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Kim Noh

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What Is Internal Control?

In accounting, a key term to know is “internal control.” Internal control is the series of processes and procedures that are performed within the organization to ensure the integrity and accuracy of the financial information and reporting of that organization. Internal control is very important to consider in order to protect the business owners, employees, vendors, investors, and other stakeholders.

In a small business, maintaining good internal control is often a challenge since staff size is smaller and resources are limited. Yet, it is essential to understand so that the business owners understand what risks they are taking every day in their businesses.  A good system of internal controls can help the organization reduce the risk of fraud, safeguard against loss, and demonstrate good business practices.

Key Concepts

Segregation of duties is the first of three key concepts of internal control. It means that tasks should be assigned to different people when there is a risk that having everything assigned to one person could hide errors or even theft.  For example, the person who opens the mail and receives checks should not be the same person who applies the check to the correct customer in Accounts Receivable.

Delegation of authority is the second key concept of internal control.  While the owner has ultimate control, they cannot do everything. They must delegate to staff. Staff have the responsibility to maintain internal controls in their area of responsibility.

System access is the third concept of internal control. Access to documents, rooms, computers, applications, and other items should be on a need-to-know basis to reduce risk. While one person might have system access to enter a transaction, they should not also be the one to have system access to review or approve that same transaction.

Business Operations

Every aspect of the business should be considered while setting up the company’s policies and procedures.  In a small business, an easy way to develop internal controls is to review each major transaction flow and implement the controls needed.

On the customer side, this includes receiving the customer order, sales contracts, shipping, invoicing, managing accounts receivables, collections, bank deposits or merchant reconciliations, and cash management. It can also include customer service, pricing, and promotional activity.

On the vendor side, the process includes adding controls for vendor selection, purchase orders, receiving, bill pay, managing accounts payable, payments, managing travel and expense accounts, and company credit cards.

Depending on the company, additional areas that need to be reviewed for internal control include inventory and supply chain management and government contracts, if any.

When hiring, the process of hiring, onboarding, training, evaluating performance, and payroll should be considered.  Safety is also an important consideration.

A very large part of internal control development should focus on the information technology operations of the company. Areas include user access and controls, password management, naming conventions, physical security, disaster recovery, and network and applications development, updates, and change control. Data entry should also be considered and is best included when developing controls for the customer, vendor, and employee functions.

Additional functions that need internal control processes include treasury and financing; financial reporting, budgeting, and planning; records storage, access, retention, and destruction; asset management; and insurance.

Internal controls can be applied to small businesses as well as large organizations. It’s all about being able to feel confident that your business is operating with financial integrity, accuracy, efficiency, and a reduced risk of failure. If you have questions about how internal control applies to your business, be sure to reach out to us any time.

Getting to the Next Level of Your Business

Sometimes it’s hard for business owners to know how to take their businesses to the next level of growth and profitability. If you’ve been stuck at the same revenue or profit level for a while, it could be because knowing how to scale your business is not a skill in your skillset — yet.

Enter a classic management book on scaling: High Output Management by Andrew Grove, ex-chairman and CEO of Intel. While it was written in 1983, it has made a recent comeback in Silicon Valley but is still not well-known outside of the Bay area. Many people who have read it say it’s the best management book they have ever read, life-changing even. It is certainly a timeless and invaluable read for business owners and managers.

In the book, Grove applies the principles of engineering and manufacturing production to management. It’s all about process: developing processes and procedures so that you can track what’s going on and measure the results, or output, every step of the way.  Only then can you improve the process so that it leads to high output.

Measurement is an important concept in the book. No matter what business you’re in, you can apply the ideas of developing processes, measuring them, and improving upon them in your business.

Grove gets into how managers can motivate their team members and affect production outputs. He talks a lot about leverage, which enables scaling both positively and negatively, and how it can affect employees’ output. One example of positive leverage is when managers can add a “nudge” activity to enable their employees’ work. A negative example is when managers meddle and get in the way of the employee making progress.

In the section on meetings, Grove breaks them down by purpose and lends his ideas on how to run each type better. He touches on other key topics such as decision-making, planning, motivation, performance reviews, and values.

One significant highlight from the book is that if you’re motivated to become a better manager, and wish to improve the output of your organization, then there is nothing more important than training yourself.

Reading this book is a wonderful way to spend time learning new business skills you can use and benefit from immediately.

