Last night @USTreasury @SBAgov put out FAQs on PPP. Picture has emerged of how some VC-backed companies can access PPP when these FAQs are combined with this past weekends guidance. Some startups won't be able to access PPP but others will. Details: https://tinyurl.com/yxxn5g6b 

BANK DEFERENCE: helpful & hopefully gives banks confidence: "responsibility of the BORROWER to determine which entities. . .are its affiliates and determine the employee headcount of the borrower and its affiliates. Lenders are permitted to rely on borrowers' certifications."

FRESH START: "If a minority shareholder in a business irrevocably waives or relinquishes any existing rights specified in 13 CFR 121.301(f)(1), the minority shareholder would no longer be an affiliate of the business [assuming no other affiliation issues]"

PEOs: "payroll documentation provided by the payroll provider that indicates the amount of wages and payroll taxes reported to the IRS by the payroll provider for the borrower's employees will be considered acceptable PPP loan payroll documentation."

BUT...INDEPENDENT CONTRACTORS: "Any amounts that an eligible borrower has paid to an independent contractor or sole proprietor should be excluded from the eligible business's payroll costs. However, an independent contractor or sole proprietor will itself be eligible [for PPP."