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Leonard H. Johnson, shareholder in the firm's Finance and Real Estate groups, is quoted in the Washington Business Journal article, "Big Brother is eyeing some PPP loans. Here's why it might be time to give the money back" regarding the legal obligations some companies may have to return their PPP loans.

Most agree the problem is not just a legal one. While some of the criticism has been directed to publicly traded or venture backed companies, larger businesses that have kept PPP funding face the prospect of significant public-relations damage.

"It made a lot of people who don’t fit that mold very nervous," Leonard Johnson, an attorney at Buchanan Ingersoll & Rooney PC.

He agrees with Carp that originally eligible businesses who followed the rules should be legally safe. He also recommends businesses document all financials associated with their PPP applications. He acknowledged those businesses still face the prospect of litigation, overzealous public prosecutors and brand damage, regardless of what the guidance says.

"I think it’s as much a PR call as it is a legal call," Johnson said. "Even if you qualified, you are going to potentially have some explaining to do, as they said on 'I Love Lucy.' It doesn’t mean you did anything wrong and doesn’t necessarily mean anything is going to happen. But if you ask me if I have total faith that no one is going to bother anybody who was in that scenario, I don't have total faith in that."