5 Tips to Spice Up Working from Home

We’ve been in a pandemic for what seems like five years now, right? All joking aside, if you’ve been lucky enough to work from home this past year, then it’s possible that you are in the process of going stir-crazy. Or maybe you’re simply ready to shake things up a bit.

Working from home has its benefits. Yet, if you are someone who enjoys going to the office every day, chatting with co-workers in person, attending meetings that aren’t all virtual, and having a little spontaneity each week, then we’re here to help. Here are five tips to boost your WFH (working from home) environment.

  1. Take Short Breaks

Taking regular breaks throughout the day is so important, and more so now than ever before! Without a doubt, these breaks will help you mentally (that is, keep you from going stir-crazy), but they can also help your work productivity and quality. These breaks don’t need to be—and shouldn’t be—long or strenuous.

Walk the dog. Stand up and do some light stretches. Run up and down your stairs. Go outside into your backyard. Dance to a song. Do a quick chore, like emptying or loading the dishwasher. Call a friend. Or choose your own favorite break activity.  The goal is to get the blood flowing and the fog cleared from your mind.

  1. Switch Up Locations

Get creative and switch up your location. If you have a yard or patio of some sort – and good weather — that allows you to sit outside and work, perfect! If not, try working from the living room, the dining room, the kitchen, even the bedroom. The idea here is to change your surroundings a couple of times a week so that you don’t feel stuck or get lost in the monotony of a daily routine.

  1. Treat Yourself with Lunch

Everyone needs something to look forward to, and what is better to look forward to than food? Depending on your budget, treat yourself to a special lunch once a week, every other week, or monthly. Consider trying new restaurants, different foods, places that you’ve always wanted to eat at but haven’t had the opportunity to do so. Not only will this be fun for you, but you will also be supporting small, local businesses. Win-win!

  1. Dress for Success

We can probably all agree on one thing: sweatpants are comfortable! As such, it can be difficult to trade in the sweats for jeans or dress pants every day. After all, if you’re working from home and there’s no dress code to enforce, it can be hard to dress for success. Yet, doing so can give you a little burst of inspiration to get through the day. You can keep your outfits casual just as long as you have fun getting dressed. For example, you could have Sandal Mondays or Blue Shirt Fridays. Again, just have fun with it!

  1. Create a New Playlist

Does music motivate you? Are you able to work and listen to music at the same time?  If so, create different music playlists to listen to throughout your day. Try listening to various genres or new artists, anything that keeps you alert and stimulated, even excited about your workday. Depending on the type of music you enjoy listening to, you can even get up periodically and take dance breaks (Tip #1)!

Keep your day fresh, and boost your productivity and mood by using your imagination and trying the tips above.

Mix Up Your Revenues for More Profits

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Many small business owners focus on generating more revenue every year, and that’s a wonderful goal.  But not all revenue is created equally since some items are more profitable than others.  If you sell more than one product or service in your business, then you may benefit from looking at your revenue mix.

While it’s fun to watch revenues grow, your business profit is what really matters.  If your expenses grow faster than your profits, then you have a lot of activity going on, but you don’t get to keep as much of what you make.

An insightful exercise to try is to take a look at your revenue mix.  Then you can ask “what if?” to optimize your profits.

Your Revenue Mix

Let’s say you offer three different services: Services J, K, and L. Your revenue pie looks like this:

J:  $700K or 70% of the total
K:  $150K or 15% of the total
L:  $150K or 15% of the total
Total:  $1.0 million

In this example, Service J is clearly the service making you the most revenue in your business.  But is it making you the most profits?

The profit you receive from each of these service lines is as follows:

J:  $80K
K: $10K loss
L:  $30K
Total:  $100K

While Service J is generating the most profit volume for your business, it’s actually Service L that’s the most profitable.  Earning $80K on $700K yields 11.4% return on Service J, but earning $30K on $150K yields nearly double the return at 20%.  Service L generates the most return.   And if possible, Service K may need to be discontinued or turned around.

Optimizing Profits

Your strategy for a more optimum revenue mix might be to sell as much of Service L as possible, while eliminating or fixing the problem around Service K.

