Can you clarify where in the SBA docs it says that there is no revenue reduction required now?  I believe the rules are a bit more complex than that.

My understanding is that those who are taking first draw (under what I called the 1.0 rules, although they changed several times), there is no revenue requirement.  My understanding is also that for those taking first draw under the new ‘farm gross revenue rule’ (I call it 1.1) OR having your non-forgiven 1.0 loan revised under the 1.1 rules to increase your SE PPP portion and/or switch to 2020 revenues/943 wages, that there are no revenue reduction requirements.

My further understanding is that first draw borrowers (1.0 or 1.1), once their loan is fully used, can apply for second draw (2.0), but must meet at least one quarterly 25% revenue drop from the 4 quarters in 2020 to qualify for 2.0.  The SBA, however, will not issue a loan # for the second draw until forgiveness is complete (or applied for?) for 1.0 or 1.1


This seems to imply to me that 1.0 borrowers who properly spent their 1.0 PPP loan, but didn’t max SE owner compensation at $20,833 could apply under 1.1 for the remainder of SE owner compensation under the special gross revenue rule (as long as they hadn’t previously applied for forgiveness), apply for immediate forgiveness (as the SE portion is supposedly immediately forgiven for a sole proprietor) and then reapply for 2.0 for the second full SE portion + another 2.5 months worth of wages in Q1 2021.  

Who knows what a 3rd draw might look like under the incoming administration/Congress.


Side note:  I’ve seen a lot of interesting government programs, but this has to be the first one I’ve seen that punishes those who completed program requirements early (applied for forgiveness already therefore not qualifying for the special revenue rules for the 1.0 loans).