PPP Loan Forgiveness Application, Should You Wait to Apply?

Don’t Rush Your PPP Loan Forgiveness Application

It may be a smart business decision to wait to submit the Loan Forgiveness Application (Form 3508) for your Paycheck Protection Program Loan. A lot of businesses may want to put the whole process behind them as quickly as possible. However, there are a few reasons why you may want to wait to submit it.

WHY YOU WANT TO WAIT:

Hurrying up the process may not be warranted, especially if Congress, the U.S. Small Business Administration (SBA) and the U.S. Treasury continue changing the landscape. Patience is suggested, for a variety of reasons, including:

  • Most Companies Are Utilizing the 24-Week Covered Loan Period. The Paycheck Protection Program Flexibility Act made some significant changes to the rules surrounding PPP loans. Businesses receiving PPP loans now have 24 weeks to use the funds for eligible expenses instead of the original 8-week period (although borrowers whose loan numbers were assigned before June 5 may elect to use the 8-week period). By taking advantage of the extended covered period, business owners have more time to talk to their advisors and strategize ways to achieve maximum loan forgiveness.
  • Loan Forgiveness Applications Are Not Due Until 10 Months After The Cover Period Ends. Currently, there is no set deadline for submitting your loan forgiveness materials, other than 10 months after the end of your covered period.  For example, if your loan was secured in late April 2020, then the 24-week covered period is scheduled to end in early October. After your cover period ends in October, you have up to 10 months to submit your forgiveness application.  Most businesses will likely not wait until next August to submit Form 3508, but you should have ample time to properly spend your loan proceeds, to receive future PPP guidance from SBA,  and to make sure your forgiveness calculation is accurate and all of your documentation is solid prior to submission.
  • SBA will not be opening its portal to lenders until at least August 10. The PPP Forgiveness Platform is scheduled to go live and begin accepting lender submissions on August 10, 2020. However, this is subject to delay. According to a recent Journal of Accountancy article, the SBA and Treasury are not expected to release the anticipated 25 to 30 FAQs before President Donald Trump signs the new relief legislation. Congress is currently trying to release the second relief package before going on recess August 8. If congress does pass the legislation before August 8, it will still take time for the SBA to adjust the portal accordingly for the new provisions. In addition, it will take time for lenders to open their own portals to accept forgiveness applications from borrowers following SBA’s August 10th target date.

HOW CAN KATZABOSCH HELP

We realize that borrowers may still need assistance and have more questions. Each borrower has their own individual set of circumstances, and the answers are not always black and white. It is important for borrowers to “get in front” of their loan forgiveness and make adjustments before the end of the covered period, if necessary. KatzAbosch helps businesses through the process by providing consulting and guidance for Paycheck Protection Plan (PPP) funds.

We are here to help guide and assist borrowers through this process and help gather required documentation for your lender. If you have questions about your unique situation, please reach out to your KatzAbosch representative or contact us.

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