On April 17, SBA released guidance related to the Restaurant Revitalization Fund. This program, created by the American Rescue Plan Act (ARPA) that was enacted on March 11, 2021, aims to provide relief to restaurants, bars, and similar eligible businesses who were impacted by the COVID-19 pandemic.

General Overview

The Restaurant Revitalization Fund provides grants to eligible businesses, including restaurants, food stands, food trucks, food carts, caterers, bars, saloons, lounges, taverns, snack and nonalcoholic beverage bars, and licensed facilities or premises of a beverage alcohol producer where the public may taste, sample, or purchase products. In addition, bakeries, brewpubs, tasting rooms, taprooms, breweries, microbreweries, wineries, and distilleries may be eligible if onsite sales to the public comprise at least 33% of gross receipts, and inns may be eligible if onsite sales of food and beverage to the public comprise at least 33% of gross receipts.

Grant Amount

For all applicants in operation as of January 1, 2019, grant amounts will be calculated by determining 2019 gross receipts minus 2020 gross receipts minus Paycheck Protection Program (PPP) loan amounts. Amounts will be capped to $5 million per location, not to exceed $10 million for the total applicant and its affiliated businesses. No awards will be made under $1,000.

When determining gross receipts, applicants should not include PPP loans, Economic Injury Disaster Loans (EIDL), EIDL Advances, Targeted EIDL Advances, state and local grants (via CARES Act or otherwise) or amounts paid on behalf of SBA loans through Section 1112 of the CARES Act.

Fund Uses

Restaurant Revitalization Funds may be used for certain business payroll costs (including sick leave and group health care, life, disability, vision or dental insurance premiums), payments on business mortgage obligations, rent, principal and interest payments, utilities, maintenance expenses, construction of outdoor seating, business supplies (including personal protective equipment and cleaning materials), business food and beverage expenses (including raw materials), covered supplier costs as defined by the program, and business operating expenses as defined by the program. Awardees must use all funds by March 11, 2023 on eligible expenses incurred between February 15, 2020 and March 11, 2023. Unused funds must be returned.

Grant recipients will be asked to complete annual reporting submissions beginning no later than December 31, 2021 regarding their use of funds, until the funds have been depleted. SBA may ask for supporting documentation at any time.

Applications

Although the SBA has not announced when it will begin accepting applications, ARPA indicates that the SBA can only fund certain entities in the first 21 days of the application period. Specifically, applications from small businesses that are at least 51% owned by women, veterans, or socially and economically disadvantaged individuals will be considered for funding. Other entities may apply during this time, but their applications will not be considered for funding until the 21-day priority period ends. A sample application can be found at https://www.sba.gov/document/sba-form-3172-restaurant-revitalization-funding-application-sample.

Next Steps

As demand is expected to exceed funding availability, interested businesses should carefully review SBA guidance and confirm their eligibility. Eligible entities may wish to begin preparing documentation and the draft application, understanding that the application may be changed before the application portal goes live. SBA guidance can be found as follows:

• General Program Overview: https://www.sba.gov/funding-programs/loans/covid-19-relief-options/restaurant-revitalization-fund
• Restaurant Revitalization Funding Program Guide: https://www.sba.gov/document/support-restaurant-revitalization-funding-program-guide
• Draft Application: https://www.sba.gov/document/sba-form-3172-restaurant-revitalization-funding-application-sample

For assistance or questions regarding the Restaurant Revitalization Fund, please contact your HBK Advisor.

On March 30, 2021, President Biden signed the PPP Extension Act of 2021 into law.

Previously, the SBA had until March 31, 2021 to approve new first draw or second draw Paycheck Protection Program (PPP) loans. Many lenders closed their application processes or portals early, to ensure the SBA had time to approve loans in the queue. This early close, paired with changes made to the program in late February and early March, caused some confusion at the end of the original application period.

With the PPP Extension Act of 2021 now enacted, the program is extended to May 31, 2021. SBA will have an additional 30 days to approve loans after this deadline. This Act does not affect PPP loan forgiveness applications or timing.

Those interested in obtaining a first or second draw PPP loan should consider the following actions:

1. Ensure eligibility requirements are met. The PPP has evolved since the program was introduced by the CARES Act in March 2020. Potential borrowers should understand program rules and eligibility requirements before applying.


2. Watch for communication from your lender. As many lenders have closed their loan application portals, it is unknown when they may reopen.


