The SBA released revised PPP Loan Forgiveness Application Form 3508S late Tuesday night. This form was revised to now be applicable for borrowers that received $150,000 or less from either a first draw or a second draw PPP loan. Form 3508S was originally only available to those borrowers who received $50,000 or less in PPP funding. The new form is one page in length and requires the borrower to list the PPP loan amount, the number of employees (headcount NOT FTE) at the time of the original loan application and at the time of the forgiveness application, the covered period dates, the amount of the loan spent on payroll costs, and the requested loan forgiveness amount. The borrower must also make two certifications regarding compliance with eligible use of funds and that the information provided is true and correct.
While there is (almost) no documentation required to be submitted with the Form 3508S, the instructions state that if you received a loan of more than $50,000 OR if you received a loan of $50,000 or less but together, with your affiliates, received a first or second draw loan of more than $2 million, you are still required to calculate a reduction in loan forgiveness for reductions in full-time equivalent employee (FTE) counts or wage/salary reductions of more than 25%. Borrowers will not need to take these reductions into account if you meet one of the criteria for filing the Form 3508EZ.
Documentation showing proof of the gross receipts decline is required when submitting a loan forgiveness application for a second draw loan if it was not submitted when initially applying for the loan. Any documentation used to substantiate loan and loan forgiveness calculations should be retained in the borrower’s records for a minimum of four years.
The form also clarifies that you must apply for forgiveness separately for each loan you receive. Borrowers will not be able to apply for forgiveness for a first draw and second draw loan together on the same application.
