance was silent on the role of EIDL. Can you provide additional
clarification on that process? Particularly if the loan for the EIDL (or part of it) was taken to cover
payroll costs and other expenses, and if these will be forgiven once rolled into a PPP loan.

How to apply, when and where?
The loan application states that on April 3, 2020 "small businesses and sole proprietorships" may
apply. You then show April 10 for "independent contractors and self-employed". Generally
speaking, independent contractors and self-employed are sole proprietors. When should they file?
Most independent contractors and self-employed file a schedule C as a sole proprietor.
Most critically, changes to the current SBA website have created challenges to identifying local
lenders. Can SBA please provide a location or update on Lender Match portal in order for
businesses to easily find banks.

We urge you to reach out directly with any questions, given the timely nature of these policies.
We are available at your convenience and can be speedily convened by contacting John Stanford

Sincerely,

Chiling Tong, President & CEO, Asian/Pacific Islander Chamber of Commerce and
Entrepreneurship
Jill Houghton, President & CEO, Disability:IN
Keith Hall, President & CEO, National Association for the Self Employed
Jen Earle, CEO, National Association of Women Business Owners
Todd McCracken, President & CEO, National Small Business Association
Karen Kerrigan, Chair, Small Business Roundtable, CEO, Small Business & Entrepreneurship
Council
Ron Busby, President & CEO, U.S. Black Chambers, Inc.
Ramiro Cavazos, President & CEO, U.S. Hispanic Chamber of Commerce
John Stanford, Co-Executive Director, Small Business Roundtable
Rhett Buttle, Co-Executive Director, Small Business Roundtable



cc:

The Honorable Mike Pence, Vice President of the United States
The Honorable Steve Mnuchin, Secretary, Department of Treasury
Larry Kudlow, Director, National Economic Council, White House
The Honorable Jovita Carranza, Administrator, Small Business Administration
The Honorable Jerome Powell, Chairman of the Board of Governors of the Federal Reserve System
The Honorable Marco Rubio, Chairman, Senate Committee on Small Business and Entrepreneurship
The Honorable Ben Cardin, Ranking Member, Senate Committee on Small Business and Entrepreneurship
The Honorable Nydia Velazquez, Chair, House Committee on Small Business
The Honorable Steve Chabot, Ranking Member, House Committee on Small Business
Members, United States Senate
Members, United States House of Representatives


