Home / News and Resources / #33: The SBA Publishes Simplified Forgiveness Guidelines for Loans Less Than $150,000

#33: The SBA Publishes Simplified Forgiveness Guidelines for Loans Less Than $150,000

On January 19th, 2020, the SBA published updated forgiveness applications and instructions.  For borrowers with PPP loans under $150,000 the process has been simplified greatly.

Borrowers of $150,000 or Less:

Use SBA Form 3508S

You are no longer required to submit supporting documents to Citizens Bank in order to obtain loan forgiveness.  You will complete the single page SBA application 3508S making certifications to the bank and the SBA, and the bank will turn the document in to the SBA to obtain your loan forgiveness.

Please be aware that your file is still subject to SBA audit.  You must maintain and make available upon request, the supporting documentation verifying the use of your PPP funds as well as other program compliance.  Failure to do so will call the forgiveness of your loan into question.

Please be sure to read the application and instructions closely.  If you have questions about your compliance with PPP rules, please contact your outside legal or accounting advisors.  Citizens Bank will rely on your statements on the application.

How Do I Apply for Forgiveness If My Loan Amount Exceeds $150,000?

You are required to submit either the 3508 or 3508EZ application.  The EZ application allows eligible borrowers to submit a PPP loan forgiveness application with fewer calculations and less documentation.

Borrowers are eligible to use the EZ application to apply for loan forgiveness if they fall into one of the following three categories:

  • The borrower is a self-employed individual, independent contractor, or sole proprietor with no employees at the time of the PPP loan application.
  • The borrower did not reduce by more than 25% the salary of any employee who did not have annualized salary of more than $100,000 during any single pay period in 2019 and did not reduce the number of employees or the average paid hours of employees during the loan period (ignoring reductions in employees or paid hours that arose from an inability to rehire similarly qualified employees for unfilled positions or an employee who refused a restoration of hours).
  • The borrower did not reduce by more than 25% the salary of any employee who did not have annualized salary of more than $100,000 during any single pay period in 2019 and was unable to operate, or was operating at a lower level of business activity, during the loan period due to compliance with sanitation, social distancing, or any other safety requirements or guidance issued by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration related to COVID-19.

Please note - The EZ Application does not eliminate the obligation to provide and maintain the supporting documents to determine loan forgiveness amounts.

Regardless of loan size, you will additionally be required to submit a Loan Forgiveness Acknowledgment.

You can use our secure server to submit your request and supporting documents online. Please submit your application to the Citizens Bank lender that originally helped you with your PPP application.

As always, we stand ready to answer your questions about the PPP using the best available information. 

Citizens Bank recommends however 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.

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.

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