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.