It’s fun to experiment with different revenue mixes.  And of course, there are many more variables besides profit, such as:

  • What services/products do you prefer to work on/sell?
  • Are you able to sell more of the most profitable service or are there marketing limitations?
  • Is one service a loss leader for the others?
  • Are you able to adjust price on the lower margin services to increase your profits?

There are many more questions to ask and strategies to consider to make you more money, which is why we love being accountants.

A New Mix

We hope you’ll spend some time analyzing your revenue mix and having fun asking yourself “what if?”   If we can help you expedite the process or add our perspective, please reach out anytime.

Managing Customer Service with Technology

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Do you have a lot of customer service inquiries in your business? If so, it can be a challenge to manage them all. Being responsive with customer service can make all the difference in your company’s success, so it makes sense to take a look at some tools that can streamline the process.

The most common solution to automating customer service inquiries is to implement a ticket management system, which is also called help desk software. Some of the things that are important to consider include:

  • How fast you can respond to a customer
  • How well you solve the customer’s problem
  • How to track a customer’s issue if it has to be open for a while before it can be solved
  • How to do all of this in a cost-effective and efficient, yet friendly, manner

These days, an inquiry can come from a multitude of places:

  • Phone calls and voice mails
  • Emails
  • Text messages
  • Social media accounts, for all the platforms you have a business presence
    • Posts, replies, and comments
    • Messaging
    • Any other methods you have set up in your social accounts
  • Chat feature on website
  • Snail mail

That’s a lot of inputs to organize. When they can all be fed into the same system, you have just unified your messaging input and taken a giant step toward organizing all of these moving parts.  A good ticketing system will accomplish this, and the feature you want to ask for is multi-channel accessibility.

Keeping your customer service costs low is another factor, and one way to accomplish that is to help users self-serve and solve their own issues when they can. This requires a robust knowledge base feature. A knowledge base is a set of how-to articles and videos of the most frequently asked customer service questions.

Here are a few very basic topics to consider including in your knowledge base:

  • What forms of payment do you accept?
  • What is your shipping policy?
  • How can I get help if I need it?
  • What is your return/refund policy?
  • What is your privacy policy?
  • What is your guarantee?
  • Is my data secure with you?
  • How do I update my credit card/address/phone/email?
  • When will my items arrive?
  • What licenses do you have?
  • What are your hours?
  • Do you have hours for seniors?
  • How do I login?
  • How do I access my digital items?
  • What are your covid-19 policies for your employees? For customers?
  • Are you hiring? How do I apply? What are your employment policies?

A good ticket system will also have the ability to customize the ticket, the customer service agents, the customer records, and the other important parts of the system. For example, you may want to set up your own status items for each ticket.  Open, assigned, active, hold, and complete are typical status types, but you may need another one.

The workflow must also be considered in a ticket system.  How does a typical ticket flow through your business, and can the system replicate that flow.

Other important features of a ticket system include:

  • Support for multiple languages
  • Customer response to tickets, as well as customers can view status of their tickets
  • Uptime of system – service-level agreements
  • Tracking, such as number of open tickets, tickets on hold, and the like
  • Reporting metrics, such as wait time, ticket servicing time, and number of tickets handled by each agent
  • Ticket tagging and categorizing
  • Feedback loop for customer suggestions of product improvements
  • Ease of use for customers and agents
  • Notifications

A few of the most popular ticket management systems include:

  • Zendesk
  • Freshdesk or Freshservice by Freshworks
  • Zoho Desk
  • HubSpot Service Hub
  • Salesforce Service Cloud
  • LiveAgent

There are literally hundreds of technology options for any size business.

If you want to take your customer service to the next level or just want to get more organized, consider looking into these ticket systems.

Fighting Cybersecurity Threats in Your Business

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If you keep any kind of digital information in your business, you have a chance of becoming a victim of a cybercrime. The odds have increased exponentially during the pandemic, with more cyberthreats and scams floating around than ever before. Here are some ways to reduce your chances of getting attacked.

Social Engineering

Social engineering is when thieves try to get your employees to provide confidential information via a phone call or email. You can reduce your risk here by developing procedures and training any employees that take customer phone calls for the business. Require them to ask for identifying information such as a pin or code, or simply prevent them from giving out any information over the phone.