3. Prepare your application and related documentation. The SBA and Treasury have provided guides to help determine eligible loan amounts, measure gross receipts reductions, and ensure proper documentation is submitted with the loan application.

For questions regarding PPP, please contact your HBK Advisor.

On March 24, the U.S. Small Business Administration (SBA) announced additional relief available for businesses impacted by COVID-19.

The Economic Injury Disaster Loan Program (EIDL) was made available to small businesses and non-profit organizations last spring. Due to high demand, loan amounts were capped at $150,000. The loans, which are intended to support certain working capital needs, carry a 3.75% interest rate for businesses or a 2.75% rate for nonprofit organizations and a maturity of up to 30 years.

In its announcement, SBA indicated that effective April 6, the maximum COVID-19 EIDL program loan amount will be increased to $500,000, based on 24 months of economic injury. This change was made due to the pandemic continuing longer than expected, causing many organizations to require additional financial support. Borrowers who previously received funds should not submit a request for an increase; instead, SBA may contact these borrowers regarding their eligibility for an increased loan amount.

This new funding is in addition to the SBA announcement that loans issued through the EIDL program would have an extended deferment period, meaning that borrowers would not be required to make payments until 2022. As interest is accruing through this time, some borrowers may wish to make payments during the deferment period.

To learn more about the COVID-19 EIDL program, please visit sba.gov/disaster and choose the COVID-19 EIDL link. For more information about COVID-19 relief options, contact your HBK Advisor.

The Small Business Administration’s (SBA) Office of Disaster Assistance will begin accepting applications for Shuttered Venue Operator Grants on April 8. This grant program was introduced in the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act signed into law on December 27, 2020 and recently modified by The American Rescue Plan Act, the $1.9 trillion stimulus bill passed on March 11. The program focuses on supporting performing arts businesses that have been closed or limited by COVID-19 restrictions.

Eligibility

The list of entities eligible for the grants includes live venue operators or promoters, theatrical producers, live performing arts organization operators, museum operators, motion picture theatre operators, and talent representatives. It also includes certain entities owned by state or local governments—for example, museums or historic homes—that are operated solely as a venue. Eligibility is limited to venues operating as of February 29, 2020.

Originally, venues that received Paycheck Protection Program (PPP) loans were prohibited from receiving the grants, but the American Rescue Plan Act removed that restriction. However, entities will be ineligible for a PPP loan once they receive an SVOG.

Grants will generally be available equal to 45 percent of 2019 gross earned income, or $10 million, whichever is less. Grant awards may be reduced by PPP loan amounts.

How to apply

As the SBA works on its application platform, applicants are advised to proceed as follows:

• Reference the SVOG Eligibility Requirements and register for a DUNS number.
• Register in the System for Award Management (www.SAM.gov). Each eligible entity must have its own SAM registration.
• Gather documents to support your employee count and monthly revenues.
• Determine the amount of gross revenue loss you suffered between 2019 and 2020. You can use this information to see if you qualify for one of the priority periods.
• Reference the SVOG Preliminary Application Checklist for additional preparation recommendations.

The application schedule

The SBA expects to open applications on April 8, 2021. Entities who have suffered great revenue loss will be prioritized.

How to use the funds

Funds may be used for certain expenses, including:

• Payroll costs
• Rent payments
• Utility payments
• Scheduled mortgage payments (not including prepayment of principal)
• Scheduled debt payments (not including prepayment of principal on any indebtedness incurred in the ordinary course of business prior to February 15, 2020)
• Worker protection expenditures
• Payments to independent contractors (not to exceed $100,000 in annual compensation per contractor)
• Other ordinary and necessary business expenses, including maintenance costs
• Administrative costs (including fees and licensing)
• State and local taxes and fees
• Operating leases in effect as of February 15, 2020
• Insurance payments
• Advertising, production transportation, and capital expenditures related to producing a theatrical or live performing arts production. (May not be the primary use of funds)

Funds may not be used to:

• Buy real estate
• Make payments on loans originated after February 15, 2020
• Make investments or loans
• Make contributions or other payments to, or on behalf of, political parties, political committees, or candidates for election
• Any other use prohibited by the Administrator

To learn more about the SVOG program, visit https://www.sba.gov/funding-programs/loans/covid-19-relief-options/shuttered-venue-operators-grant or visit the FAQs at https://www.sba.gov/sites/default/files/2021-03/3-22-21%20SVOG%20FAQ%20FINAL.pdf. For more information about the SVOG program or other COVID-19 relief options, contact your HBK Advisor.

