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Home Source documents Basics of Paycheck Protection Program (PPP) Loan Forgiveness and the Small Business Administration (SBA) PPP Loan Forgiveness Platform — Overview of PPP Loan Forgiveness Process, Ask the Regulators Session (September 3, 2020)

Basics of Paycheck Protection Program (PPP) Loan Forgiveness and the Small Business Administration (SBA) PPP Loan Forgiveness Platform — Overview of PPP Loan Forgiveness Process, Ask the Regulators Session (September 3, 2020)

Summary

Slides from an Ask the Regulators session on September 3, 2020, Basics of Paycheck Protection Program (PPP) Loan Forgiveness and the SBA PPP Loan Forgiveness Platform, with speakers Bill Briggs, Ginger Allen and Marty Andrews of the SBA, Cailin Schmeer of the U.S. Treasury and Ben Wallace of The Summit Group. The presentation describes itself as a general, non-comprehensive review and states that official guidance, including the CARES Act, the Paycheck Protection Program Flexibility Act of 2020 and the PPP interim final rules, governs in any conflict. It covers an overview of the forgiveness process, the loan forgiveness platform and how lenders submit decisions, followed by questions and answers. Information is current as of 9/3/20.

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Basics of Paycheck Protection Program(PPP)
 Loan Forgiveness and the Small Business
Administration (SBA) PPP Loan Forgiveness
                 Platform

 Speakers:

      ►Bill Briggs, SBA
      ►Cailin Schmeer, U.S. Treasury
      ►Ginger Allen, SBA
      ►Ben Wallace, The Summit Group
      ►Marty Andrews, SBA


                         September 3, 2020
                                              Welcome everyone

• Today’s session
• Questions:
   – Email your question to: asktheregulators@stls.frb.org
      or
   – Use the “Ask Question” button in the webinar tool
• This call is being recorded and will be available following the
  session.
   – Archived recording can be accessed using the same link as today’s webinar.
• A survey will be delivered via email following the call. Let us know
  your thoughts or ideas for future sessions.

                                                                                  2
                                                  Overview of
                     PPP Loan Forgiveness Process

                                               September 3, 2020

                                  Ask the Regulators Session
This presentation is developed to provide a general, non-comprehensive review of PPP loan forgiveness. In the event of any
inconsistency between this presentation and the CARES Act, the Paycheck Protection Program Flexibility Act of 2020, PPP IFRs, FAQs,
Loan Forgiveness Applications and Instructions, and other PPP guidance (together, official guidance), the official guidance governs.
           What this Session Will Cover:


      1      Overview of PPP Loan Forgiveness

             Loan Forgiveness Platform &
      2
             How To Submit Lender Decisions

      3      Q & A with Panel




                                                                                                4
Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                           PPP Loan Forgiveness Basics
Borrowers are eligible for forgiveness in an amount equal to the sum of the eligible costs and
payments during the 8-week or 24-week Covered Period:
                      Eligible Costs                                             Additional Considerations
                                                                    • Payroll costs must account for at least 60% of
         Payroll Costs                                                the total PPP forgiveness amount or the
                                                                      amount of forgiveness will be reduced
         Business Rent Payments
                                                                    • Salary / wage reduction can be no more than
         (lease effective prior to February 15, 2020)                 25% during the Covered Period or the amount
                                                                      of forgiveness will be reduced (certain
         Mortgage Interest Payments                                   exemptions / safe harbors may apply)
         (incurred prior to February 15, 2020)                      • Borrower must maintain the average number
                                                                      of full-time equivalent (FTE) employees during
         Utility Payments                                             the Covered Period or the amount of
         (service in place prior to February 15, 2020)
                                                                      forgiveness will be reduced (certain
                                                                      exemptions / safe harbors may apply)


                                                                                                                       5
               Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                       Payroll Cost Considerations

Timing: To be eligible for forgiveness, payroll costs must be:

1. Incurred or paid during the Covered Period or Alternative Payroll
   Covered Period.
2. Incurred before the Covered Period or Alternative Payroll Covered
   Period, but paid during the Covered Period or Alternative Payroll
   Covered Period.
3. Incurred during the Covered Period or Alternative Payroll Covered
   Period, but paid on or before the next regular payroll date after the
   Covered Period or Alternative Payroll Covered Period.