Passwords

Passwords are terribly inconvenient but incredibly necessary. Almost everyone is guilty of using passwords that are simply too easy to guess. Here are some password tips:

  1. Avoid using dictionary words, even if the syllables are broken up in the password.
  2. Always use a combination of upper and lower case, and don’t just make the first letter uppercase which is too predictable.
  3. Include special characters, and don’t just use the exclamation point.
  4. Use separate passwords for everything, especially for banking apps, accounting apps, and social media apps which are frequently hacked.
  5. Make your passwords at least 12 characters.  More characters will be needed each year.

Receiving and Delivering Information

If you deliver or receive information, it should be done safely and securely. One way to do this is to use a customer portal such as Box or ShareFile, where the information is securely stored in the cloud. Another tool that to safeguard information delivery is encrypted email.

Anti-Virus

All computer users should have anti-virus software implemented and active on their devices.  Company procedures should dictate the settings as well as the brand to use.

Spam Protection for Email

Anti-spam software is also necessary to protect the device from bad links in emails.  Users should be trained to detect and avoid phishing emails.

Malware Protection

Malware can be installed on your computer without your knowledge and if you are not careful.  To protect against these threats, avoid file-sharing when possible, be careful when visiting unknown websites, don’t download software that you don’t recognize, and be careful with links in emails.

You may also need to protect your website from malware attacks by installing a firewall or other preventative solutions.

Software Releases

Stay current with all of your software upgrades. Upgrades can patch vulnerabilities, so you are safer with each new upgrade you install.

Data in the Cloud

Make sure any data that you have in the cloud is behind an acceptably secure technology solution.  Today, this generally means files are stored with AES 256-bit encryption. You can also look for SOC1 and SOC2 certifications.

Need to Know

There are many policies that need to be developed for employees with regard to data handling. One example is providing data access to employees on a need-to-know basis.  For example, an operations manager does not need the password to the payroll system, but the payroll manager does.

Reducing Business Risk

These items above are the tip of the iceberg when it comes to having good data security practices in your business. Develop an excellent set of policies, train and monitor employees, and set a great example yourself when it comes to this growing threat to your business.

The Concept of Independence in Accounting

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Independence is a key concept in accounting, especially in the assurance or auditing area of accounting. Assurance services are services where a licensed CPA reviews an organization’s financial statements and accounting records and provides an opinion about them. This opinion takes the form of a report that can be shared with third parties such as banks and shareholders. Auditing services are one of many forms of assurance services.

Only a licensed CPA can provide assurance services; this is regulated by the states. A CPA who provides certain assurance services must be independent from the business that it is writing an opinion for. Essentially, independence means that the auditor must be able to do their work objectively and with integrity. And it goes farther. The auditor must not be perceived as having any kind of bias or connection with the business it is auditing. There must be no perception of any impropriety.

To this end, the auditor must not have a relationship with the company’s executives. A CPA cannot, for example, audit her brother’s company.  A CPA cannot be an investor in the company and also be the auditor because of the financial relationship. The audit opinion must not be influenced in any way by a relationship between the auditor and anyone in the company. The CPA must be able to provide an honest, professional, and unbiased opinion when auditing financial statements.

Being independent also means the CPA must have a healthy dose of skepticism.  A common phrase in the accounting profession is “Trust, but verify.”

Numerous rules abound to protect auditor independence. For example, an auditor cannot be paid on a contingent or commission basis. All practicing CPAs must complete ethics courses every few years, and these almost always include independence scenarios and case studies.

If you have any questions about independence, assurance, or auditing, please feel free to reach out any time.

Ten Places to Look to Find More Profits

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A great way to start 2021 is to take a fresh look at your business finances. Many things changed in 2020, and if you are in the habit of spending on the same items year after year, it’s the perfect time to decide what is essential and what can go.

There are only a few ways to increase profits when you think about it in black and white terms. You can either raise revenues or cut costs. Let’s take a look at where we can potentially cut costs.

Publications

These expenses tend to be monthly or yearly, and we tend to just let them automatically renew time after time. But do we really need them? Take a look in your Dues and Subscriptions account to evaluate what you really need to stay informed, and cancel the rest.

Memberships

If you are a member of an organization or two, what benefits are you getting from your investment? Does it raise revenue for you? Do you use everything the membership offers? If not, it might need to go on the chopping block.

Memberships are especially tricky if the organization provides a local meeting component as a benefit and your state or county has been shut down. There’s a tradeoff right now between supporting the organization so that it’s still there when we can freely meet again and being responsible about your own business costs.

