June 18, 2020 Due to the changes under the Paycheck Protection Program Flexibility Act and in response to congressional pressure to simplify the process for businesses The U.S. Small Business Administration (SBA), in consultation with Treasury, released Wednesday revised loan forgiveness applications for the Paycheck Protection Program (PPP). A brief review of the new applications and what they now emphasize are as follows: PPP Loan Forgiveness Application 3508: The application has been revised to reflect the PPP Flexibility Act as follows: Borrowers that received loans before June 5 can choose between using the original eight-week covered period or the new 24-week covered period. There are safe harbors for excluding salary and hourly wage reductions, and reductions in the number of employees (full-time equivalents), from loan forgiveness reductions. Health insurance costs for S corporation owners cannot be included when calculating payroll costs; however, retirement costs for S corporation owners are eligible costs. Owner compensation for the new 24 month period is limited to 2.5 months of 2019 compensation capped at $20,833(the 2.5 month equivalent of $100,000 per year). 60% of the loan should be used for payroll costs versus 75% in the original law. New Form 3508EZ: This form can be used by certain borrowers. You may use the EZ Forgiveness Application if you are a: Schedule C / Self-employed individual with no employees. Borrower who did not reduce salary/wage levels by more than 25% and did not reduce full-time equivalents (FTE’s) from Jan. 1, 2020 to end of the covered period. Borrower who did reduce salary/wage levels by more than 25% and met the safe harbor for the level of business activity as a result of health directives related to COVID-19. WHERE CAN I FIND THE NEW FORMS? The applications and instructions are available in the links below: Revised PPP Loan Forgiveness Application and instructions EZ PPP Loan Forgiveness Application and instructions HOW CAN WE HELP? If you have questions about what applications and strategies apply to your organization’s situation, we are happy to discuss them with you. For more information, visit our PPP consulting services and resources.
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