Home / News and Resources / #27: PPP Loan Forgiveness Update for Loans Over $150,000

#27: PPP Loan Forgiveness Update for Loans Over $150,000

The SBA is actively accepting and processing forgiveness applications, and Citizens Bank has received forgiveness on several loans already.  If your PPP loan is over $150,000, the path is clear for you to proceed with your forgiveness application. 

The only reason to consider waiting at this point is if you also took an SBA Economic Injury Disaster Loan (EIDL) and received an initial advance up to $10,000.  The SBA has thus far been netting the advance amount from PPP forgiveness, but there is some hope for a legislative fix for this issue in the coming weeks and months.  If you received an EIDL advance, it is the opinion of Citizens Bank that you should wait to apply for forgiveness of your PPP loan until this issue is clarified.

How do I apply for SBA PPP Forgiveness?

To apply for forgiveness, 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.

Please note: The EZ Application does not eliminate the obligation to provide and maintain the supporting documents to determine loan forgiveness amounts.

3508 Application and Instructions

3508EZ Application and Instructions

Additionally you will be required to submit a Loan Forgiveness Acknowledgment.

Keep in mind your Covered Period for both the 3508 and the 3508EZ must be either 8 weeks or 24 weeks.  It is acceptable to use your loan funds in less than 24 weeks, and you will only need to document the actual time period in which you used the PPP funds, but the covered period must be indicated as either 8 or 24 weeks on the application regardless.

Use our secure server to submit your request and supporting documents. Please submit your application to the Citizens Bank lender that originally helped you with your PPP application.

Once a completed application is received the bank has 60 days in which to respond to you or submit your application to the SBA, and the SBA has an additional 90 days to render their decision.  We anticipate needing to reach back out to our borrowers for clarification 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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