On Monday, February 22, the Biden-Harris Administration announced changes to the PPP program that focus on small businesses. These changes included expanded eligibility and a fourteen-day period during which only businesses that employ fewer than 20 people could apply for a PPP loan. This period ends on March 9.

In addition, the Administration announced that sole proprietors, independent contractors, and self-employed individuals could be eligible for more financial relief. At the time of the announcement, no specifics regarding how to calculate the larger loan amount were released.

On March 3, SBA issued an Interim Final Rule detailing this new calculation. Now, Schedule C tax filers with or without employees can apply for a PPP loan based on the net income or the gross income reported on their Schedule C. By using gross income, some Schedule C filers who were excluded from the PPP could now be eligible to apply for a PPP loan while others could receive substantially larger loan amounts.

Schedule C filers seeking to apply using their gross income should consider the following:

• Borrowers whose loans were approved before March 3 cannot modify their loan amount. Only Schedule C tax filers who are eligible for a first or second draw PPP loan and who have not applied for that loan may now apply with this new calculation.
• SBA released revised loan applications for first draw and second draw applications using this calculation methodology. Interested borrowers may choose to discuss any revised processes regarding the submission of this application version and related documentation with their PPP lender.
• If a first draw PPP Borrower who applies for a loan using the gross income calculation has Schedule C gross income that exceeds $150,000, they will not be automatically deemed to have made the certification concerning the necessity of loan in good faith. SBA has determined that these borrowers may have other sources of liquidity and is committed to reviewing a sample of these loans. This does not apply to second draw loans since those applicants are required to certify a reduction in their gross receipts.
• The period to apply for a loan has not been extended. Loans must be approved by March 31, 2020.

For questions regarding your PPP loan, please contact your HBK Advisor.

The Consolidated Appropriations Act, 2021 includes several changes to the CARES Act’s Paycheck Protection Program (PPP) loan forgiveness process. The changes are reflected in new forgiveness applications issued January 19 by the Small Business Administration (SBA). The two applications can be found at: Standard Application: https://home.treasury.gov/system/files/136/PPP–Loan-Forgiveness-Application-and-Instructions–Form-3508-1192021.pdf EZ Application: https://home.treasury.gov/system/files/136/PPP–Loan-Forgiveness-Application-Instructions–Form3508EZ-1192021.pdf Criteria for using the standard application versus the EZ application remain the same. Key changes to the applications include:

• Checkboxes were added to select whether the forgiveness application is for the first draw or second draw loan.
• The Economic Industry Disaster Loan (EIDL) Advance Amount and EIDL Application Number fields were removed. Per the Act, the EIDL Advance no longer reduces the amount of PPP forgiveness.
• Lines were added to report new nonpayroll costs: covered operations expenditures, covered property damage costs, covered supplier costs, and covered worker protection expenditures.

On the standard application, the safe harbors for the FTE Reduction (Safe Harbor #2, Step 4), and Salary/Hour Wage Reduction (Step 2c) were updated so that borrowers who received a loan before December 27, 2020 (the date the Consolidated Appropriations Act was passed) have until December 31, 2020, to eliminate any reduction to their forgiveness amount, while those receiving a loan after December 27, 2020, have until the last day of their covered period to take this action. In addition, an updated 3508S application was released for borrowers who received loans of $150,000 or less: https://home.treasury.gov/system/files/136/PPP–Loan-Forgiveness-Application-Instructions–Form-3508S-1192021.pdf. Borrowers using the form are required to make two certifications: 1) confirm that they complied with the rules regarding the use of the funds, the proportion of funds used for payroll costs, and their calculations regarding forgiveness, and 2) that the information they are providing in the application is “true and correct.” Borrowers who received a PPP loan between $50,000 and $150,000 and borrowers of a loan of $50,000 or less who received, together with their affiliates, loans of $2 million or more are required to complete FTE and Salary/Wage Reduction tests that may reduce forgiveness. While the borrower is not required to submit this documentation, they are required to maintain it in order to provide it to the SBA upon request. Other Guidance