Office/Store Rent

With many employees working from home, the question has come up in many businesses about how much space they really need. As leases expire, consider how much space you really need. Some employees may love to work from home permanently, which frees up space.

Retail stores that have moved their business online may be able to cut back on customer-facing space but might need more inventory storage space. A restaurant that has successfully transitioned to pickup and delivery orders might be able to get by with a smaller seating area.

Software Apps

Are you paying for any technology applications that you are simply not using?  This is a good place to look for cuts.

Some applications charge by number of contacts.  Keeping your lists clean inside these apps will avoid increases and cut costs in some cases.

Office Supplies

Do you really still need things like staplers and scissors on everyone’s desk? If your business is going paperless, you can save a lot on office supplies.

Printing

Do you need to spend money on printing, or can the printed item be delivered electronically?

Shipping/Postage

While information can be delivered electronically, physical goods still need to be shipped.  Make sure you have the best deal with your shipping vendors based on your volume.  You may also need to consider building your shipping costs into the price of the product or add a shipping fee to the bill if you don’t already.

Marketing

A great way to increase profits is to become more intentional about your marketing costs. Are you able to measure what’s working and what isn’t? Or are you doing the same thing year after year?

Marketing has changed so much, even in the last few years. It might be time to implement digital marketing methods, which can be more cost-effective than older, outdated methods.

Labor

Make sure employees manage their time effectively by providing the right training and supervision. This should help to reduce labor expenses.

Telephone/Internet

Has your business changed?  Do you need all those extra features you are paying for?  Could you do without those extra lines?  Would another phone plan save you money on long distance or international calls? Many telecommunication companies will often bargain with you or offer you a new deal just for checking in with them.

This gives you ten places to look to cut costs and correspondingly increase profits for 2021. If you need help reviewing your income statement, please reach out.

Should Your Business Become Cash-Free?

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A cashless business is one that processes all cash transactions electronically. There is no paper or coin money taken or handled. While no one society has become 100 percent cashless yet, most organizations are moving in that direction.

A business can become cash-free by providing multiple electronic alternatives to payment.  Credit cards are the most common electronic payment implementation. This option most likely includes MasterCard, Visa, Discover, and American Express.  Some businesses also have a PayPal account and offer that method for payments. Venmo, owned by PayPal, is an efficient mobile alternative, but it is mostly used for consumer-to-consumer transactions. And there is also cryptocurrency.

Cashless businesses are more efficient, help to reduce crime, and have a better audit trail of transactions. Going cash-free also saves money and time spent counting the money, storing the money, safeguarding the money, protecting employees at risk of becoming theft victims, and physically going to the bank.

On the negative side, credit card companies charge fees to merchants, although these can now be passed to the customer in most states. Electronic transactions also require a higher level of technology, and privacy is reduced. And while security is an issue, all merchants that take credit cards must comply with PCI (Payment Card Industry) security standards and sign a document each year stating so.

If your clientele does not keep their money in a bank or if they are not able (or have chosen not) to have a credit card, you may need to rethink going cashless. About 20 percent of U.S. households are challenged when it comes to having access to checking and savings accounts. This has led to several state and local laws being passed in the U.S. prohibiting a business from going cashless. Nothing has been passed at the national level as of this writing, however the Payment Choice Act was introduced in both chambers in mid-2020.

The pandemic has accelerated the move to cashless with the desire for contactless transactions. Several countries are leading the way to becoming cash-free as an entire country, including Sweden, Finland, Norway, China, and South Korea. Sweden’s government has been the most aggressive, claiming they will become a 100 percent cashless society by 2023.

Is going cashless right for you? Meeting your clients’ needs is a prime consideration. At the very least, you can move to increase the percentage of electronic transactions and decrease the percentage of cash transactions when feasible.  This measure will save time and money in and of itself.

PPP January 2021 Update

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Qualifying small businesses can now apply for Paycheck Protection Program (PPP) loans through certain lenders. The Small Business Administration (SBA) reopened its PPP portal on January 11, 2021 after Congress passed and the President signed legislation in December 2020, authorizing the continuation of the program and an additional $284 billion in funds.

The program allows for two types of applications:

  • First Draw Loans to qualifying entities that did not receive a PPP loan in 2020, and
  • Second Draw Loans for previous PPP loan recipients and with a narrower set of qualifications. 

