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#2235771 - 04/27/20 09:27 PM PPP Potential Misuse of Funds
BSA2019 Offline
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Joined: Mar 2019
Posts: 17
In the event that we come across transactions that indicate that funds are not used for the provisions of the CARES Act then the activity would be reportable correct?

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#2235772 - 04/27/20 09:45 PM Re: PPP Potential Misuse of Funds BSA2019
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,365
Illinois
I'm not sure what you mean. If the funds aren't used for payroll and other approved expenses, then the loan is not forgivable. Businesses won't be providing certification requesting loan forgiveness for several weeks.

If you discover a falsification on the application just as a hidden bankruptcy, the business had more than 500 employees, etc. that is one thing. Beyond that I'm not sure what you are trying to police.
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#2235792 - 04/28/20 12:33 PM Re: PPP Potential Misuse of Funds BSA2019
edAudit Offline
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edAudit
Joined: Jul 2008
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You are here
I am not sure how you would be able to tell if the funds are not used for the provisions of the CARES Act. But if somehow you can if within limits file a SAR and move on.

For falsification such as BrianC noted follow regular bank processes for fraud.
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