February 19, 2025
Pivotal Role of Online Selling Highlighted in Small Business Roundtable Report
January 6, 2025
A recent TechNet-Ipsos survey looked at the role e-commerce marketplaces (think Amazon, Walmart online, Etsy, etc.) play in the small business economy. In short: these marketplaces are becoming more and more meaningful for engaging customers, in a large part by addressing competitive disadvantages small business owners face. From expanding customer reach to reducing operational costs, the survey underscores how these platforms are empowering small retailers to thrive in a competitive and evolving digital economy. As small businesses increasingly adopt multi-channel strategies, e-commerce has emerged as a cornerstone of their success. Survey Highlights: The Digital Advantage For many small businesses, finding and connecting with customers is a constant uphill battle. Traditional methods, such as relying on foot traffic or expensive advertising campaigns, often fall short. Yet, 92% of respondents noted that e-commerce marketplaces make it significantly easier to reach potential customers, while 88% emphasized the ability to expand into international markets. These platforms effectively eliminate geographic constraints, allowing small businesses to tap into global audiences without requiring hefty marketing budgets. Running a small business also requires significant effort towards the management of financial demands, which E-commerce marketplaces tend to ease the burden of. According to the survey, 85% of small business owners reported that operating on the listed E-commerce platforms helped reduce overall expenses. Additionally, 82% highlighted the transparency of costs on e-commerce platforms compared to traditional sales channels. This clarity gives business owners the confidence to plan, invest, and grow without uncertainty and hidden fees eating into their margins. Perhaps most importantly, e-commerce platforms give small businesses the tools needed to stay creative and adaptable. From analytics that uncover customer trends to AI-powered systems that streamline daily tasks, these marketplaces are more than just places to sell—they're partners in helping businesses grow and thrive. It’s no surprise that 90% of small business owners highlighted the value of these tools in launching new products and running effective ad campaigns. Small businesses are thriving thanks to e-commerce marketplaces, which open doors to wider audiences and provide powerful resources for scaling and success. According to the TechNet-Ipsos survey, platforms like Amazon, eBay, and Etsy are leading the charge, helping small retailers unlock new opportunities. By addressing key barriers for small businesses, e-commerce marketplaces are leveling the playing field for those hoping to navigate an ever-changing retail landscape. E-Commerce and Brick-and-Mortar: A Symbiotic Relationship You CAN have both. Contrary to the narrative that e-commerce threatens traditional retail, the survey reveals a mutually beneficial relationship. Nearly 80% of respondents said their success in e-commerce has created opportunities to feature their products in physical stores. Additionally, small businesses with both e-commerce and in-store presence often see complementary growth. Customers who discover products online may visit physical stores to make purchases (looking at you, last-minute holiday shoppers), while in-store shoppers who can’t find exactly what they need often turn to the retailer’s e-commerce site to complete their transaction, allowing digital and physical retail to reinforce each other. Conclusion: E-Commerce as a Growth Engine for Small Businesses E-commerce marketplaces have proven to be indispensable for small businesses, offering cost-effective solutions to grow, streamline operations, and connect with customers. These platforms are far more than sales channels—they are engines of growth and innovation fueling the Main Street stores we know and love. For policymakers and stakeholders, it is key to recognize the synergy that exists between E-commerce and small business. Efforts to regulate or constrain leading e-commerce platforms could inadvertently harm the small business community, restricting innovation, alongside access to the tools that empower small retailers to remain competitive and thrive. E-commerce is not just a lifeline—it is the foundation for the future of small business success.
October 9, 2024
Small Business Roundtable hosted its third annual Entrepreneurship Exchange 2024 (EX 24) in Toronto, Canada on Wednesday, September 4 and Thursday, September 5, 2024. This year’s event featured a welcome dinner; a half-day event consisting of panels, fireside chats, and keynote addresses; a roundtable with North America policy experts; and a closing reception with a focus on three main themes: Navigating the New Normal: The Shifting Political and Economic Landscape and Their Implications for Business in North America; The Innovation Trifecta: Where AI, E-Commerce, and Policy Collide for Small Business Growth in North America; and Securing Our Future: What’s Happening in North American Energy and How Policy Can Help
November 20, 2023
Last week, the Small Business Roundtable (SBR) joined with a number of its members in submitting comments in support of the Small Business Administration’s (SBA) proposed rule breaking down barriers for entrepreneurs with prior justice involvement. You can read the full comment here . Under current regulations, individuals seeking access to various SBA loan programs may be deemed ineligible for loans if they are on parole, on probation, or otherwise have a criminal history record. Research has shown there is little to no correlation between a qualified borrower’s criminal record and their ability to repay borrowed funds. Additionally, the SBA has found that preventing justice-impacted individuals from accessing loan programs could increase the rate of recidivism among returning citizens while denying them an important channel to economic stability. While the proposed rule represents a critical step towards expanding access to capital for entrepreneurs with prior justice involvement, SBR will work with the Administration and Congress to address more opportunities to ensure participating lenders follow the SBA’s lead.
