FORGIVENESS - REVISED
Paycheck Protection Program (PPP)
IMPORTANT UPDATE as of June 23, 2020
CLARIFICATION OF FORGIVENESS GUIDANCE:
On June 22, 2020, SBA issued clarification of key points for the forgiveness process:
- You can apply for forgiveness any time on or before the maturity of the loan, including before the end of the 8-week or 24-week Covered Period, if you have spent all of the funds for which you are requesting forgiveness. However, if you have reduced wages for individual employees more than 25%, the excess weekly salary reduction must be multiplied by either the full 8 weeks or the full 24 weeks, even if you apply early.
- If you do not apply for forgiveness within 10 months of the end of your Covered Period, the loan deferral will end and you must begin paying principal and interest.
- If your PPP loan was funded in the middle of a payroll period, you can either pro-rate the payroll to only include the days that fall within your Covered Period or you can use an Alternate Covered Period that starts on the 1st day of your 1st payroll after your loan funding and continues for 8 or 24 weeks after.
- Non-payroll costs can be pro-rated, provided the expense is incurred during the Covered Period and the bill is paid on or before the next regular billing date, even if that billing date is after the Covered Period.
- The FTE deduction can be waived if you can document that your business activity was lower during the period of 3/1/20 to 12/31/20 than it was prior to 2/15/20, as a result, directly or indirectly, of COVID requirements and guidance at the national or state level (such as requiring closure of your business or reduced capacity). Documentation would include your relevant financial records and copies of the applicable COVID requirements or guidance.
Click here to access SBA Form 3508EZ and instructions.
Click here to access the revised SBA Form 3508 and instructions.
Click here to read the Interim Final Rule issued on June 22, 2020.
AMERICAN NATIONAL BANK – FORGIVENESS PROCESS:
SBA is not yet accepting applications from banks for forgiveness. Once SBA is ready, the Bank will email you a link to login into the online application software. This is how you will fill out the application and upload supporting documents. Please be sure to check your email and the Bank’s website for updates.
We also continue to strongly recommend that you check the Treasury’s website for updated information and guidance (click here), read the relevant CARES Act sections (click here), and consult with your CPA and/or attorney for professional advice, as Borrowers are solely responsible for their use of PPP funds and should not rely on American National Bank and its own interpretation of the Act.