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Paycheck Protection Program

This information is intended to convey general information only and not provide legal advice or opinions. This information (and the posting and viewing of this information on the IBC website) should not be construed as legal advice, may not be current and is subject to change without notice.

Matrix Summary Chart - updated January 19

March 30
Here is the CO PPP Progress as of March 28, 2021: https://www.sba.gov/sites/default/files/2021-03/PPP_Report_Public_210328-508.pdf
 
CO PPP Loan #s:              60,374
CO PPP Loan $s:              $4,069,821,291
 
For the most current version of the COVID Disaster Relief equitable access data report click here.


FYI....President Joe Biden signed the PPP Extension Act of 2021 into law today, extending the Paycheck Protection Program an additional two months to May 31, 2021, and then providing an additional 30-day period for the SBA to process applications that are still pending.

Click here to view the SBA revised guidance on the PPP platform’s procedures for addressing hold codes and compliance check error messages.  Note, the SBA conducts front-end compliance checks on lender loan guaranty applications. When an issue is identified, the compliance checks generate an error message.  The SBA’s existing Procedural Notice provides lenders with methods for resolving hold codes on first-draw PPP loans and compliance check error messages on first- and second-draw loans.  In this update, the SBA said it has refined its automated screening process to return fewer hold codes and now allows greater use of lender certifications to resolve hold codes. SBA also removed error messages related to borrowers’ disqualifying criminal histories and delinquent or defaulted federal student loans after revising those eligibility restrictions.

March 25

Congress today passed ICBA-advocated legislation to extend the Paycheck Protection Program ahead of its March 31 expiration. The extension now goes to President Joe Biden to sign into law.

Under existing law, any application not approved by March 31—even if it was submitted prior to that date—cannot receive PPP funds. The newly passed bill allows borrowers to apply for loans through May 31 and gives the SBA until June 30 to consider applications.

March 23
The SBA issued updated Paycheck Protection Program application forms that incorporate last week's interim final rule implementing American Rescue Plan Act changes.
 
The Rule: The IFR authorizes PPP loans for Shuttered Venue Grant applicants (though the PPP loan amount will be deducted from the grant); clarifies payroll costs not eligible for forgiveness; and clarifies eligibility for 501(c) organizations, NAICS code 72 businesses, and internet-only news businesses.
 
Forms: The SBA issued updated versions of the following:  
More: More PPP information and resources are available on the SBA and Treasury sites and ICBA's PPP and EIP News page

March 19
The U.S. Small Business Administration is launching a splash page for the Shuttered Venue Operators Grant (SVOG) application portal today in anticipation of opening applications for the much-anticipated critical economic relief program on Thursday, April 8, 2021.  Prior to the official application opening, the SBA will host a national informational webinar to highlight the application process for potential eligible entities from 12:30 to 2 p.m. MT on Tuesday, March 30, 2021. The registration information is found here.
 
One last reminder:  the order of approval is important if a client wants both PPP and SVOG.  The PPP must be approved first.

March 4
Here is the link to the SBA webinar slide deck presented March 4.  It clarifies much from the new PPP IFR, including links on page 19 to newly posted FILLABLE application forms.
 
Also note updates to the SBA’s frequently asked questions which contain these highlights:
  • FAQs 57 and 58: defines lobbying activities as it applies to eligibility of 501(c)(6) organizations and destination marketing organizations; and clarifies that PPP proceeds may not be used for lobbying activity expenses by any PPP borrower.
  • FAQs 59 and 60: borrowers who filed for bankruptcy after disbursement of their First Draw loan are eligible for forgiveness if funds were used according to forgiveness rules, but are not eligible for a Second Draw loan.
  • FAQ 61: a borrower may certify on a Second Draw application that it will have used all First Draw proceeds “only for eligible expenses” (if true), even if it doesn’t use 60 percent for payroll, in which case forgiveness will be reduced.
  • FAQ 62: a borrower that received partial forgiveness of its First Draw loan is eligible for a Second Draw loan as long as the borrower used the full amount of its First Draw PPP Loan only for eligible expenses listed in the consolidated IFR implementing PPP updates.
  • FAQ 63: clarifies that alternative business size standards are not applicable to Second Draw loans. Generally, borrowers must have no more than 300 employees, with a few limited exceptions.
  • FAQ 64: outlines which borrowers may use an Individual Taxpayer Identification Number (ITIN) instead of a Social Security Number (SSN) when applying for a PPP loan.
  • FAQ 65: for PPP borrowers who claim the Employee Retention Credit, payroll costs that are qualified wages for the Employee Retention Credit are not eligible for loan forgiveness if the employer elects to claim the credit for those amounts.
March 3
New PPP Interm Final Rule plus FAQs and new Application Forms Released
The following have been posted to SBA's PPP website:
PPP Interim Final Rule - Revisions to Loan Amount Calculation and Eligibility
Effective Mar 3, 2021 - https://www.sba.gov/document/policy-guidance-ppp-interim-final-rule-revisions-loan-amount-calculation-eligibility