                                                                                                           6
           Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                Loan Forgiveness Process and Timeline

          Borrower                                    Lender                                    SBA Review
         Application                                 Review &                                       &
         Submission                                 Submission                                  Remittance
                                                                                      SBA reviews lender decisions
                                          Lender reviews and submits                   & makes a determination on
 Borrower submits forms and
                                          forgiveness decision to SBA                  loan forgiveness, subject to
  documentation to lender
                                                                                      any SBA review of the loan or
                                                                                             loan application
If borrower does not submit                            60 Days                                      90 Days
Forgiveness Application within
10 months of the end of the
Covered Period, deferral on PPP
loan ends, and borrower must
begin making payments.

                                                                                                                      7
                  Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
         Borrower Documentation Requirements
What documentation does the borrower submit to the lender with its forgiveness
application?
In addition to the signed Forgiveness Application Form (SBA Form 3508, 3508EZ, or lender
equivalent) borrowers are generally expected to submit the following (see SBA Form 3508 or
3508EZ instructions for specific details):
    1.   Payroll: Proof of payment
    2.   Nonpayroll: Proof of obligation and proof of payment
    3.   3508 Only: PPP Schedule A and FTE Documentation
    4.   3508EZ Only: FTE Information (if applicable)
    For each form, there are certain documents that the borrower is required to maintain, but not
    submit. See Instructions to forms.
    Additionally, all loans $2 million and over will be subject to SBA loan reviews and additional
    documentation will be required.


                                                                                                          8
          Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
            Borrower Documentation – Payroll

Documents Must Provide Proof of Eligible Costs (e.g., that
payments were made towards eligible payroll costs and within the
eligible Covered Period or Alternative Payroll Covered Period) with the
following:
1. Bank account statements or third-party payroll service provider
   reports documenting the amount of cash compensation paid to
   employees.
2. Tax forms or equivalent third-party payroll service provider reports.
3. Payment receipts documenting the amount of any employer
   contributions to employee health insurance and retirement plans.
See Instructions to forms for other acceptable documents.
                                                                                                         9
         Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
         Borrower Documentation – Non-Payroll

Documents Must Provide Proof of Eligible Costs (e.g., that
verify existence of eligible non-payroll obligations/services prior to
February 15, 2020 and eligible payment from the Covered Period) with
the following if borrower includes nonpayroll expenses in the amount
requested for forgiveness:
1. Business mortgage interest payments – amortization schedule
   and receipts.
2. Business rent or lease payments – lease agreement and receipts.
3. Business utility payments – invoices from February 2020 and
   invoices paid during Covered Period and receipts.
See Instructions to forms for other acceptable documents.
                                                                                                         10
         Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
   Borrower Forgiveness Application Submission FAQ
Question: Who can use the SBA Form 3508EZ forgiveness
application?

Answer: (See Form 3508EZ instructions, page 1)
1) Self-employed individual, independent contractor, or sole proprietor who had no employees
   at the time of the PPP loan application and did not include any employee salaries in the
   calculation of their average monthly payroll (when determining their eligible loan amount); or
2) Borrower didn’t reduce annual salary or hourly wages of any employee by more than 25%
   during Covered Period or Alternative Payroll Covered Period and didn’t reduce the number
   of employees or the average paid hours of employees between 1/1/20 and the end of
   Covered Period; or
3) Borrower didn’t reduce salary or wages of any employee by more than 25% during Covered
   Period or Alternative Payroll Covered Period and was unable to operate during Covered
   Period at the same level of business activity as before 2/15/20 due to compliance with HHS,
   CDC, or OSHA restrictions issued between 3/1/20 and 12/31/20 related to COVID-19.
                                                                                                               11
               Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
   Borrower Forgiveness Application Submission FAQ
Question: May a borrower submit a forgiveness application
before the end of their covered period?

Answer: Yes, if the borrower has used all the loan proceeds for which it is
requesting forgiveness.
If borrower reduced annual salary or hourly wages by more than 25%,
borrower must account for the reduction for the full Covered Period (either
8- or 24-week period beginning on the PPP Loan Disbursement Date).




                                                                                                             12
             Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
     Lender Reviews – Making a Forgiveness Decision
                    Lenders Have Four Decision Options:
❑ Approved in Full – Lender approved the full forgiveness amount requested by
   borrower, and the forgiveness amount requested by lender equals that amount.
❑ Approved in Part – Lender did not approve the full forgiveness amount requested by
   borrower and the forgiveness amount decision by lender is less than the forgiveness
   amount requested by borrower.
❑ Denied – Lender denied the entire forgiveness amount requested by the borrower.
❑ Denied without Prejudice – Lender should use this status when SBA notifies the
   lender that a loan review is pending at the time the borrower submits a loan forgiveness
   application.




