Can I us my US Treasury and SBA PPP loan with my SBA EDIL without merging the two loans as it shows in the borrowers form?

FAQ#: 249 published 4-24-2020

When I read section Q Duplication:

"(Q) Duplication.-Nothing in this paragraph shall prohibit a recipient of an economic injury disaster loan made under subsection (b)(2) during the period beginning on January 31, 2020 and ending on the date on which covered loans are made available that is for a purpose other than paying payroll costs and other obligations described in subparagraph (F) from receiving assistance under this paragraph."

I read it as I can use the PPP for payroll and EIDL to cover my overhead for 3.75% and 30 year term during the covered period.

I can prove my PPP was used 100% for Payroll with the option to use up to 25% forgivable for other eligible expenses.

On the lenders form I see it merges my EIDL with PPP less the advance. From what I read published US Code under duplication only payroll is a duplication of benefits so I am not forced to merge the two loans if I need more for overhead and only want to use EIDL for those expenses and use the PPP for the 8 week covered period for payroll.

I'm I reading this correctly?

36(F)

36(Q)

Research Reference: 

 

 

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