Earlier this month the SBA (Small Business Administration) and Treasury published updated Paycheck Protection Program (PPP) loan forgiveness guidance and released new forms for borrowers to use if they would be applying for PPP loan forgiveness of $150,000 or less.
The latest form is called the PPP Loan Forgiveness Application Form 3508S. This form seeks information that will be used in qualifying borrowers for the forgiveness of their PPP loan and includes information such as:
- PPP loan amount
- Disbursement date
- Employee totals
- Covered period dates
- Amount of the loan spent on payroll
- The amount of the loan for which forgiveness is being sought.
While borrowers are not required to submit any supporting documentation with the application but are required to maintain payroll, non-payroll, and any other documents and records that could be requested during an SBA loan review or audit.
The SBA and Treasury released two other PPP Loan Forgiveness Applications:
Should a borrow be applying for loan forgiveness using form 3508 or form 3508EZ they will be required to submit payroll and nonpayroll expense documentation.
In addition, the SBA and Treasury released Form 3508D, for which, certain individuals must use this form to disclose a controlling interest in an entity applying for a PPP loan.
An interim final rule (IFR) was also released which helped to simplify or consolidate prior PPP loan forgiveness rules and incorporated changes made by The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act. P.L. 116-260. This Act funded the PPP with $284 billion of additional capital and created second-draw loans, which allows borrowers that received PPP loans during the first draw of the program last year to seek a second loan of up to $2 million provided they were able to meet the smaller size requirements and can document a year-over-year revenue decrease of at least 25% for one quarter in 2020 when compared to the same quarter in 2019.
The IFR and all four of the forms released this 2021 apply to first-draw or second-draw PPP loans.
In the first month of 2021, the SBA announced that it approved approximately 60,000 PPP loan applications that had been submitted to nearly 3,000 lenders. This equates to over $5 billion since the program’s re-opening.
At this time, the Paycheck Protection Program is scheduled to remain open for First and Second Draw PPP loans until March 31, 2021.
If you have any questions regarding your PPP forgiveness or application, please contact our office at 314.884.4000.