• An Interim Final Rule (IFR) on PPP Loan Forgiveness was issued in conjunction with these applications. The rule combines a number of previous IFRs and explains changes associated with the Consolidated Appropriations Act, 2021 and new forgiveness applications. A copy of the IFR can be found at https://home.treasury.gov/system/files/136/PPP–IFR–Loan-Forgiveness-Requirements-Loan-Review-Procedures-Amended-Economic-Aid-Act-1192021.pdf
• Borrowers of first draw PPP loans who received those loans before December 27, 2020, are also required to disclose if the U.S. President, Vice President, head of an Executive department as defined in 5 USC 101, or a member of Congress, or the spouse of any of these individuals directly or indirectly held a controlling interest in the borrowing entity at the time the PPP application was submitted to the lender. The SBA released a Disclosure of Certain Controlling Interest Form (Form 3508D) which can be found at https://home.treasury.gov/system/files/136/PPP–Borrowers-Disclosure-Certain-Controlling-Interests-1192021.pdf. Disclosures must be made by January 26, 2021.

For questions regarding your PPP loan and related forgiveness, contact your HBK Advisor.

On December 27, 2020, the Consolidated Appropriations Act 2021 (CAA), also referred to as the Economic Aid Act or Omnibus Bill, was signed into law, providing new COVID 19 relief options for individuals and small businesses, including a second round of Paycheck Protection Program (PPP) loans. Interested borrowers have been awaiting guidance, which the SBA and Department of the Treasury have begun to release.

New Guidance

Two Interim Final Rules (IFRs) were released on January 6. The first, titled “Interim Final Rule on Paycheck Protection Program as Amended by Economic Aid Act,” combines guidance from several previous IFRs with new provisions in the CAA. A second IFR, “Interim Final Rule on Second Draw Loans,” provides guidance on eligibility and loan details for the new round of loans. Highlights of that second IFR include:

Eligibility criteria. In general, eligible entities must employ 300 or fewer employees, have received a First Draw PPP loan that they have used or will use to pay eligible expenses, and must have experienced a gross receipts reduction of 25 percent or greater in at least one 2020 quarter compared to the same quarter in 2019. Other eligibility criteria may also apply.

Defining gross receipts. For eligible nonprofits, veterans, nonprofit news, 501(c), or destination marketing organizations, gross receipts are defined in section 6033 of the Internal Revenue Code of 1986. For other entities, the IFR defines gross receipts per the SBA definition in 13 C.F.R. 121.104, and notes that it includes “all revenue in whatever form received or accrued (in accordance with the entity’s accounting method) from whatever source, including from the sales of products or services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances.” Exclusions include “taxes collected for and remitted to a taxing authority if included in gross or total income (such as sales or other taxes collected from customers and excluding taxes levied on the concern or its employees); proceeds from transactions between a concern and its domestic or foreign affiliates; and amounts collected for another by a travel agent, real estate agent, advertising agent, conference management service provider, freight forwarder or customs broker.” Additionally, proceeds from forgiven PPP loans are excluded from the definition of gross receipts.

Determining the loan amount. Eligible borrowers may generally borrow up to two-and-a-half months of their average monthly payroll cost, up to $2 million. Businesses that are entities of a corporate group are limited in aggregate to $4 million of Second Draw Loans. Those with a NAICS code beginning with 72 (generally hospitality industry organizations) at the time of disbursement can calculate their loan amount by using three-and-a-half months of their average monthly payroll cost. Average payroll costs can be based on 2019, 2020, or for borrowers who are not self-employed, a sole proprietor, or an independent contractor, the precise one-year period before the date on which the loan is made.

Other loan details. Second Draw PPP loans will carry a 1 percent interest rate and five-year maturity, with no collateral or personal guarantees required. Loans will be available on a first-come, first-served basis and can be funded through the sooner of March 31, 2020, or when funding is depleted.

Applications

In addition to the new guidance, the SBA also released two new applications and instructions for new First Draw and Second Draw Loans.

For First Draw Loans, the application and instructions can be found at: https://home.treasury.gov/system/files/136/PPP Borrower Application Form.pdf.

For Second Draw Loans, the application and instructions can be found at: https://home.treasury.gov/system/files/136/PPP Second Draw Borrower Application Form.pdf.

As with previous PPP loan applications, many lenders will require borrowers to submit their applications through online portals. Community Development Financial Institutions (CDFIs) and Minority Depository Institutions (MDIs) are authorized to begin accepting applications the week of January 11 with larger banks to follow.

Take Action Now.

The PPP provisions in this legislation, as well as in other economic and tax relief provisions, are complex and must be used specifically. Interested parties should take immediate action to review their business and financing needs as some options are time-sensitive.

