The SBA Paycheck Protection Program loan forgiveness portal opens today – Monday August 10th. In preparation, the SBA and the Treasury Department issued a Frequently Asked Questions (FAQs) on PPP Loan Forgiveness. While the FAQ does not answer every question, it does provide additional clarity regarding timing issues related to payroll costs and eligible nonpayroll costs (including business interest, rent, and utilities), allowable costs, and forgiveness reductions. The full PPP FAQ is available online.
Following are links for the two forgiveness applications, both of which include additional instructions.
As a reminder, a Borrower may use the 3508EZ if it meets at least one of the three following safe harbors:
- You are self-employed and do not have any employees; or
- You did not reduce annual salary or hourly wages of any employee by more than 25%, and you did not reduce the number of employees or the average paid hours between January 1, 2020 and the end of your covered period; or
- You did not reduce annual salary or hourly wages of any employee by more than 25%, and you were unable to operate at the same level of business during the covered period due to public health directives
Attached are separate lists of for each application format (3508 and the 3508EZ) as a guide to what additional information Borrowers will need to submit with their forgiveness application.
As part of the process, Citizens Bank will additionally require the attached Loan Forgiveness Acknowledgment be included with every application. This document acknowledges that while Citizens Bank has attempted to provide timely and accurate information throughout the loan process, the covered period and now forgiveness, that we are not in a position to provide definitive program advice. You are strongly encouraged to consult your outside advisors – your CPA and your attorney, etc. – for guidance on applying for receiving full loan forgiveness.
While we are now accepting forgiveness applications, Citizens Bank anticipates that we will wait a few days to a week to begin to formally submit them to the forgiveness portal. This will allow time to ensure the SBA’s site is up and functional, and to hopefully receive additional guidance. There also seems to be bi-partisan Congressional support to accomplish some type of automatic or streamlined forgiveness. Thus far the consensus (if you can ever find one in Washington) is that loans below $150,000 may receive some form of automatic forgiveness.
For this reason, we encourage borrowers with loan amounts less than $150,000 to wait to see if a legislative solution is provided. There is no “cost” to wait as any forgiveness granted will be on a principal plus interest basis.
As with the application process, we ask your patience as we begin to work through the SBA portal. Our commitment to you is that we will work in a thoughtful and methodical way to process your application as quickly as possible.
Citizens Bank recommends that you consult your outside advisors and experts in all matters relating to the PPP and loan forgiveness. We will work to provide you timely and accurate information, but the burden for obtaining forgiveness rests on the borrower. All information provided in this format or any other communication regarding the program is believed to be accurate, but no guarantee is or can be made by any Citizens Bank representative.
Please submit your questions to pppquestions@citizens-banking.com. Include the name of your business in your e-mail. We will endeavor to answer in a timely way with the best information currently available.