Applying for PPP Forgiveness (As Of June 8, 2020)
Summary
A slide presentation, Applying for PPP Forgiveness As Of June 8, 2020, based on Form 3508 (released 5/20/2020), IFR 136/Borrower (5/22/2020) and HR7010, the Paycheck Protection Program Flexibility Act of 2020 (6/5/2020), with a resource list of SBA partners in the Texas Gulf Coast. It says it summarizes eligible costs, required documents and guidance but gives no specific advice. It lists seven key changes under HR 7010, among them extending the covered period from eight weeks to 24 weeks, lowering the payroll-cost requirement from 75 percent to 60 percent, a safe harbor for borrowers unable to rehire employees by December 31, 2020, a maturity of five years for loans approved on or after June 5, 2020, and a longer payment deferral. It then walks through the forgiveness forms, 11 pages in five pieces, and the salary and FTE reduction rules.
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Applying for PPP
Forgiveness
As Of June 8, 2020
Based on Form 3508 (released 5/20/2020)
IFR 136/Borrower (5/22/2020)
And HR7010 - ‘Paycheck Protection Program Flexibility Act of 2020’ (6/5/2020)
For The Next 45 Minutes or so…
This Presentation Will This Presentation Will Not
• Summarize eligible costs for • Go over detailed calculations
forgiveness • Review every line of every form,
• Review documents required schedule and worksheet
• Summarize available guidance • Give specific advice for your
• Review contents of business
• Schedule A & Worksheet
• Application for Forgiveness
Please Note
• This Presentation is only an introduction to the PPP Forgiveness
Application and process.
• It includes pertinent information from guidance documents.
• You should personally review the same documents yourself.
We Recommend
For Calculation Examples and more
• From the Texas Gulf Coast Small Business Development Center
• PPP Loan Forgiveness Webinars
• Eligibility Requirements
• Required Paperwork
• General Rules Around Loan Forgiveness
• Tips for Spending PPP Loan and Maximizing Loan Forgiveness
• Check calendar – they do at different times, most days of the week:
• www.sbdc.uh.edu/sbdc/PPP-Loan-Forgiveness-Webinars.asp
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Resource Partners of the SBA
Texas Gulf Coast WBEA Women’s Business Houston SCORE
Small Business Center (WBC)
Development Center (SBDC)
713-752-8444 713-681-9232 713-487-6565
www.sbdc.uh.edu www.wbea- www.houston.score.org
texas.org/womens-business-
center
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SBA Resources & Links
For EIDL Loan Applicants Houston District Office - SBA Other SBA District Offices
• 1-800-659-2955 • 713-773-6500 www.sba.gov/about-sba/sba-
• e-mail • Houston@sba.gov locations
disastercustomerservice@sba.
gov • Twitter: @SBA_Houston
• www.sba.gov/funding- • www.sba.gov/tx/houston
programs/disaster-assistance (look under ‘Coronavirus’)
PPP Forgiveness Application PPP Forgiveness Guidance
www.sba.gov/document/sba-form--paycheck- Most Recent:
protection-program-loan-forgiveness- https://home.treasury.gov/system/files/136/PPP-
IFR-Loan-Forgiveness.pdf
application
General: https://www.sba.gov/funding-
programs/loans/coronavirus-relief-
options/paycheck-protection-program
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HR 7010 Summary
Paycheck Protection Program Flexibility Act of 2020
(6/5/2020)
Most Important
SBA, in consultation with Treasury, will
promptly issue rules and guidance,
a modified borrower application form,
and a modified loan forgiveness application
implementing these legislative amendments to the PPP
Seven Key Changes
(Changes 1-3)
1. Extends the covered period for loan forgiveness from eight weeks after loan disbursement to 24
weeks
• Borrowers who have already received PPP loans retain the option to use an eight-week covered period.
2. Lowers the requirement that 75 percent of a borrower’s loan proceeds must be used/spent for
payroll costs during the loan forgiveness covered period to 60 percent for each of these
requirements.
3. Provides a safe harbor from reductions in forgiveness, based on reductions in full-time equivalent
employees, for borrowers that are unable to return to the same level of business activity prior to
February 15, 2020, due to compliance with requirements/guidance between March 1, 2020 and
December 31, 2020 by the:
• Secretary of Health and Human Services
• Director of the Centers for Disease Control and Prevention
• Occupational Safety and Health Administration, related to worker or customer safety requirements related to
COVID–19.
Seven Key Changes
(Changes 4-7)
4. Provides a safe harbor from reductions in loan forgiveness based on reductions in full-
time equivalent employees…:
• unable to rehire individuals who were employees of the borrower on February 15, 2020
• unable to hire similarly qualified employees for unfilled positions by December 31, 2020.
