IBA Compliance Connection

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Has the SBA released guidance on the procedures banks should use to request PPP loan forgiveness? We are familiar with the forgiveness application, but we would like to know more about the process for requesting forgiveness. For example, should we use the Capital Access Financial System (CAFS) or should we use the 1502 reporting process?

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The SBA recently released a procedural notice containing guidance for lenders related to submitting PPP loan forgiveness decisions. The SBA will provide a secure PPP Forgiveness Platform for PPP lenders to submit loan forgiveness decisions, supporting documentation, and requests for forgiveness payments. The platform is scheduled to go live on August 10, 2020. 

PPP Lender Authorizing Officials (AOs) should receive a welcome email from the email address [email protected] with instructions on how to access the platform. If an AO does not receive this email, the SBA notice instructs AOs to contact its PPP Lender Hotline at (833) 572-0502. The procedural notice also contains instructions on how to make submissions to the platform and clarifies what documentation will need to be submitted, among other items. Detailed instructions for using the platform will be available after login to the PPP Forgiveness Platform.

For resources related to our guidance, please see:

  • SBA Procedural Notice, Procedures for Lender Submission of Paycheck Protection Program Loan Forgiveness Decisions to SBA and SBA Forgiveness Loan Reviews (July 23, 2020) (“SBA has partnered with a financial services technology provider – Goldschmitt-CRI – to make available a secure SaaS platform (the PPP Forgiveness Platform) to accept loan forgiveness decisions, supporting documentation, and requests for forgiveness payments . . . The PPP Forgiveness Platform will go live and begin accepting Lender submissions on August 10, 2020.”)
  • SBA Interim Final Rule, Paycheck Protection Program – Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules, 85 Fed. Reg. 38304, 38306 (June 26, 2020) (“To receive loan forgiveness, a borrower must complete and submit the Loan Forgiveness Application (SBA Form 3508, 3508EZ, or lender equivalent) to its lender (or the lender servicing its loan). As a general matter, the lender will review the application and make a decision regarding loan forgiveness. The lender has 60 days from receipt of a complete application to issue a decision to SBA. If the lender determines that the borrower is entitled to forgiveness of some or all of the amount applied for under the statute and applicable regulations, the lender must request payment from SBA at the time the lender issues its decision to SBA. SBA will, subject to any SBA review of the loan or loan application, remit the appropriate forgiveness amount to the lender, plus any interest accrued through the date of payment, not later than 90 days after the lender issues its decision to SBA.”)
  • SBA Interim Final Rule, Paycheck Protection Program – Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules, 85 Fed. Reg. 38304, 38310 (June 26, 2020) (“When the lender issues its decision to SBA approving the application (in whole or in part), it must include the following: i. For applications submitted using the SBA Form 3508 or lender's equivalent form: (1) the PPP Loan Forgiveness Calculation Form; (2) PPP Schedule A; and (3) the (optional) PPP Borrower Demographic Information Form (if submitted to the lender). ii. For applications submitted using the SBA Form 3508EZ or lender's equivalent form: (1) the SBA Form 3508EZ or lender's equivalent form; and (2) the (optional) Borrower Demographic Information Form (if submitted to the lender).”)
  • SBA Interim Final Rule, Paycheck Protection Program – Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules, 85 Fed. Reg. 38304, 38310 (June 26, 2020) (“The lender must confirm that the information provided by the lender to SBA accurately reflects lender's records for the loan, and that the lender has made its decision in accordance with the requirements set forth in 2.a. If the lender determines that the borrower is entitled to forgiveness of some or all of the amount applied for under the statute and applicable regulations, the lender must request payment from SBA at the time the lender issues its decision to SBA. SBA will, subject to any SBA review of the loan or loan application, remit the appropriate forgiveness amount to the lender, plus any interest accrued through the date of payment, not later than 90 days after the lender issues its decision to SBA.”)