SBA Announcements Clarify New Changes & Requirements for PPP Loans

The United States Small Business Administration has spent January 2021 making several key announcements regarding Paycheck Protection Program (PPP) loans, including guidance concerning PPP loan review and several final rulings on the topic.

In total, the organization has published 15 documents or changes to existing ones in the new year so far. According to the SBA, prior to the newest program round of loans, the SBA has supported 5.2 million borrowers for loans that totaled more than $525 billion.

• The SBA added a one-page application for borrowers who received a loan of $150,000 or less called the PPP Loan Forgiveness Application Form 3508S. Borrowers who are submitting this form do not have to provide supporting documentation with it, but they do have to maintain payroll and other files in case of an audit. 
• The SBA also released three other forms: Form 3508, Form 3508EZ, and Form 3508D. For Form 3508 and Form 3508EZ, borrowers must submit payroll, non-payroll and other documentation with the forms. For Form 2508D, individuals must use this to disclose controlling interest in an entity when applying for PPP loan program funding.
• The SBA also released an interim final rule consolidating the recent changes made to the PPP program by The Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act. The act enabled $284 in new PPP program funding and created the second-draw of loans; businesses that received loans in the first round of funding last year can apply for and receive new funding provided they meet certain requirements.  

The IFRs and all forms released this month apply to both first-draw and second-draw program loans.

For a full breakdown of changes and new considerations, BKD CPAs and Advisors have published several articles recently covering each announcement. Click here and here to read the articles.