5. Increases to five years the maturity of PPP loans that are approved by SBA (based on the date SBA
assigns a loan number) on or after June 5, 2020.
• For loans before that time; contact your lender to see if they will adjust to the 5-year term.
6. Extends the deferral period for borrower payments of principal, interest, and fees on PPP
loans to the date that SBA remits the borrower’s loan forgiveness amount to the lender
• or, if the borrower does not apply for loan forgiveness, 10 months after the end of the borrower’s loan forgiveness covered period.
7. Removed the restriction of participating in the deferment (employer portion) of social security payroll tax
if you received a PPP loan. Now you can defer through December 31, 2020 and pay the balance deferred
50% on December 31, 2021 and 50% on December 31, 2022.
PPP Forgiveness Overview
Applying for PPP Loan Forgiveness
• Forgiveness Forms -11 pages
• Breaks into five pieces; 1 and 2 must be submitted to Lender:
1. PPP Forgiveness Application and Attestation (pp 3 & 4)
1. Application instructions (pp 1 & 2)
2. Schedule A (p 6)
1. Schedule A instructions (p 5)
3. Schedule A worksheet (p 9)
1. Schedule A worksheet instructions (pp 7-8)
4. Documents Required with Submission and Documents to Retain (p 10)
5. Borrower Demographics (p 11)
When Completing You Will Need
• PPP Forgiveness Application package:
• www.sba.gov/ppp under ‘Loan Details and Forgiveness
• Calendar
• Calculator
• Loan documents
• Business records for use when applying
• Patience and…
Smile!
Alternative Covered Period
Period has been extended to 24 weeks
Covered Period: eight-week (56-day) Covered Period of your PPP loan. The first day of the
Covered Period must be the same as the PPP Loan Disbursement Date.
Alternative Payroll Covered Period: Borrowers with a biweekly (or more frequent) payroll
schedule may elect to calculate eligible payroll costs using the eight-week (56-day) period that
begins on the first day of their first pay period following their PPP Loan Disbursement Date.
Effect on Alternative Covered Period is not known
For example, if the Borrower received its PPP loan proceeds on Monday, April 20, and the first day of its
first pay period following its PPP loan disbursement is Sunday, April 26, the first day of the Alternative
Payroll Covered Period is April 26
Borrowers who elect to use the Alternative must apply the Alternative wherever there is a
reference to “the Covered Period or the Alternative Payroll Covered Period.”
However, Borrowers must apply the Covered Period (not the Alternative Payroll Covered Period)
wherever there is a reference to “the Covered Period” only.
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Required FTE Calculation
The actual loan forgiveness amount that the Borrower will receive may be less,
depending on whether the Borrower’s average weekly number of FTE employees during
the Covered Period or the Alternative Payroll Covered Period was less than during the
Borrower’s chosen reference period.
For each employee, for the appropriate period (Covered or Alternate Covered)
1. Take the average number of hours paid per week, divide by 40, and round the total to
the nearest tenth.
• The maximum for each employee is capped at 1.0.
2. Or, simply assign a 1.0 for employees who work 40 hours or more per week and 0.5 for
employees who work fewer hours
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Costs Eligible for
Forgiveness
What is ‘Payroll Cost’
Original IFR III 2 ii f
Payroll costs consist of
• compensation to employees (whose principal place of residence is the United States) in the form
of salary, wages, commissions, or similar compensation; cash tips or the equivalent (based on
employer records of past tips or, in the absence of such records, a reasonable, good-faith
employer estimate of such tips);
• payment for vacation, parental, family, medical, or sick leave;
• allowance for separation or dismissal;
• payment for the provision of employee benefits consisting of group health care coverage,
including insurance premiums, and retirement;
• payment of state and local taxes assessed on compensation of employees;
• and for an independent contractor or sole proprietor,
• wage, commissions, income, or net earnings from self-employment or similar compensation.
Summary of Eligible Costs - Payroll
Period has been extended to 24 weeks
• Payroll costs paid and payroll costs incurred during the eight-week (56-day) Covered Period
• Payroll costs are considered paid on the day that paychecks are distributed or the Borrower
originates an ACH credit transaction.
• Payroll costs are considered incurred on the day that the employee’s pay is earned.
• Payroll costs incurred but not paid during the Borrower’s last pay period of the Covered
Period are eligible for forgiveness if paid on or before the next regular payroll date.
• Otherwise, payroll costs must be paid during the Covered Period.
Effect on Alternative Covered Period is not known
• For each individual employee, the total amount of cash compensation eligible for forgiveness
may not exceed an annual salary of $100,000, as prorated for the covered period.
• Count payroll costs that were both paid and incurred only once.