Many of the factors determining whether your business qualifies for these loans or should apply for the new round of PPP funding are organization-specific. There are also legal implications for applying and using PPP funds. We encourage interested parties to consult with their legal counsel regarding questions on eligibility under the terms of this latest round of legislation.

We recognize that the effects of the COVID-19 pandemic on businesses are ongoing and we remain committed to supporting you. If you would like assistance with evaluating your opportunity to participate in COVID-19 tax and/or economic relief measures, please contact your HBK Advisor.

As the new year approaches, we are eager to put 2020 and its challenges behind us and embrace a hopefully much improved 2021. Manufacturers are no different; whether experiencing struggles or business growth in 2020, most manufacturers are anxious to begin the new year. However, before we put 2020 in the past, consider five lessons that manufacturers learned – or were reminded of – in the past year:

• A strong balance sheet can help you weather challenging times. Cash is king. That’s an unalterable principle, but one that took on even more importance in 2020. Having enough cash or cash availability to weather a storm proved vital to ongoing operations, if not survival itself. Government loans and grants supported many manufacturers, but overleveraged companies (or those with a high amount of debt) now find themselves in an unexpected position. Many are working actively to determine how to reduce debt in times of continuing uncertainty, while others face struggles and lender pressures to resolve the debt, as restrictions to capital have become increasingly common.

  Lesson: Actively work on improving your balance sheet in good times to be able to persevere through tough times.

• Relationships are key.

  Technology has been a boon to manufacturing, but in an age of technology and automation, some manufacturers have found that their face-to-face relationships have weakened or have been replaced by email, text messages, and automated communications. Although many relationships may remain more virtual than in the past for some time, virtual technologies such as video calls can create a pseudo-face-to-face environment while reducing the time and cost associated with travel.

Using all available methods to proactively build and maintain relationships will help manufacturers through uniquely challenging issues that have emerged in the pandemic. Think about the benefits of these relationships, including:

• Relationships with customers can aid in your understanding of their needs, allowing you to anticipate their future needs and make efforts to supply them without disruption.
• Relationships with vendors can help you ensure your own supply chain continuity by understanding potential problems and seeking alternatives, when necessary.
• Relationships with advisors can help you decipher complex COVID-19 regulations and maximize available loans, grants, and tax deductions or credits available.

Lesson: Look for ways to continue relationships in safe, meaningful ways, including through virtual technologies that can actually help us save time and money.

• Diversification and flexibility can build resiliency.

Firms with a diversified customer base were better equipped to navigate the pandemic economy. Even in non-pandemic times, having a handful of large customers or a focus on one end-user market created risk, especially if those customers or if that market faced a business downturn. Further, the pandemic caused markets previously identified as growth markets, such as aerospace, to falter, while some commodity markets, such as consumable products including disposable kitchenware, surged.

Some manufacturers took their diversification a step further and retrofitted their operations to support needs created by the pandemic, such as for personal protective equipment (PPE). They supported their communities while protecting their income by adjusting their operations quickly to respond to immediate demand.

Lesson: While focusing on commodity products and exploring rapid retrofits may never be key parts of your strategic plan, the ability to recognize and adapt to customer needs and diversify your customer base can help strengthen your business, especially in weak economic times.

• The lowest cost might not be the best option.

Many manufacturers work with overseas suppliers to deliver critical products at low costs. However, after some tariffs were implemented, efforts to re-shore (or resource those goods domestically) increased. For those still working with overseas suppliers, disruptions caused by the pandemic and related international shutdowns created ongoing supply chain questions and resurfaced calls for the re-shoring of critical goods

A manufacturer’s supply chain strategy should consider cost, quality, and the potential for disruption. Even firms relying principally on domestic supply chains should have multiple alternate sources for critical supplies or materials before a problem occurs.

As the supply chain is critical to a manufacturer’s ability to supply, a manufacturer should carefully outline its supply chain strategy. Think about the supply chain similar to a succession plan or an IT continuity plan. A problem can occur that interrupts the ability to do business; what can we do to ensure that those interruptions are mitigated?

Lesson: Manufacturers should plan for supply chain continuity for equipment, supplies, and other inputs needed to manufacture their products.

• We can be optimistic about 2021 and beyond.

While there remains uncertainty about how the pandemic will continue to affect us in 2021, there are many reasons to have cautious optimism about the year ahead. First, as additional federal COVID-19 relief programs have been passed into law, manufacturers may find new support options available to them, including a second draw Paycheck Protection Program loan, extended and expanded Employee Retention Credit, or tax credits or deductions. In addition, some states and localities have other programs that can support manufacturers, such as Ohio’s TechCred program. As always, manufacturers should carefully evaluate their eligibility for any programs available and carefully assess those that can support them.

