On April 23, the U.S. Department of the Treasury issued new and troubling guidance on the Paycheck Program. This guidance recasts one of the several vague certifications that borrowers have to make, suggesting that it requires borrowers to prepare themselves “to demonstrate” that, at the time they applied for the loan, that they did not have access to enough other “sources of liquidity” to support their ongoing operations. In this episode, two partners in one of Washington’s most prominent law firms, Crowell & Morning, put the new guidance into context and explain how borrowers should respond to it, including the potentially severe consequences of not assembling the documentation they might need. This information is significant as AGC’s Chief Economist reports that a large share of construction firms have received loan funds, allowing contractors to add and retain employees, as evidenced by AGC’s latest survey results.