Paycheck Protection Program Loan Forgiveness Guidance

May 20, 2020
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On May 18, the Small Business Administration released the official Paycheck Protection Program (PPP) Loan Forgiveness Application. We are here to help you understand how to complete the application, document your costs, and maximize your forgiveness portion of the loan. 

Below you will find some key definitions, instructions, and suggestions on records you will need to keep. Please do not hesitate to reach out to us if you need any assistance. We are here to guide you and make sure you fully understand this information. 

KEY DEFINITIONS:

Payroll:

  • “Covered Period”: First day of loan receipt and subsequent 56 days. 
  •  “Alternative Payroll Covered Period”: For payroll purposes, starts with date of first paid payroll and then 56 days thereafter is the last day.
  • Eligible Payroll: Choose between Covered or Alternative methods; both equal 56 days.  Eligible payroll includes paid amounts as well as any earned, unpaid amounts as long as paid on subsequent payroll after the 56 day period. Eligible payroll amount per employee CANNOT exceed $15,385 in total for the 56 day period. 

Eligible Nonpayroll: An eligible nonpayroll cost must be paid or incurred during the Covered Period.  It appears prepaying expenses beyond the Covered Period is not eligible.

INSTRUCTIONS FOR CLIENTS:

Where to Start?  

  1. Begin with PPP Schedule A Worksheet (“Worksheet) and complete Tables 1 and 2; then, complete steps for Full-Time Equivalents (FTE) Reduction Safe Harbor.
  2. Use Worksheet to complete PPP Schedule A.
  3. Use PPP Schedule A to complete Loan Forgiveness Calculation Form.

What to Submit to Lender?

  • PPP Schedule A
  • PPP Loan Forgiveness Calculation Form
  • Documentation:
    • Payroll:
      • 941s for the Covered or Alternative 8-week period
      • State quarterly wage reporting and unemployment insurance tax filings
      • Bank statements or third-party reports detailing compensation paid
    • FTE Documentation:
      • The average number of FTE employees on payroll per month employed by the Borrower between February 15, 2019 and June 30, 2019; 
      • The average number of FTE employees on payroll per month employed by the Borrower between January 1, 2020 and February 29, 2020; or 
      • In the case of a seasonal employer, the average number of FTE employees on payroll per month employed by the Borrower between February 15, 2019, and June 30, 2019; between January 1, 2020, and February 29, 2020; or any consecutive 12-week period between May 1, 2019, and September 15, 2019
    • Nonpayroll Documentation:
      • Mortgage Interest Payments:  
        • Amortization schedule
        • Receipts or cancelled checks
      • Rent/Lease Payments:
        • Lease agreement
        • Receipts or cancelled checks
      • Business Utility Payments:
        • Copies of invoices
        • Cancelled Checks or account statements verifying payment 

RECORDS TO KEEP:

  • Keep all submitted information AND Worksheet A as well as any employee job offers/refusals, firings, resignations, and written employee requests for reductions in work.
  • Must keep for 6 years from date of loan forgiveness OR date loan is repaid in full.

APPLICATION LINK:

https://home.treasury.gov/system/files/136/3245-0407-SBA-Form-3508-PPP-Forgiveness-Application.pdf

This form can be confusing and hard to understand. Please give us a call if you have any questions. 

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