On June 17th, the SBA issued a new Interim Final Rule that implements changes made by Congress in the Paycheck Protection Program Flexibility Act of 2020 (PPPFA). They also issued a revised forgiveness application to reflect the PPPFA changes along with a new “EZ” Paycheck Protection Program loan forgiveness application. A link to the new Interim Final Rule is here.
Form 3508EZ applies to borrowers who meet any one of the following criteria:
- The Borrower is a self-employed individual, independent contractor, or sole proprietor who had no employees at the time of the PPP loan application and did not include any employee salaries in the computation of average monthly payroll in the Borrower Application Form.
- Did not reduce salary or wages for any employee by more than 25% during the covered period AND did not reduce the number or hours of their employees (excepting laid-off employees who refused an offer to return).
- Did not reduce salary or wages for any employee by more than 25% during the covered period AND experienced reductions in business activity as a result of health directives related to COVID-19.
If you meet at least one of the criteria above, you will be allowed to use the SBA Form 3508EZ to apply for forgiveness. For review purposes only, the new Form 3508EZ is here and the form instructions are here.
*IF YOUR LOAN IS $50,000 OR LESS, PLEASE COMPLETE THIS FORM. For form instructions, please click HERE.
(To read the SBA Press Release regarding this announcement, click here)
If you do not meet any of the criteria above, you cannot use SBA Form 3508EZ and instead you must apply for forgiveness of your PPP loan using SBA Form 3508 (6/20). For review purposes only, the new Form 3508 is here and the form instructions are here.
As we wait for further guidance, you should gather the following documents verifying eligible expenses, including the number of full-time equivalent employees on your payroll and their pay rates for the time frame used to verify you met the staffing and pay requirements:
- Payroll reports from your payroll provider;
- Payroll tax filings (Form 941);
- Income, payroll, and unemployment insurance filings from your state;
- Documents verifying any retirement and health insurance contributions; and
- Documents verifying your eligible interest, rent, and utility payments (canceled checks, payment receipts, and account statements).
Applications can be dropped off at any InFirst Bank branch with the attention addressed to: Rachel Staley.
For more information, visit the FAQ page. You can also call us toll-free at (800)349-2814
This update is being provided to you as a convenience. This information does not, and is not intended to, constitute legal advice; instead, all information, content, and materials are for general informational purposes only. InFirst Bank does not assume, and expressly disclaims, any responsibility to provide future updates to you. You should contact your attorney to obtain advice with respect to any particular legal matter herein. InFirst Bank gives no warranty and accepts no responsibility or liability for the accuracy or the completeness of the information and materials contained herein. All liability with respect to any action taken or not taken based on the content above are hereby expressly disclaimed.