Conducting an internal PPP compliance audit without engaging legal counsel is not recommended. First and foremost, you need to be certain that your company's certification for PPP loan forgiveness is valid, and this requires an in-depth understanding of the legal and regulatory requirements that apply. As a result, most companies will need to engage an outside law firm that is actively representing companies with regard to federal compliance in relation to the recent pandemic.
Additionally, if your company is not in full compliance, you will need to decide what to do next. You will also need to ensure that company personnel who may have made mistakes do not compromise the integrity of the audit, and it will be in your company's best interests to have the audit protected by the attorney-client privilege. At Oberheiden P.C., we offer complimentary initial consultations, and one of our attorneys will be happy to answer any additional questions you may have about conducting an internal PPP compliance audit in confidence.