On October 8, 2020, the Small Business Administration (SBA) provided a simplified PPP loan forgiveness application, Form 3508S, for borrowers with loans of $50,000 or less and new guidance concerning these small loans along with form instructions.
The guidance provides that PPP borrowers with loans of $50,000 or less are exempted from any reductions in forgiveness based on:
- Reductions in full-time equivalent (FTE) employees; and
- Reductions in employee salary or wages.
The new application form can be used by PPP borrowers applying for forgiveness on PPP loans with a total loan amount of $50,000 or less, unless those borrowers together with their affiliates received loans totaling $2 million or more.
All borrowers are still required to make certifications and provide documentation for their loan expenses.
There remains a possibility that Congress may provide additional legislation to simplify the loan forgiveness process further, allow tax deductions for forgiven expenses or further clarify the forgiveness rules. We will keep you posted on new legislation or further guidance in this area.
If you would like assistance completing your loan forgiveness application and the necessary supporting documentation, our team is available to assist.
The Treasury and the SBA continue to update, change and clarify the guidance related to the PPP Loan Program. Your ORBA advisor is available to assist you through this complex process. If you have questions regarding this Client Alert or if we can be of assistance in helping you through the application or forgiveness process, please contact Frank Washelesky at [email protected] or your ORBA advisor.