New forgiveness applications

The U.S. Small Business Administration (SBA), in consultation with the Department of the Treasury, posted revised Paycheck Protection Program (PPP) loan forgiveness applications on Wednesday, June 17, 2020. The revised applications implement changes enacted by the PPP Flexibility Act of 2020, signed into law by President Trump earlier this month. In addition to tweaking the full forgiveness application, the SBA also published a new EZ version of the forgiveness application that may be used by certain borrowers. There is already confusion about which borrowers are permitted to use the EZ application. If you are one of the lucky ones, the EZ application requires fewer calculations and less documentation.

Click here for the EZ Forgiveness Application and Instructions.

Click here for the Full Forgiveness Application and Instructions.

Both applications give borrowers the option of using the original 8-week covered period (for loans made before June 5, 2020) or the extended 24-week covered period.

New guidance

Additionally, the SBA has issued three new interim final rules, and borrowers can expect 25 to 30 frequently asked questions (FAQs) some time in the next two weeks. Among the questions that are expected to be answered are four big ones: 

  • Who is an owner-employee?
  • What are self-employed/general partners to use for 2020 compensation?
  • What the heck is included in utilities, that is, what does “transportation” mean?
  • Can borrowers apply for forgiveness before the end of their covered period?

Absent something mind-blowing, we are going to wait for the dust to settle around the new forgiveness applications and those promised FAQs before providing additional information. 

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