                                                                                                              13
              Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                       Overview of Forgiveness Process
Lenders will use the Forgiveness Platform for all aspects of the forgiveness process:

                                                     Lender Decision
              Account Creation                                                                   Monitoring
                                                       Submission


      •   Authorizing Officials (AOs)         •   Lenders submit their                •   Lenders monitor their
          receive a “Welcome to                   forgiveness decisions via               Forgiveness submissions
          Forgiveness” email with                 the Forgiveness Platform.               and respond to any SBA
          instructions on how to                                                          inquiries.
                                              •   Lenders upload any
          access the Forgiveness                  supporting documents for            •   Lenders receive SBA's
          Platform and create an                  their decisions.                        decision on each
          account.                                                                        submission within 90 days,
                                              •   Lenders upload ACH
      •   Initial AO creates their                                                        subject to SBA review of
                                                  instructions and
          Platform Account.                                                               loan or loan application.
                                                  Confirmations.
      •   AOs can select up to 10                                                     •   Lenders monitor their
          members at their institution                                                    payment status.
          to receive access to the                                                    •   AOs view institution’s total
          Forgiveness Platform.                                                           application portfolio for
                                                                                          reporting.
                                                                                                                         14
                   Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                                  Forgiveness Platform
• The Forgiveness Platform can be accessed at forgiveness.sba.gov.
• The Platform supports three
  methods of submission for
  lender forgiveness decisions:
   1. Lenders can manually enter
      data and upload supporting
      documentation.
   2. Lenders can connect via API
      and submit lender decisions in
      bulk.
   3. Software Providers can
      connect via API and submit
      decisions on behalf of lenders.

• Use MS Edge or Google Chrome browsers for an optimal experience.
• Complete information on APIs can be found at https://ussbaforgiveness.github.io/.
                                                                                                               15
               Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
    Forgiveness Platform – Resources




                                                                                                16
Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
         Forgiveness Platform - Videos




                                                                                                17
Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
Forgiveness Platform – Payment Settings




                                                                                                 18
 Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
Forgiveness Platform – Lender Decision Reminder




                                                                                                     19
     Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
Forgiveness Platform – Communication Tools




                                                                                                   20
   Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                  Forgiveness Platform Submission Process
1. Verify Loan Status                                                     1
• Click “Lookup Disbursed Loans”
• Search for the loan



2. Create New Decision                                                    2
• Four options
• Click “New PPP Decision Submission”
• Select an application form
• Enter loan information



3. Add Supporting Documents
                                                                          3
• Signed Form 3508/3508EZ or lender equivalent
• PPP Schedule A for Form 3508
• Demographic Information Form (if provided)



                        Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.   21
         Forgiveness Platform Submission Process (cont’d)
                                                                 4            4
4. Confirm Lender Forgiveness Decision

• Confirm that forgiveness decision criteria has been met
• Designate the decision
• Click “Submit Decision” if the application is complete




5. Monitor Forgiveness                                          5
• Click “All Forgiveness Submissions”
• Locate loans by filtering for status OR searching for the SBA
  Loan Number
• View the application status




                                                                                                                         22
                         Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                 Forgiveness Monitoring




                                                                                                23
Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                       SBA Loan Review Overview
  If a loan is selected for an SBA loan review, the lender will be
  notified via the Forgiveness Platform. See SBA Procedural Notice
  5000-20038 (July 23, 2020), Procedures for Lender Submission of
  Paycheck Protection Program Loan Forgiveness Decisions to SBA
  and SBA Forgiveness Loan Reviews.




What will SBA
review?

                                                                                                           24
           Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
              SBA Forgiveness Payment to Lender

When SBA remits forgiveness payment to
lender, lender must notify borrower of:
•   Amount of forgiveness payment received (or that
    SBA determined no amount of the loan is eligible for
    forgiveness)
•   Due date of borrower’s first payment (if applicable)




                                                                                                            25
            Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
        Economic Injury Disaster Loan (EIDL) FAQ
Question: How will a lender know the amount of the EIDL
advance that will be automatically deducted by SBA?


Answer: If a borrower received an EIDL advance, SBA is required to
reduce the borrower’s loan forgiveness amount by the amount of the
EIDL advance. SBA will deduct the amount of the EIDL advance from the
forgiveness amount remitted by SBA to the lender. The lender will be
able to confirm the amount of the EIDL advance that will be automatically
deducted by SBA from the forgiveness payment by reviewing the
borrower’s EIDL advance information in the Forgiveness Platform.