Lender forms
Paycheck Protection Program Lender Application Form First Draw Loan Guaranty (updated 03-03-21) - https://www.sba.gov/document/sba-form--lender-application-form-paycheck-protection-program-loan-guaranty-0
Paycheck Protection Program Lender Application Form Second Draw Loan Guaranty (updated 03-03-21) - https://www.sba.gov/document/sba-form-2484-sd-ppp-second-draw-lender-application-form

Borrower Forms
Paycheck Protection Program First Draw Borrower Application Form (updated 03-03-21) - https://www.sba.gov/document/sba-form--paycheck-protection-program-borrower-application-form
Paycheck Protection Program First Draw Borrower Application Form for Schedule C Filers Using Gross Income (published 03-03-21) - https://www.sba.gov/document/sba-form-2483-c-ppp-first-draw-borrower-application-form-schedule-c-filers-using-gross-income
Frequently Asked Questions - https://www.sba.gov/document/support-faq-lenders-borrowers
Borrower second draw schedule C filer form 2483-SD-C
https://www.sba.gov/document/sba-form-2483-sd-c-ppp-second-draw-borrower-application-form-schedule-c-filers-using-gross-income

March 2
In response to the White House’s recent changes to the PPP program, the SBA announced it will "soon" publish a new interim final rule and revised application for Schedule C filers. Until then, it issued the following considerations:
  • The new definition of “payroll costs” for Schedule C filers will be available for loans approved after the effective date of the interim rule. To use the new definition, applicants must use the new application form (SBA Form 2483-C or SBA Form 2483-SD-C).
  • Lenders who have submitted the current application form to the platform and have not yet been approved may withdraw the application from the platform.
  • If the application has been approved but the loan has not yet been disbursed, lenders may cancel the loan and the applicant may apply for a new loan using the new application form.
  • If lenders have disbursed the loan but have not yet filed the related Form 1502, they may cancel the loan and applicants may repay and apply for a new loan using the new application form.
  • If lenders have disbursed the loan and filed the related Form 1502, the loan cannot be canceled.
  • Loans cannot be increased to take advantage of the new definition.
February 25
While one of the Biden administration's Paycheck Protection Program reforms announced earlier this week started yesterday, the rest are set to be implemented next week.
 
Now: A 14-day period during which only businesses with fewer than 20 employees can apply for PPP relief started yesterday. Applications already in the pipeline or requiring error resolution will continue to be processed during this period.
 
Next Week: Several other reforms are not set to take effect until next week. SBA said it will communicate details on these program changes this week.
  • A revised loan calculation formula for sole proprietors, independent contractors, and self-employed individuals will reportedly use gross income instead of net income, as advocated by ICBA. Further, $1 billion will be set aside for PPP loans to businesses in this category that do not have employees and that are located in low- or moderate-income areas.
  • Qualifying restrictions for small-business owners delinquent on their federal student loans or with prior non-fraud felony convictions will be eliminated.
  • Non-citizen small-business owners who are lawful U.S. residents may use Individual Taxpayer Identification Numbers to apply for relief.
The SBA Denver District office just released the attached and below.  There is a lot of information here:
 
Link to the PPP Reform Fact Sheets directly from SBA’s site. Here it is: https://www.sba.gov/document/support-biden-administration-ppp-reform-fact-sheets. If you scroll down that page, you will find different targeted community versions for your use. A version is translated into Spanish and is at the very bottom of the page.
 
On the PPP Reform Announcement, there are 5 major programmatic reforms intended to expand access to underserved communities. They are summarized below and discussed in the fact sheets.
The only one that is fully rolled out, as of yesterday, is the 2-week Exclusivity Period.  The rest will require updates to guidance, rules, forms and systems.
 
