Pandemic Darlings The pandemic economy, in original documents
Home Source documents Applying for PPP Forgiveness As Of May 29 2020

Applying for PPP Forgiveness As Of May 29 2020

Summary

A slide presentation, Applying for PPP Forgiveness As Of May 29 2020, based on Form 3508, released 5/20, and on IFR 136 for borrowers, dated 5/22. The slides say the presentation will summarize eligible costs for forgiveness, review documents required, explain the safe harbor and exception, and review the contents of Schedule A and its worksheet and the application for forgiveness. They state that it will not go over detailed calculations, review every line of every form or give specific advice for a business, and that it is only an introduction to the PPP forgiveness application and process.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Applying for PPP
  Forgiveness
        As Of May 29 2020
Based on Form 3508 (released 5/20)
   And IFR 136/Borrower (5/22)
                   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
• Explain safe harbor and          • Give specific advice for your
  exception                          business
• Review contents of
   • 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




                                                                          5
                    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




                                                                                 6
                                 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




                                                                                                                 7
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
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.

    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.
                                                                                                                          12
                        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


                                                                                        13
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
• 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.
• 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:
    • 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




                       24
Sched A Worksheet - Table 1




                              25
Sched A Worksheet - Table 2




                              26
               FTE Reduction Safe Harbor

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
PPP Forgiveness
  Application
  Schedule A
Schedule A
PPP Schedule A
PPP Schedule A
PPP Schedule A
PPP Schedule A
PPP Schedule A
PPP Forgiveness
  Application
Forgiveness Application
PPP Forgiveness Application pg 1
PPP Forgiveness Application pg 1
PPP Forgiveness Application pg 1
PPP Forgiveness Application pg 1
PPP Forgiveness Application pg 1
PPP Forgiveness Application pg 2
PPP Forgiveness Application pg 2
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
                         IRF 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.
                  IRF 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
                                   IRF 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.
 IRF 136 - 3b. Are salary, wages, or commission payments to furloughed
employees; bonuses; or hazard pay during the covered period eligible for loan
                               forgiveness?



                                    Yes
  IRF 136 - 3c. 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.
         IRF 136 - 4. Nonpayroll Costs Eligible for Loan Forgiveness (1 of 2)
a. When must nonpayroll costs be incurred and/or paid to be eligible for forgiveness?


   …if it was
   (i)   paid during the covered period; or
   (ii) 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.
                              IRF 136 – 4a Example

A borrower’s covered period begins on June 1 and ends on July 26.
 The borrower pays its May and June electricity bill during the covered period and
  pays its July electricity bill on August 10...
 … May and June electricity bills … were paid during the covered period.
 … the borrower may seek loan forgiveness for the portion of its July electricity bill
  through July 26… because it was incurred during the covered period and paid on the
  next regular billing date.
IRF 136 - 4b. Are advance payments of interest on mortgage obligations eligible
                                   for loan forgiveness?

                                           No



                 IRF 136 – 5. Reductions to Loan Forgiveness Amount
 a. Will a borrower’s loan forgiveness amount be reduced if the borrower laid-off or reduced
the hours of an employee, then offered to rehire the same employee for the same salary and
  same number of hours, or restore the reduction in hours, but the employee declined the
                                           offer?


                                            No
                       FAQ/Summary of IRF 136 (1 of 2)
5b. 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.
                      FAQ/Summary of IRF 136 (2 of 2)
5b. What effect does a reduction in a borrower’s number of full-time equivalent (FTE)
                  employees have on the loan forgiveness amount?

 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.
IRF 136 – 5c. What does “full-time equivalent employee” mean?



           Full-time equivalent employee means an
           employee who works 40 hours or more, on
           average, each week.
IRF 136 - 5d. How should a borrower calculate its number of full-time equivalent
                                (FTE) employees?

 … borrowers must divide the average number of hours paid for each employee per
 week by 40, capping this quotient at 1.0.
 For example, an employee who was paid 48 hours per week during the covered
 period would be considered to be an FTE employee of 1.0.
 … (if employee works) less than 40 hours per week, borrowers may choose to
 calculate … in one of two ways.
     1. … if an employee was paid for 30 hours per week on average during the
        covered period, the employee could be considered to be an FTE employee of
        0.75… (30/40).
     2. … borrowers may elect to use… 0.5 for each part-time employee.
 … must apply (the chosen) method consistently …
IRF 136 – 5e. 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.
                        IRF 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).
   IRF 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.
 IRF 136 - 5g. If a borrower restores reductions made to employee salaries and
wages or FTE employees by not later than June 30, 2020, can the borrower avoid a
                  reduction in its loan forgiveness amount?

                                       Yes



   IRF 136 – 5h. Will a borrower’s loan forgiveness amount be reduced if an
employee is fired for cause, voluntarily resigns, or voluntarily requests a schedule
                                    reduction?
                                       No
                                 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
                                                                                            65


File and source

File
PPP_Forgiveness_June_1.pdf
Size
7,811,507 bytes
SHA-256
f4aedc42f662dc786a344076008399409b587016fc5c4caad4bea16f91a1cb16
Our copy
PPP_Forgiveness_June_1.pdf
Original
www.sba.gov
Back to top