Summary of Eligible Costs – Non Payroll
• Covered mortgage obligations:
Non Payroll has been increased to 40%
• payments of interest (not including any prepayment or payment of principal) on any
business mortgage obligation on real or personal property incurred before February 15,
2020
• Covered rent obligations:
• business rent or lease payments pursuant to lease agreements for real or personal
property in force before February 15, 2020
• Covered utility payments:
• business payments for a service for the distribution of electricity, gas, water,
transportation, telephone, or internet access for which service began before February 15,
2020
• An eligible nonpayroll cost must be paid during the Covered Period or incurred during
the Covered Period and paid on or before the next regular billing date, even if the
billing date is after the Covered Period.
• Eligible nonpayroll costs cannot exceed 25% of the total forgiveness amount.
• Count nonpayroll costs that were both paid and incurred only once
Documents Required
Documents to Submit for Payroll
Document to Submit for FTE
Documents to Submit for Non Payroll
Required to Keep (6 Years); Not Submit
PPP Forgiveness
Application
Schedule A Worksheet
Safe Harbor & Exception
Schedule A Worksheet
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Forgiveness Application will be changing
Sched A Worksheet - Table 1
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Forgiveness Application will be changing
Sched A Worksheet - Table 2
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FTE Reduction Safe Harbor
Safe Harbor date has been extended to December 31, 2020
Borrower is exempt from the reduction in loan forgiveness based
on FTE employees described above if both of the following
conditions are met:
1. the Borrower reduced its FTE employee levels in the period
beginning February 15, 2020, and ending April 26, 2020; and
2. the Borrower then restored its FTE employee levels by not
later than June 30, 2020 to its FTE employee levels in the
Borrower’s pay period that included February 15, 2020
FTE Reduction Exception
Indicate the FTE of
1. any positions for which the Borrower made a good-faith, written offer to rehire an
employee during the … Period which was rejected by the employee; and
2. any employees who during the … Period
1. were fired for cause
2. voluntarily resigned, or
3. voluntarily requested and received a reduction of their hours.
3. In all of these cases, include these FTEs only if the position was not filled by a new
employee.
4. Any FTE reductions in these cases do not reduce the Borrower’s loan forgiveness
Two New Exceptions:
unable to rehire individuals who were employees of the borrower on February 15, 2020
unable to hire similarly qualified employees for unfilled positions by December 31, 2020.
PPP Forgiveness
Application
Schedule A
Schedule A
Forgiveness Application will be changing
PPP Schedule A
Forgiveness Application will be changing
PPP Schedule A
Forgiveness Application will be changing
PPP Schedule A
Forgiveness Application will be changing
PPP Schedule A
Forgiveness Application will be changing
PPP Schedule A
PPP Forgiveness
Application
Forgiveness Application will be changing
Forgiveness Application
Forgiveness Application will be changing
PPP Forgiveness Application pg 1
Forgiveness Application will be changing
PPP Forgiveness Application pg 1
Forgiveness Application will be changing
PPP Forgiveness Application pg 1
Forgiveness Application will be changing
PPP Forgiveness Application pg 1
Forgiveness Application will be changing
PPP Forgiveness Application pg 1
Forgiveness Application will be changing
PPP Forgiveness Application pg 2
Forgiveness Application will be changing
PPP Forgiveness Application pg 2
Forgiveness Application will be changing
PPP Forgiveness Application pg 2
Smile!
May 22 IFR 136 / Borrower
Pertinent Summary
See the IFR for all details
https://home.treasury.gov/system/files/136/PPP-IFR-SBA-Loan-Review-Procedures-and-Related-
Borrower-and-Lender-Responsibilities.pdf
May 22 IFR 136 / Borrower
This is ONLY a Summary
You should review the information for yourself
IFR 136 - 2. Loan Forgiveness Process
• … complete and submit the Loan Forgiveness Application… 3508 or lender equivalent… to
lender.
• … The lender has 60 days to … issue a decision to SBA.
• …SBA will deduct EIDL Advance Amounts from the forgiveness amount remitted to the
Lender…
• If SBA determines … that the borrower was ineligible … the loan will not be eligible for loan
forgiveness.
• The lender is responsible for notifying the borrower...
• If only a portion of the loan is forgiven, or if the forgiveness request is denied, any remaining
balance … must be repaid … on or before the two-year maturity of the loan.
New guidance forthcoming – this may be changed
IFR 136 – 3. Payroll Costs Eligible for Loan Forgiveness
a. When must payroll costs be incurred and/or paid to be eligible for forgiveness?
Borrowers may seek forgiveness for payroll costs for the eight weeks beginning on either:
i. the date of disbursement of the borrower’s PPP loan proceeds from the Lender…
ii. Or the first day of the first payroll cycle in the covered period (the “alternative payroll
covered period”).
… Payroll costs incurred during the borrower’s last pay period … are eligible for forgiveness if
paid on or before the next regular payroll date;
otherwise, payroll costs must be paid during the covered period (or alternative payroll covered
period) to be eligible for forgiveness.
