The SBA recently issued some guidelines on PPP loan forgiveness. There is a safe harbor presumption that any PPP loan was made in good faith under $2,000,000.00. The SBA forgiveness application is finally out, SBA Form 3508 (05/20). The application must be completed and given to your PPP lender who will then submit the application to the SBA. The SBA will likely take at least 60 to 90 days to make a forgiveness determination.
To complete the forgiveness application, start with the worksheets and work backwards. Many will need guidance from their PPP lender and CPA because the application is complex. Payroll costs are eligible for forgiveness. On the form there are distinctions between payrolls costs paid and payroll costs incurred. Payroll costs are further defined at 85 FR 20811. Certain nonpayroll costs are eligible for forgiveness if incurred before 2-15-20 – such as mortgage interest. The FTE dates have been changed and there are options in the application’s instructions. You have a choice of when your covered 8-week period starts. Generally, it can be either when the loan was disbursed or when you first made a payroll payment. There is no deadline set to submit the application at this point.
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