As more people are vaccinated against COVID-19, the stress on our overall economy is anticipated to decline. Further, business opportunities may increase as additional reshoring efforts could result in more domestic production. Advanced technologies, such as robotics, artificial intelligence, additive manufacturing, data analytics, and cloud computing, will continue to make operating more efficient and level the competitive playing field.

Lastly, while manufacturers faced pre-pandemic challenges of available workers, the higher level of unemployment has more potential workers looking for their next opportunity. Manufacturers looking to expand their workforce may want to actively consider their recruiting and training strategy to support their business needs while also aiding those in need of employment. Lesson: Manufacturers planning for 2021 should have cautious optimism, considering multiple economic and healthcare factors that could contribute to a year of recovery and opportunity.

Most economic analysts expect slow but steady economic growth in 2021. It should be a year of recovery and a chance to move our companies profitably forward. The lessons we learned from 2020 will help us prepare for better times in the coming year and beyond.

Last month, Paycheck Protection Program (PPP) borrowers learned about Loan Necessity Questionnaires (SBA Form 3509 and SBA Form 3510) that were released from the SBA to lenders. SBA indicated that these forms would be provided to borrowers that, together with their affiliates, received loans of $2 million or more in an effort to evaluate their good-faith certification that current economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant”. Because no guidance was issued and the forms were initially not published with other PPP guidance on the SBA or Treasury websites, many borrowers raised questions about these forms and how they would be used by SBA.

While the SBA and Treasury have now posted these forms, they also released a new Frequently Asked Question (FAQ). In the answer, SBA confirms that a request to complete these forms does not indicate that the SBA is questioning the borrower’s certification of economic uncertainty or need for the loan.

SBA continues by explaining that “this certification is required to have been made in good faith at the time of the loan application, even if subsequent developments resulted in the loan no longer being necessary.” SBA may review the borrower’s “circumstances and actions both before and after the borrower’s certification to the extent that doing so will assist SBA in determining whether the borrower made the statutorily required certification in good faith at the time of its loan application.” SBA reserves the right to request additional support, which may allow borrowers to provide more detailed responses or narratives regarding their circumstances.

Borrowers expecting to receive these forms may consider the following actions:

• Review the available forms and prepare your responses.
• Consider additional narratives that may be important for the SBA to consider.
• If you receive the form from your lender, submit your response within 10 business days of receipt.

For questions regarding the PPP or Loan Necessity Questionnaires, please contact your HBK Advisor.

On October 8, 2020, the Small Business Administration (SBA), in conjunction with the Treasury Department, released a new application designed to simplify the Paycheck Protection Program (PPP) loan forgiveness process for some small borrowers.

SBA Form 3508S is intended for borrowers who received PPP loans of up to $50,000. However, if those borrowers and their affiliates received loans totaling at least $2 million, they are not eligible to use Form 3508S.

Form 3508S simplifies the forgiveness process by eliminating the FTE and wage/salary reduction calculations. In an Interim Final Rule also released on October 8, the SBA and Treasury explained that these exemptions are allowable as de minimis exceptions to the CARES Act. Specifically, the SBA believes that most borrowers in this dollar range would not be affected by these reductions because they did not have FTE or wage/salary reductions or they would otherwise qualify for the safe harbor options.

Borrowers who do not fall into the under-$50,000 range should continue to use Form 3508 or Form 3508EZ applications. They should also stay alert to possible changes to forgiveness requirements through future legislation.

To obtain the SBA copy of the simplified application, instructions and related Interim Final Rule, visit:

• Form 3508S: https://home.treasury.gov/system/files/136/PPP-Loan-Forgiveness-Application-Form-3508S.pdf
• Form 3508S Instructions: https://home.treasury.gov/system/files/136/PPP-Loan-Forgiveness-Application-Form-3508S-Instructions.pdf
• Interim Final Rule – Additional Revisions to Loan Forgiveness and Loan Review Procedures Interim Final Rules: https://home.treasury.gov/system/files/136/PPP–IFR–Additional-Revisions-Loan-Forgiveness-Loan-Review-Procedures-Interim-Final-Rules.pdf

For questions about PPP loan forgiveness or for support in completing the application documents, please contact your HBK Advisor.