•            Exclusivity Period - Instituted a 14-day period during which only businesses with fewer than 20 employees can apply for relief through PPP. The 14-day exclusivity period started on Wednesday, February 24, 2021 at 7 a.m. MST and will go through March 9, 2021. Number of employees refers to the total number on payroll, not the FTE count. We will continue working on those loans already submitted before this date but we will not queue loans for larger businesses through this period.  Larger-sized businesses are encouraged to keep working with resource partners and lenders on applications until they can be submitted after March 9th.
•            Allow sole proprietors, independent contractors, and self-employed individuals to receive more financial support by revising the PPP’s funding formula and creating a $1 billion set-aside for these categories of applicants. The $1 billion set-aside is for non-employer Schedule C applicants located in LMI census tracts. Once those set-aside funds are allocated, these entities will still have access to remaining pool of funds. Schedule C filers will now use the Gross Profit Line and not the Net Profit Line, as the basis for doing the loan calculation. SBA will provide additional guidance, update systems and revise the How to Calculate the Loan Fact Sheets for this item.
•            Eliminate the exclusionary restriction that prevents some small business owners with prior non-fraud felony convictions from obtaining relief through the PPP. Rules and systems need to be updated to effect this change.  The felony cannot be fraud related and the applicant cannot be incarcerated now.
•            Working with the Departments of the Treasury and Education, the SBA will remove the student loan delinquency restriction to broaden access to the PPP. Rules and systems need to be updated to effect this change. 
•            Ensure access for non-citizen small business owners who are lawful U.S. residents by clarifying that they may use Individual Taxpayer Identification Numbers (ITINs) to apply for relief. This is the number assigned by IRS to non-citizens for tax purposes. It needs to be current and not expired. It must be a US-issued ITIN.  SBA cannot issue these numbers. The PPP Application Platform has already been updated to accept this form of unique identifier.  However, we expect more guidance on this topic.
 
PPP Progress as of 2/21/2021:
 
Latest report: Paycheck Protection Program approved lending through February 21, 2021
 
Colorado
#s:                        36,060 (1.88% of Natl #s)
$s:                        $2,858,692,297  (2.04% of Natl $s)
Avg Loan size:     $79,276
 
National
#s:                        1,918,663
$s;                        $140,280,566,497
Avg Loan Size:   $73,114
# of Lenders:     5,158
 
Nationally almost 72% of the loan approvals have been made to those requesting $50k or less.
 
Both Draw Loans with 10 or fewer employees:  
1,560,958                         81.36% of all loans
$41,795,041,497             29.79% of all dollars
 
Current Data on achieving equity:
SBA COVID Relief Program Report (published 02-19-21)
 
Other PPP News:
This week, lenders were provided with more training, guidance and tools on how to resolve PPP applications with error codes, including self-service instructions for EINs/TINs issues. They can download all instructions and documents from the PPP Platform.
 
Lenders were reminded this week that beginning March 5, 2021, it is mandatory to use the revised PPP Forgiveness Forms and/or collect the same data in their systems. Forgiveness Information is located here: https://www.sba.gov/funding-programs/loans/coronavirus-relief-options/paycheck-protection-program/ppp-loan-forgiveness.
 
SBA CO’s David Benavides, LRS, teamed up with Cory Arcarese, from Pikes Peak SBDC/Colorado Enterprise Fund and recorded a “How To Apply for PPP” tutorial. The video lasts just under an hour and is very informative for prospective PPP applicants. It can be accessed here:  How to Apply for the SBA PPP Loan.  You can find all PPP applications at www.sba.gov/ppp.
 
Targeted EIDL Advance:
 
SBA has been reaching out to those in the first Priority Group (EIDL applications that already received a partial EIDL Advance between $1,000 - $9,000) to request a “true up” to $10,000. Applicants are being invited back into the portal via email with instructions to determine eligibility and submit documentation.  To help in spotting and stopping fraud, be aware all communications from SBA will be sent from an official government email with an @sba.gov ending.
 
The applicants invited back in to the portal must still prove they meet the “targeted” eligibility criteria.  We added a mapping tool to help applicants determine if they are located in a low-income community BEFORE they complete the application: https://sbaeidl.policymap.com/app. Once they accept and establish a profile in the portal, they will be directed through a series of Next Steps and can see statuses in their own portal profile.  They should expect to sign a Form 4506-T electronically to allow SBA to get tax documents from IRS and then they will start completing an application. This will be reviewed and decisioned by ODA personnel. It is in the applicant’s best interest to triple check that every answer can be verified and make sure all numbers and bank information is up to date. As of now, there is no waiver of eligibility criteria or appeal of any final decision.
 
Next, SBA will reach out to those who applied for EIDL assistance on or before December 27, 2020, but did not receive an EIDL Advance due to lack of program funding. We do not have a time line for when that might happen yet.
 