                                                                                                           26
           Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                               Remaining Balance FAQ
Question: How should a lender handle any remaining
balance due on a PPP loan after SBA remits the forgiveness
amount to the lender?

Answer: If a PPP loan is not forgiven in full (including if there has been a
reduction in the forgiveness amount for an EIDL advance), any remaining
balance due on the PPP loan must be repaid by the borrower.
•   Lenders must notify borrower of the loan forgiveness amount remitted by SBA and the date on
    which the borrower’s first loan payment is due.
•   The lender must continue to service the loan.
•   The borrower must repay the remaining loan balance by the maturity date of the PPP loan
    (either two or five years).
If a borrower is determined to have been ineligible for a PPP loan for any reason, SBA
may seek repayment of the outstanding PPP loan balance or pursue other available
remedies.
                                                                                                              27
              Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
               General Forgiveness Process FAQs
•   How do lenders access the portal?                         •    Is there a maximum number of documents
    This platform can be accessed at                               that can be uploaded with each application?
    forgiveness.sba.gov.                                           No, lenders may submit an unlimited number of
                                                                   documents with each application. The Platform
•   How do lenders contact the SBA?                                supports pdf, xls, xlsx, csv, doc, docx, jpg, jpeg,
    The SBA’s PPP Lender Hotline is +1 (833) 572-                  and png files. The total document limit is 35 MB.
    0502.
                                                              •    Which version of the forgiveness application
•   Where can lenders find information about                       should lenders use (3508EZ or 3508)?
    APIs?                                                          When entering a forgiveness decision on the
    A complete guide for Platform API use can be                   Forgiveness Platform, lenders should use
    found here.                                                    whichever version of the form the borrower
                                                                   provided. Instructions on determining if a
•   How many Platform users can each institution                   borrower is eligible to use the 3508EZ form can
    have?                                                          be found here.
    Authorizing Officials may create up to 10 active
    users for each institution. We recommend that no
    more than two users be Authorizing Officials.



                                                                                                                         28
                 Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                 General Forgiveness Process FAQs
•   How long will it take to receive an SBA                   •    Should the Forgiveness Amount on Line 11 of the
    forgiveness decision?                                          3508 or Line 8 of the 3508EZ include the EIDL
    SBA has 90 days to review and remit payment to                 deduction?
    the lender, subject to any SBA loan review.                    No, SBA automatically will reduce the Forgiveness
                                                                   Amount by the amount of any EIDL Advance before
•   Can documents be added to a forgiveness                        remitting the payment to the lender. Lenders should
    submission after it is submitted?                              input the EIDL Advance information provided by the
    No, submissions must be withdrawn and                          Borrower on the 3508/3508EZ, where requested in
    resubmitted with two exceptions:                               the Platform, but should not subtract it from the
    o If a lender is using APIs, a lender generally                Forgiveness Amount.
       has 24 hours after submission to add
       additional documents to the file. After the            •    Can a borrower appeal a final SBA loan review
       SBA picks up the review, the Platform doesn’t               decision?
       allow additional documents or file changes.                 Borrowers may appeal to SBA’s Office of Hearings
    o The Platform will allow a lender or API vendor               and Appeals (OHA) certain final SBA Loan Review
       to add additional documents if the SBA asks                 decisions. Lenders do not have a right to appeal to
       for additional documents as part of its review.             OHA. Please see Interim Final Rule on Appeals of
                                                                   SBA Loan Review Decisions under the Paycheck
                                                                   Protection Program posted on 8/11/20 at
                                                                   www.sba.gov/ppp.

                                                                                                                         29
                  Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
          Helping Lenders Be Succesful
      Phone: SBA PPP Lender Hotline – +1 (833) 572-0502


      Email: SBA Forgiveness Inbox – help@ussbaforgiveness.com


      Forgiveness Platform Resources: https://forgiveness.sba.gov


      Web: www.SBA.gov/ppp
      • FAQs
      • Interim Final Rules & Guidance
      • Loan Forgiveness Applications (3508 / 3508EZ) and Instructions


                                                                                                30
Information Current as of 9/3/20 – Visit www.sba.gov/ppp for the most up-to-date information.
                                        To Ask a Question:

• Email your question to: asktheregulators@stls.frb.org

• Use the “Ask Question” button in the webinar tool




                 Thanks for joining us.


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