PPP Loan Forgiveness Application, Should You Wait to Apply?

New PPP Loan Forgiveness Form 3508 S To Simplify Forgiveness Process for Small Businesses

The U.S. Small Business Administration, in consultation with the Treasury Department, issued an Interim Final Rule yesterday relating to a simpler loan forgiveness application for Paycheck Protection Program (PPP) loans of $50,000 or less.

Several of the issues that make the standard application for forgiveness so confusing and time-consuming have now been removed for these small borrowers. Specifically, a borrower of a PPP loan of less than $50,000 is no longer required to reduce the amount eligible for forgiveness if the borrower:

  1. Reduces the salary or hourly wage of an employee (who earned less than $100,000 in 2019) during the “covered period” of the loan, relative to the first quarter of 2020, or
  2. Reduces full-time equivalent employees (FTEs) during the covered period relative to a base period.

Simply stated, these borrowers are now exempt from the FTE reduction and salary reduction rules.  Additionally, the new one-page form (plus the optional demographic information form), requires only certifications. Calculations on how you came to your final numbers, do not need to be shown. Howeverthe instructions make clear that the SBA may request from the borrower support for their computation at any time.

For your convenience here are further resources for your review around this matter:

  • Click here to view the simpler loan forgiveness application.
  • Click here to view the instructions for completing the simpler loan forgiveness application.
  • Click here to view the Interim Final Rule on the simpler forgiveness process for loans of $50,000 or less

How Can KatzAbosch Help?

Each borrower has their own individual set of circumstances, and the answers are not always clear. If you have questions about your situation, please reach out to your KatzAbosch representative or contact us.

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