On January 20th, the SBA released updated PPP forgiveness forms including a new one-page form for loans under $150,000. These forms may be used for applying for forgiveness for the original PPP loans and 2nd draw PPP loans.
PPP Loan Forgiveness Application Form 3508S (replaces the previous under $50,000 version)
This form can be used for borrowers with loan amounts of $150,000 or less, even those borrowers with combined loans to affiliates totaling $2 million or more. Unlike the long form 3508, SBA Form 3508S requires fewer calculations and less documentation for eligible borrowers. SBA Form 3508S does not require borrowers to show the calculations used to determine their loan forgiveness amount. However, SBA may request information and documents to review those calculations as part of its loan review or audit processes. This requirement indicates that although the $150,000 form is easier to complete, the borrower must still perform the cumbersome forgiveness calculations unless they are under $50,000 or meet the same requirements of the 3508EZ form (did not reduce wages more than 25% and did not reduce FTE’s).
Borrowers can use this form to apply for forgiveness of a First or Second Draw (PPP) Loan if the Borrower’s PPP loan amount is more than $150,000 and the Borrower did not reduce annual salary or hourly wages of any employee (making less than 100,000 in 2019 on an annualized rate) by more than 25 percent during the Covered Period compared to the most recent full quarter before the Covered Period AND The Borrower did not reduce the number of employees or the average paid hours of employees between January 1, 2020 and the end of the Covered Period (when excluding FTE and hours reductions allowed to be excluded under Safe Harbor 1 rules)
The third form released by SBA is used for all other borrowers to apply for forgiveness, requires full forgiveness calculations and support to be submitted with the application.