Monday, October, 12, 2020
Over this past weekend, the U.S. Small Business Administration (SBA) posted a new loan forgiveness form to the public for those who received a Paycheck Protection Program (PPP) loan of $50,000 or less. The new form, form 3508S, is much simpler than both the long form (form 3508) and the EZ form (form 3508EZ). While the form states that it is for those who received a PPP loan of $50,000 or less, note that a borrower cannot use the new form if the borrower, together with their affiliates, received total loans of $2,000,000 or more.
In addition to the $50,000 threshold, a borrower can use the new form if –
- The requested forgiveness amount was used to pay costs that are eligible for forgiveness;
- The borrower used at least 60% of the requested amount on payroll costs; and
- The requested forgiveness amount took into consideration the applicable owner-employee or self-employed individual/general partner compensation caps.
The borrower does not need to show any calculations of the loan forgiveness amount on or with the form, as they would have to do with the long form or the EZ form. Furthermore, the borrower is exempt from applying the complicated loan forgiveness salary and FTE reductions when using the new form 3508S.
With the new form also comes simpler procedures for lenders.
As noted above, the $50,000 threshold applies to the original loan amount, not the amount of forgiveness being requested. It is also not a blanket forgiveness, which is something that lenders had been pushing for in the past few months. A borrower must still retain records that support the calculation of the forgiveness amount being requested.
The announcement of the simpler form comes about a week after the opening of the loan forgiveness season by the SBA. While it is not what many borrowers and lenders were hoping for, it will still ease the time burden on smaller businesses and their lenders. Keep in mind that banks are using their own equivalent online forms for loan forgiveness applications, so eligible borrowers should first check with your bank to see when the new form will be available to file with your bank.
To access the newly released Form 3508S, click here.
To access the instructions to Form 3508S, click here.
Contact our COVID-19 Response Team for questions on the new forgiveness forms.
Robert Jackson, CPA
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