First Draw PPP Loans for First-Time Borrowers

Borrowers that qualify for first-draw PPP loans can apply for up to 2.5 times their average monthly payroll costs (with caps), for a maximum loan amount of $10 million. Generally speaking, the applicants must have been in operation on February 15, 2020 and be among the following types of businesses:

  • Businesses with 500 or fewer employees that are eligible for other SBA 7(a) loans
  • Sole proprietors, some self-employed individuals, and independent contractors
  • Nonprofits, including churches
  • Sec. 501(c)(6) businesses
  • Food or lodging operations with NAICS codes that start with 72 and with fewer than 500 employees per location
  • Certain news operations with qualifying NAICS codes in the 51 range

A number of entities are specifically prohibited from receiving loans.

The SBA application for First Draw Loans is here:
https://www.sba.gov/document/sba-form-2483-ppp-first-draw-borrower-application-form

The applicant must attest to the necessity of the loan, among several other declarations.

Second Draw PPP Loans for Borrowers That Received a PPP Loan in 2020

Borrowers that qualify for a second-draw PPP loan can apply for up to 2.5* times their average monthly payroll costs (with caps), for a maximum loan amount of $2 million. Generally speaking, the applicants must qualify as follows:

  • Employ no more than 300 employees
  • Have spent all of their first PPP loan on eligible expenses
  • Do not have to apply for forgiveness for the first loan ahead of receiving the second loan
  • Can show a 25 percent drop in gross receipts in any one 2020 calendar quarter from 2019. If it’s easier to show a 25 percent drop for the entire 2020 year compared to 2019, applicants can submit their tax returns as proof.

*Companies with NAICS code 72, which generally speaking are food and lodging operations, can borrow up to 3.5 times their average monthly payroll costs (with caps).

The SBA application for Second Draw Loans is here:
https://www.sba.gov/document/sba-form-2483-sd-ppp-second-draw-borrower-application-form

The applicant must attest to the necessity of the loan, among multiple other certifications and declarations.

Loan Forgiveness

PPP loan recipients can apply to have PPP loans forgiven if the funds are used within a specified covered period from 8 to 24 weeks on the following eligible costs: payroll (60 percent of funds), rent, covered worker protection and facility modification expenditures, covered property damage costs, certain supplier costs, accounting (!) expenses, and a handful of other qualifying expenses.

Timing

The SBA portal opened Monday, January 11, 2021 for first-draw loans by lenders (about 10 percent) that cater to underserved communities. These include Community Development Financial Institutions (CDFIs), Minority Depository Institutions (MDIs), Certified Development Companies (CDCs) and Microloan Intermediaries.

On Wednesday, January 13, 2021, the SBA application portal began accepting applications for Second Draw loans. A few days later, additional lenders will be added to the portals.      

SBA says it “plans to dedicate specific times to process and assist the smallest PPP lenders with loan applications from eligible small businesses.”

What to Do Next

Here are some suggested steps to get ready for this next round of PPP funds.

  1. Determine which lender you want to use to apply for PPP funds.
  2. Visit your lender website to see if they have a PPP notification signup so you can get notified of updates.
  3. Collect the documents you need for the application.
    a. Payroll summary reports
    b. Profit and loss statements
    c. Tax returns
  4. Begin calculating the amounts you’ll need for the application:
    a. Gross receipts by quarter for 2020 and 2019
    b. Average monthly payroll costs, including cap limits for wages over $100,000, for the year you want to use (2020, 2019, or the year from the application date)
  5. Contact us if you need help with documentation or calculation or other advice.
  6. Contact us for advice about tax ramifications.
  7. Contact your attorney to evaluate the loan agreement. 

Further PPP Resources

Updated PPP Lender forms, guidance, and resources are available at www.sba.gov/ppp.

CARES Act Treasury page: https://home.treasury.gov/policy-issues/cares/assistance-for-small-businesses

Jan 6, 2021 SBA PPP Interim Final Rule – 82 pages
https://home.treasury.gov/system/files/136/PPP-IFR-Paycheck-Protection-Program-as-Amended-by-Economic-Aid-Act.pdf

Jan 6, 2021 SBA PPP Second Draw Interim Final Rule – 42 pages
https://home.treasury.gov/system/files/136/PPP-IFR-Second-Draw-Loans.pdf

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