The SBA published two documents late last Friday evening that together take significant steps toward clarifying the forgiveness process. While the SBA has indicated that additional guidance is forthcoming, these two documents make meaningful strides toward describing what the program will look like for borrowers, and what the lenders must to do complete the process.
The documents are linked below:
Loan Forgiveness: https://home.treasury.gov/system/files/136/PPP-IFR-Loan-Forgiveness.pdf
Lender and Borrower Responsibilities: https://home.treasury.gov/system/files/136/PPP-IFR-SBA-Loan-Review-Procedures-and-Related-Borrower-and-Lender-Responsibilities.pdf
Citizens Bank encourages you to read these documents carefully as you begin to compile your forgiveness application. You should consult with your CPA and attorney as you determine your eligible expenses.
While Citizens Bank will underwrite and submit your application for forgiveness to the SBA, we continue to believe we are not in position to provide a definitive interpretation of the regulation. While these two documents are very helpful, there continue to be significant questions regarding the program.
We will provide you with feedback as we underwrite your forgiveness application in the same way that we did when you submitted your original loan application. You can expect Citizens Bank to take a careful and conservative approach to this process. Our due diligence today is designed to protect both you and the bank in the long run.
Citizens Bank will continue to bring you information and resources as they become available.
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.
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.