… this … is limited to payroll cycles that are bi-weekly or more frequent
New guidance forthcoming – this may be changed
24-week period available under the PPP Flexibility Act
IFR 136 - 3a. Example
• A borrower has a bi-weekly payroll schedule.
• … eight-week covered period begins on June 1 and ends on July 26.
• The first day of the borrower’s first payroll cycle … is June 7.
• The borrower may elect an alternative payroll covered period … that starts on June 7 and
ends … August 1.
• … payroll costs incurred during this … period are eligible for forgiveness as long as they are
paid on or before the first regular payroll date occurring after August 1.
• Payroll costs that were both paid and incurred during the … period … may only be counted
once.
IFR 136 - 3b. Are salary, wages, or commission payments to furloughed
employees; bonuses; or hazard pay during the covered period eligible for loan
forgiveness?
Yes
IFR 136 – 3c. Are advance payments of interest on mortgage obligations eligible
for loan forgiveness?
No
IFR 136 – 3d. Are there caps on the amount of loan forgiveness available for
owner-employees and self-employed individuals’ own payroll compensation?
• Yes… lesser of 8/52 of 2019 compensation… or $15,385 per individual in total across all
businesses.
• In particular … capped by the amount of their 2019 employee cash compensation and
employer retirement and health care contributions made on their behalf.
• Schedule C filers … by the amount of their owner compensation replacement, calculated
based on 2019 net profit.
• General partners … by the amount of their 2019 net earnings from self-employment
(reduced by claimed section 179 expense deduction, unreimbursed partnership expenses,
and depletion from oil and gas properties) multiplied by 0.9235.
• No additional forgiveness is provided for retirement or health insurance contributions … as
such expenses are paid out of their net self-employment income.
FAQ/Summary of IFR 136 (1 of 2)
5a. What effect does a reduction in a borrower’s number of full-time equivalent (FTE)
employees have on the loan forgiveness amount?
The borrower must first select a reference period:
(i) February 15, 2019 through June 30, 2019;
(ii) January 1, 2020 through February 29, 2020;
(iii) in the case of a seasonal employer, either of the two preceding methods or a
consecutive 12-week period between May 1, 2019 and September 15, 2019.
If the average number of FTE employees during the… period … is less than during the
reference period, the total eligible expenses available for forgiveness is reduced
proportionally…
For example, if a borrower had 10 FTE employees during the reference period and this
declined to 8 FTE employees during the covered period, the percentage… declined by
20 percent and thus only 80 percent… (is) available for forgiveness.
IFR 136 – 5b. What effect does a borrower’s reduction in employees’ salary or
wages have on the loan forgiveness amount?
… in excess of 25 percent will generally result in a reduction in the loan
forgiveness amount… calculation is performed on a per employee basis, not in
the aggregate.
New guidance forthcoming – this may be changed
60% Payroll and 40% non payroll under PPP Flexibility Act
IFR 136 – 5e. Example
• A borrower reduced a full-time employee’s weekly salary from $1,000 per
week during the reference period to $700 per week during the covered
period.
• The employee continued to work on a full-time basis during the covered
period with an FTE of 1.0.
• In this case, the first $250 (25 percent of $1,000) is exempted from the
reduction.
• Borrowers seeking forgiveness would list $400 as the … reduction for that
employee (the extra $50 weekly reduction multiplied by eight weeks).
IFR 136 - 5f. How should borrowers seeking loan forgiveness account for the
reduction based on a reduction in the number of employees … …relative to the
reduction relating to salary and wages …?
… the salary/wage reduction applies only to the portion of the decline in employee salary
and wages that is not attributable to the FTE reduction.
Example:
• An hourly wage employee had been working 40 hours per week during the borrower
selected reference period (FTE employee of 1.0)
• … the borrower reduced… hours to 20 hours per week during the covered period (FTE
employee of 0.5).
• … no change to the employee’s hourly wage during the covered period.
• Because the hourly wage did not change, the reduction in the employee’s total wages
is entirely attributable to the FTE employee reduction
• and the borrower is not required to conduct a salary/wage reduction calculation for
that employee.
SBA Resources
Texas Gulf Coast WBEA Women’s Business Houston SCORE
Small Business Center (WBC)
Development Center (SBDC)
713-752-8444 713-681-9232 713-487-6565
www.sbdc.uh.edu www.wbea- www.houston.score.org
texas.org/womens-business-
center
For EIDL Loan Applicants Houston District Office - SBA Other SBA District Offices
• 1-800-659-2955 • 713-773-6500 www.sba.gov/about-sba/sba-
• (TTY: 1-800-877-8339) locations
• Houston@sba.gov
• e-mail
disastercustomerservice@sb • Twitter: @SBA_Houston
a.gov
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