Paycheck Protection Program Considerations for Advisers

Like any clients that have taken advantage of the Paycheck Protection Program (PPP), advisory practices must be careful about the provisions the Small Business Administration has set forth to make any payments forgivable.

Art by Philip Lindeman


Just like other small businesses that have been negatively impacted by the effects of the coronavirus pandemic on the markets and their profits, retirement plan advisory practices have been hit hard, and some have applied to the Small Business Administration (SBA) for grants from the Paycheck Protection Program (PPP).

Bimal Shah, chief executive officer of Rajparth Achievers, has not only helped clients apply for PPP grants, but he has obtained a $40,000 loan for his own practice. “We have been affected by the virus and needed the help,” he says.

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Julia Carlson, founder and chief executive officer of Financial Freedom Wealth Management Group, says her practice also has been affected as its fees are based on assets under management (AUM).

“With the markets dropping 35% in March, literally freefalling, it led to sheer panic not only among our staff but among our clients,” Carlson says. “When we realized our income could potentially drop by 35%, we applied for a PPP loan and obtained $211,000. I applied because I wanted to act in good faith and be a steward over my staff.”

The purpose of the loan is to keep the business solid and help remove some of the uncertainty, Carlson continues.

“The PPP loans have brought confidence to my business and the small businesses that we serve,” she says.

Like Carlson, Robert Skloff, portfolio manager with Silver Pine Capital, says his firm’s revenue is dependent on assets under management and, therefore, dependent on how the capital markets perform.

“The Dow dropped as much as 37.1% at its worst in March,” Skloff says.

At the same time, he warns other advisory practices that take out a PPP loan to be careful about the provisions the SBA has set forth to make any payment a forgivable grant, rather than a loan.

“There isn’t much information readily available,” Skloff says. That led him to create a website, www.pppforgivenessinfo.com, which includes a PPP forgiveness and optimization tool that can handle companies with up to 25 employees and is available for $59.99. If a firm uses the optimizer, the biggest portion of PPP payments, or 75%, will be directed toward payroll costs, Skloff notes.

“The importance of knowing how you are tracking against both what you included in your PPP application and the amount of your loan is essential,” he says. “The allocations and limitations are confusing. If you do not actively track this, you could end up with a surprise at the end of the forgiveness period.”

Skloff’s website emphasizes that PPP loan recipients were given an eight-week forgiveness period.

“That time frame may not be calculated in the same manner as a monthly or weekly payroll,” he warns. “The PPP forgiveness and optimization tool gives you the ability to automate the payroll allocation and tracking process and allows you to view your weekly progress toward forgiveness.”

The tool also helps users track non-payroll costs and monitor reductions.

Another resource for advisers was published by the Division of Investment Management of the Securities and Exchange Commission (SEC). The division posted a question and answer guide tailored specifically to investment advisers applying for PPP loans.

According to the division, an investment adviser has a fiduciary responsibility to disclose to clients that it applied for a PPP loan, even if the application was denied.

The division says, “If the circumstances leading you to seek a PPP loan or other type of financial assistance constitute material facts relating to your advisory relationship with clients, it is the staff’s view that your firm should provide disclosure of, for example, the nature, amounts and effects of such assistance. If, for instance, you require such assistance to pay the salaries of your employees who are primarily responsible for performing advisory functions for your clients, it is the staff’s view that you would need to disclose this fact. In addition, if your firm is experiencing conditions that are reasonably likely to impair its ability to meet contractual commitments to its clients, you may be required to disclose this financial condition.”

The Financial Services Industry Can Help Tackle Economic Inequality

Each U.S. household in the bottom half of the wealth distribution has only $20,000 of net worth, on average, a figure that represents less than 0.1% of those at the very top. Helping more people to own homes and to invest even modestly in the stock market are seen as critical steps to closing that gap.

Art by Pete Ryan


An in-depth white paper published by PGIM Fixed Income in September shows that, since the global financial crisis of 2008 and 2009, U.S. households in aggregate have come a long way in strengthening their balance sheets.

Liabilities relative to disposable income have trended down to more sustainable levels, PGIM’s analysis shows. In tandem, household assets have surged as the value of financial assets and housing have increased. And, with the decline in liabilities and the rise in assets, PGIM Fixed Income reports, overall net worth has risen briskly and now exceeds pre-crisis levels at around 650% of disposable income. This equates to an average of over $800,000 for each U.S. household.