By John Stanford September 26, 2023
Throughout the pandemic, Small Business Roundtable (SBR) chronicled the need for small business owners to take their business online. In fact, embracing e-commerce was one of the many ways entrepreneurs survived one of the most challenging business environments in decades. From iconic restaurants utilizing delivery services to retailers offering goods on overnight-made websites or online marketplaces, small businesses leaned into online sales and digital tools to survive, and in many cases, flourish. Since the country has re-opened, I’ve been fortunate to reconnect with small business owners around the nation and hear their journeys. For many, leveraging technology has been a common response to “what’s different” about your company now. Small businesses are increasingly embracing the role of e-commerce, which is contributing to strong economic growth in this sector during the first years of the Biden Administration. In fact, the Biden Administration just recently announced more than 10 million new business starts – many of which rely on e-commerce to gain customers or digital tools to run their business. The breaking of the digital divide is finally paying the entrepreneurship dividends many of us hoped for. Earlier this month, I had the opportunity to explore one of the largest e-commerce platforms when I was in Seattle for the Amazon Accelerate 2023 conference. During the conference I prioritized spending time with some of the sellers attending the conference. Small business owners’ stories are one of the great benefits of my job, and these stories did not disappoint. There was the wreath maker, the lice-fighter, and of course, a celebrity seller (whose own story on the need for accessible products for diverse communities resonated with the audience)! Their stories had a common theme: selling online has transformed their lives. It put their product in front of an unimaginable number of customers. It’s not easy, and it isn’t overnight, but with the right combination of customer engagement and reputation management, they succeed. And for some, the success has been transformative – the very wealth creation we all work toward as small business advocates. Speaking of other advocates, I was joined by other national organization leaders and we were fortunate to get a behind-the-scenes look at the fulfillment centers that enable Amazon’s almost unthinkable delivery capabilities. What stood out the most? The sheer audacity of promising fast delivery up closer and personal. This facility houses some 21 million products, 3 million of which would move out every week. I hope to do another write up in detail soon. The conference itself – which hosted some 3,000 business owners and employees -- centered on new products designed to help sellers. Of particular interest was learning that Amazon is heavily dependent on the success of its small businesses: more than 60% of sales come from independent sellers, most of which are small or medium sized businesses. Most of the changes centered around expanding logistics capabilities available to sellers. The Fulfillment by Amazon (“FBA” to the locals) will soon be complemented by Supply Chain by Amazon (“SCBA?”) which offers an end-to-end solution. It was clear that to keep sellers engaged on this marketplace – which isn’t the only one – one theme came through—these tools encourage small businesses to focus on their core competencies like innovating for consumers, building their brands, and developing a strong customer base. I was surprised, however, to learn that many of these benefits were being offered even to those selling off Amazon. These “omnichannel” solutions – meaning they can be leveraged for direct sales or in other marketplaces including brick and mortar stores like Walmart – are a response to interest in sellers using Amazon’s logistics to enable all their business across multiple sales channels. Over the past decade, I have heard almost every imaginable barrier or obstacle facing small business owners. Most want to focus on innovating, creating and selling. It seems they have found a match in a surprising place: one of America’s largest companies, Amazon. I look forward to continuing to hear how the sellers I met continue to face challenges and competition. What is clear, though, is the fast-forwarded adoption of e-commerce is now integral to a growing part of the small business community. John Stanford is the Co-Executive Director of Small Business Roundtable.
By John Stanford September 19, 2023
By Elliott Long January 6, 2023
Now that the midterm elections are over and the 118th Congress is set to begin, it is worth considering the implications for small business and how entrepreneurs can engage. Democrats achieved a true Senate majority with key victories in the Georgia Senate runoff for incumbent Raphael Warnock. Meanwhile, Republicans took the majority by a razor thin four seats in the House. With a split Congress, partisan legislation will face challenges in the months ahead. House Republicans have already signaled an increase in Congressional oversight and investigations. While Senate Democrats will continue to work on passing legislation like they did in the 117th Congress, they will face challenges in passing legislation through a Republican-controlled House. Senate Democrats will also prioritize confirming Administration and judicial nominees with a 51-seat majority now. While partisan legislation