PPP Loan Forgiveness FAQs
- The new FAQs are on pages 10 and 11 on the Economic Injury Disaster Loans (EIDL) released August 11, 2020
- The SBA will deduct the amount of the EIDL advance from the forgiveness amount the SBA remits to the lender. The lender will be able to confirm that amount by reviewing the borrower’s EIDL advance information in the PPP Forgiveness Platform.
- If any amount is not forgiven (due or the EIDL advance or not) the lender is responsible for notifying the borrower of the loan forgiveness amount remitted by the SBA and the date on which the borrower’s first loan payment is due. The lender must continue to service the loan. The loan would need to be paid off by the borrower by the maturity date of the PPP loan (either two or five years).
- If the EIDL advance was in excess of the PPP Loan then there will be no forgiveness and the lender would have the same responsibilities as above.
You can view the new Loan Forgiveness FAQ document here.
PPP Loan FAQ
- There are two new FAQs, questions 50 & 51, on page 18.
- Question 50 has to do with the effect of payment or nonpayment of fees of an agent or other third party from lenders. The SBA’s guarantee of the loan is not material in terms of the payment or nonpayment of those fees.
- Question 51 confirms that vision and dental benefits are included in group health care benefits and forgivable, absent the rules governing owners, partners, owner-employees, or sole proprietors.
You can read the new Loan FAQ document here.
PPP – Interim Final Rule – Appeals of SBA loan review decisions under the Paycheck Protection Program
- A borrower cannot appeal a decision before it is a final written review decision.
- If a borrower wants to appeal a lender’s forgiveness decision, the borrower can request an SBA review a lender’s decision to deny the loan forgiveness application. This review would be completed by the SBA, not the SBA Office of Hearings and Appeals (OHA).
- An appeal by a PPP loan borrower does not extend the deferral period of the PPP loan.
- Provides a detailed list of the information and documentation that needs to be included with the appeal.
You can read the IFR document here.
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