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But, as the analysis starkly demonstrates, lurking under the surface of the data is a thorny issue of aggregation. Simply put, the distribution of wealth in the United States is highly unequal—about as unequal as it has ever been. Each household in the top 1% of the wealth distribution has, on average, $25 million of assets, including nearly $10 million of equities. The next 9% of the distribution holds an average of $3.5 million each, PGIM Fixed Income reports, supported by more than $1 million of pension entitlements, including defined contribution (DC) and defined benefit (DB) plans.

In marked contrast, the bottom half of households has only $20,000 of net worth, on average, a figure that represents less than 0.1% of those at the top. Such figures may not seem to be of direct professional concern to people working in the financial services field, who tend to be well compensated, but in fact they are. As PGIM Fixed Income reports, some “inequality of outcomes” can promote investment and risk taking, but if the wealth distribution in a society becomes too skewed, those toward the bottom may feel that the probability of rising is discouragingly low.

“Moreover, entire communities may not experience, at least in any first-hand way, the benefits of economic engagement through education, skill acquisition, employment and investment,” PGIM Fixed Income’s report explains. “This blunts incentives to participate in the traditional economy and, perhaps, provides incentives to play outside the system.”

The white paper further posits that highly unequal distributions of income or wealth may bring hidden vulnerabilities for the entire economy or the financial system—meaning in turn that even the wealthiest Americans have a direct stake in solving rampant income inequality.

“For example, the balance sheet data we report paints a very favorable picture of the U.S. consumer sector,” the paper states. “But, as we will show, households in the bottom 50% of the wealth distribution are really struggling. Given the limited financial resources of these households, they have few buffers to absorb a shock, especially a deterioration in labor market conditions [as seen during the coronavirus pandemic]. This means that the economy is more brittle than the aggregate data suggest and, notably, more brittle than if the same wealth was held evenly across the population.”

The white paper goes on to suggest that economic divergences of this type also manifest themselves in the political environment. And, when combined with social unrest related to racial justice issues, the outcome can be disastrous for everyone.

“Inequality economically disenfranchises those who are poorer, while the spending patterns of those at the top are economically far more significant given that they command exponentially more resources than those at the bottom,” the paper explains. “But in the ballot booth, the votes of the bottom 50% count exactly the same as those at the top. Thus, if the economic system is viewed as unfair, or is otherwise creating frustrations, this will manifest itself in the outcome of elections and, eventually, in government policies. The result could be policies that challenge or disrupt the existing economic order.”

When it comes to addressing these fundamental economic justice issues, the PGIM Fixed Income report points to two broad potential approaches—first, lifting the bottom portion of the distribution or, second, compressing the top of the distribution.

“For reasons of economic efficiency, we prefer the former approaches,” the white paper concludes. “Market economies rely crucially on the willingness of individuals to take risks and to invest capital. To operate at peak efficiency, it’s important for people to generally reap the benefits or shoulder the losses that flow from their decisions. However, given the breadth of the polarization that exists in the United States, policy measures that narrow the distribution by clipping the top are also on the table. Indeed, more fundamentally, these two approaches may not be entirely independent.”

In other words, measures to lift the lower portion of the distribution may need to be financed by increasing the burden of those at the top.

“Our regression results offer some hints as to possible steps forward,” the paper suggests. “First, over time, home ownership has proved to be one of the best ways for middle class families to accumulate wealth. This reflects both that housing allows broad access to a relatively safe, but leveraged, asset class. The capacity to accumulate wealth through buying a house has been significant. Of course, in the aftermath of the financial crisis, all of this is less certain than before. But we find the historical record to be compelling. On balance, our judgment is that policy initiatives to encourage broad-based home ownership are likely to help mitigate inequality over the medium to long run.”

A further observation made by PGIM Fixed Income is that, apart from accumulating a down payment, owning a home may not require a household to increase its saving, since rent payments can be converted to mortgage payments.

“In other words, home ownership allows families to adjust their financial footprint without disrupting their other consumption patterns,” the paper explains.

Beyond home ownership, the equity market has been a core driver of wealth for the upper portion of the income distribution, the white paper says. Indeed, the paper’s various regression analyses show that rising equity prices are a key factor explaining increasing inequality.

“The policy prescriptions should not focus on penalizing the stock market or those holding equities, but rather seek to expand the set of equity investors,” the paper concludes. “How this can be achieved broadly in the economy is very much an open issue. Over the years, a number of proposals to invest Social Security contributions in the equity market have been considered. But this entails enormous complications, including who is to bear the losses if stocks sag for extended period? Alternatively, employed workers generally have access to 401(k) or similar vehicles. Further policy focus on maximizing participation in these vehicles could include some form of tax credits (rather than just deductions) for contributions by lower-paid workers and their employers.”

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