will face an uphill battle to advance over the next two years, small business priorities could be a unique area for bipartisanship in the 118th Congress. Both Democrats and Republicans have expressed broad interest in regulating technology platforms. Others include alleviating worker shortages through training programs, expanding access to government contracting for underserved small businesses, mitigating the impact of inflation, and helping small businesses go digital. Below are five ways small business owners can make their voices heard on these and other issues important to them in the 118th Congress. Get in touch with your representatives. You can engage your representatives through an in-person meeting, phone call, snail mail or e-mail. Visit www.senate.gov/senators/ and https://www.house.gov/representatives/find-your-representative to find out who represents you. 2. Participate in a Small Business Roundtable member’s conference or fly-in. Small Business Roundtable’s members frequently have conferences around the country and fly-ins to the nation's capital to bring entrepreneurs together and make their voices heard. These events are a great way to amplify small businesses’ power and affect change. 3. Attend an in-person or virtual event. Small Business Roundtable and its members regularly host in-person and virtual events on pertinent topics. Be sure to subscribe to their newsletters and keep an eye out for these events on their websites. 4. Write an op-ed or letter to the editor. Op-eds and letters to the editor are another way to make your voice heard. Check out your local media outlets to learn how to submit one of these on the issues you care about. 5. Leverage social media in your engagement. Social media is a quick, low-resource way to engage your representatives. Be sure to think about which platforms make the most sense for your engagement and post regularly to enhance your impact.
By Ashlyn Roberts September 22, 2022
IMMEDIATE RELEASE CONTACT 9/21/2022 Ashlyn Roberts ashlyn@smallbusinessroundtable.org Washington, D.C. - The SBIR & STTR Reauthorization Act of 2022 , which reauthorizes the federal Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs, unanimously passed the U.S. Senate by unanimous vote on September 21, 2022. If passed in the House of Representatives, who is expected to take up the Senate’s bill on September 28, 2022, the legislation will fund these programs for an additional three years. View the full Senate bill text here and a section by section of its components here . Rhett Buttle & John Stanford, Co-Executive Directors of Small Business Roundtable Issued the Following Statement: “On behalf of Small Business Roundtable (SBR), we applaud the U.S. Senate for the recent reauthorization of Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) Programs and thank Senators Ben Cardin and Joni Ernst for their leadership. Timely reauthorization of these programs is a victory for all American small businesses across the nation - these programs encourage engagement with the Federal government, boost research and development, and incentivize early stage efforts towards commercialization. The SBIR and STTR programs uphold investment that many small businesses depend on and this reauthorization enables sustained innovation in technology development for another three years. Over the past 40 years, the programs have provided nearly 200,000 awards totaling more than $63.8 billion to U.S. small businesses. These programs have already changed lives, catalyzed local economies, and optimized industries. Reauthorization, paired with the enhanced technology safeguards, promises to build on the previous success of this program and create new opportunities for even greater American innovation for years to come. We are pleased with the Senate’s swift efforts and call for passage in the House of Representatives.” ### The Small Business Roundtable ( http://www.smallbusinessroundtable.org/ ) is a coalition of leading small business and entrepreneurship organizations, dedicated to advancing policy, securing access, and promoting inclusion to benefit the businesses at the heart of the American economy.
By Ashlyn Roberts September 16, 2022
FOR IMMEDIATE RELEASE 9/7/2022 CONTACT Ashlyn Roberts, ashlyn@smallbusinessroundtable.org WASHINGTON, D.C. - The Small Business Roundtable ( SBR ) , the leading coalition of entrepreneurship organizations in the United States, congratulates Liz Truss on becoming the United Kingdom’s 56th Prime Minister. The organization welcomes the opportunity to work with the UK government to advance small business priorities to benefit those entrepreneurs at the heart of the British and American economies. “We look forward to engaging with Prime Minister Truss and the UK government to benefit entrepreneurship around the globe. In so many policy areas, the United States and the United Kingdom can learn from one anothers – prioritizing an agenda that will foster wealth creation for all citizens through dynamic entrepreneurial growth. As we have with other key trading partners, SBR will work to highlight opportunities for improved bilateral relations while continuing to grow our more than $200 billion exchange of goods and services,” said John Stanford and Rhett Buttle, co-founders of SBR. The start of the Truss government coincides with SBR’s selection of London to host the 2023 Entrepreneurship Exchange (“EX23”), which convenes leading stakeholders from the global small business community for a day of dialogue and sharing of best practices. Learn more about Small Business Roundtable . ### The Small Business Roundtable ( SBR ) is a coalition of leading small business and entrepreneurship organizations, dedicated to advancing policy, securing access, and promoting inclusion to benefit the businesses at the heart of the American economy.
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