Home / News and Resources / #24: Forgiveness Process Update, Including Under $50,000 Streamline

#24: Forgiveness Process Update, Including Under $50,000 Streamline

Citizens Bank is now ready to begin accepting applications for PPP forgiveness. Depending on your loan size, our recommended actions are outlined below along with a list of documents you will need to complete and submit to start the process.

In all cases, please submit your documents and questions directly to the Citizens Bank lender who originally assisted you with your PPP Application.

Loans $50,000 and under:

On 10/08/20 the SBA published a newer simplified application – the 3508S form. As a borrower you are still required to make the forgiveness calculations and compile and submit supporting documentation to the bank, but we expect to see an expedited approval process on these loans. Instructions to complete the 3508S can be downloaded here.

Loans of $150,000 or more:

You are required to submit either the 3508 or 3508EZ application. The EZ application allows eligible borrowers to submit a PPP loan forgiveness application with fewer calculations and less documentation. Borrowers are eligible to use the EZ application to apply for loan forgiveness if they fall into one of the following three categories:

  • The borrower is a self-employed individual, independent contractor, or sole proprietor with no employees at the time of the PPP loan application.
  • The borrower did not reduce by more than 25% the salary of any employee who did not have annualized salary of more than $100,000 during any single pay period in 2019 and did not reduce the number of employees or the average paid hours of employees during the loan period (ignoring reductions in employees or paid hours that arose from an inability to rehire similarly qualified employees for unfilled positions or an employee refused to be a restoration of hours).
  • The borrower did not reduce by more than 25% the salary of any employee who did not have annualized salary of more than $100,000 during any single pay period in 2019 and was unable to operate, or was operating at a lower level of business activity, during the loan period due to compliance with sanitation, social distancing, or any other safety requirements or guidance issued by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration related to COVID-19.

The EZ Application does not eliminate the obligation to keep and provide underlying documents to determine loan forgiveness amounts.

3508 Application and Instructions

3508EZ Application and Instructions

Loans Between $50,001 and 149,999:

Citizens Bank recommends that if your loan amount is in this range that you consider continuing to wait to see what may happen on Capital Hill prior to submitting your package. There is a consensus in Washington that loans in this range will or should be provided blanket forgiveness without going through the full application process. It appears that if another COVID relief package passes this will be included, but who can say what Congress may accomplish in a highly charged election year.

We recognize that our PPP borrowers are making other financial decisions around whether or not their PPP loan will be fully or partially forgiven. If you feel you simply must apply now, we will accept your application, but it is possible that on full review you may receive partial forgiveness now, while future program changes may lead to you receiving full forgiveness in an expedited process. Should you decide to apply now, you will follow the same instructions above for loans over $150,000.

Regardless of your loan size and the application you submit, Citizens Bank will require the documentation indicated found by clicking the following links--Supporting Documents for PPP Forgiveness and Loan Forgiveness Acknowledgment--to consider your application complete. Once a completed application is received the bank has 60 days in which to respond, and the SBA has an additional 90 days to render their decision. Both of these documents can be found at our PPP page.

We plan to handle the forgiveness process with diligence and attention to detail in order to provide our borrowers the greatest potential forgiveness. We will generally prioritize loan balances under $50,000 and those over $150,000 in our initial underwriting efforts but will respond to all complete applications within the timeframes indicated above.

We anticipate needing to reach back out to our borrowers for clarifications and additional documents along the way and ask for your patience and speedy response to our requests.

We look forward to working with you to attain a satisfactory conclusion to what has at times been a confusing and frustrating process. Our focus has been and will continue to be on attaining the most potential benefit to our valued customers.

As always, we stand ready to answer your questions about the PPP using the best available information.

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.

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