More information can be found here: https://www.sba.gov/funding-programs/loans/coronavirus-relief-options/covid-19-economic-injury-disaster-loans
 
Section 1112 Debt Relief
Due to anticipated insufficiency of funds to make payments in the amounts and installments as prescribed by the Economic Aid Act, the SBA filed a new plan with Congress.  Attached is a Flow Chart to help navigate who will get what amounts and for how long. Lenders were provided a Notice and a national training call was held with them yesterday.  Potential Borrower recipients were sent letters about 3 weeks ago, before the funding became an issue. They will not receive updated letters. Lenders will need to advise their clients of the level of relief available. Program updates will be posted on the website at: https://www.sba.gov/funding-programs/loans/coronavirus-relief-options/sba-debt-relief.
 
SVOG
The Application Period has not yet been announced. However, there are actions that potential SVOG applicants can take now in preparation for the application opening. The CO SBDC Network put together a nice infographic based on tips we shared with them (attached).  Also, SBA recorded a tutorial on registering in SAM and other various systems, which must be done prior to application.  Here is where you can find that tutorial: SAM.gov Entity Registration Training (02-18-21).
 
The last updated FAQ is dated 2/12/21: https://www.sba.gov/funding-programs/loans/coronavirus-relief-options/shuttered-venue-operators-grant.
 
Websites in Spanish:
SBA added several new Spanish "vanity URLs" for key pandemic relief content.
   
Be advised:  Vanity URLs are CaSe sPeCiFiC.  If you include upper case characters in your materials, you may encounter a broken link.
 
Wildfire Disaster Assistance
Finally, yesterday SBA issued a Disaster Declaration authorizing disaster assistance for those impacted by the CO Wildfires that occurred this past Fall. Attached are materials in Spanish and English. There will be a training webinar on Tuesday, March 2, 2021 at 10:00a MST, hosted by the Northwest SBDC. Please contact Steven.White@sba.gov for more information.
 
The Virtual Outreach Center supporting this declaration opened today. You can send interested parties and individual there to answer specific application questions.
 
Virtual Business Recovery Center and
Virtual Disaster Loan Outreach Center
Monday – Friday (5 days/week)
8 a.m. – 8 p.m. Eastern Time
FOCWAssistance@sba.gov
(800) 659-2955

February 23
SBA has issued guidance dealing with fixing EINs on PPP loans. For instructions click here or cut and paste this https://www.ibcbanks.org//Files/PPP/tin-self-service-instructions.pdf to your browser. The site to login is: https://caweb.sba.gov/cls/dsp_login.cfm.


February 22
The Biden administration announced today several Paycheck Protection Program reforms to target the program to the smallest businesses.  The updates include:
  • A 14-day period, starting Wednesday, during which only businesses with fewer than 20 employees can apply for PPP relief. During this period, however, applications already in the pipeline or requiring error resolution will continue to be processed.
  • Revising the loan calculation formula for sole proprietors, independent contractors, and self-employed individuals to use gross income instead of net income, as advocated by ICBA. Additional details are expected on whether this will be limited by number of employees or otherwise. Further, $1 billion will be set aside for PPP loans to businesses in this category without employees located in low- and moderate-income (LMI) areas.
  • Eliminating restrictions preventing small-business owners delinquent on their federal student loans or with prior non-fraud felony convictions from qualifying for the PPP.
  • Ensuring access for non-citizen small-business owners who are lawful U.S. residents by clarifying that they may use Individual Taxpayer Identification Numbers to apply for relief.
https://www.whitehouse.gov/briefing-room/statements-releases/2021/02/22/fact-sheet-biden-harris-administration-increases-lending-to-small-businesses-in-need-announces-changes-to-ppp-to-further-promote-equitable-access-to-relief/?utm_campaign=2021%20Advocacy&utm_medium=email&_hsmi=112368468&_hsenc=p2ANqtz--lsmy-ie9q1nkAsDmW4g1A7WN5K6Iv2dfAcJlr0OIVYnzwgAViP4R7LYupfI_V_9AF82Iv5yKX9__V5NVNToMykw5zRbFCSRvbm-zTWDYnmEKXuCo&utm_content=112368468&utm_source=hs_email

February 10
Revised SBA PPP Procedures for Addressing Hold Codes on First Draw PPP loans and Compliance Check Error Messages on First Draw PPP Loans and Second PPP Loans - Effective February 11
SBA Procedural Notice 5000-20092 - revises guidance provided in SBA Procedural Notice 5000-20083

February 1
The SBA Denver District Office has reached out to clarify a misperception that seems to be spreading regarding Shuttered Venue Grant eligibility after a borrower has applied for PPP.  Apparently some lenders have advised and are advising clients that they could apply for PPP now and just not accept the loan or return it if they want a SVOG when that program rolls out. 
 
The only way someone who applied for PPP after Dec 27, 2020 (first or second draw) can be eligible to apply for SVOG, is if they are declined a PPP loan.  Withdraw/cancel, reject approval or immediate repayment of PPP will not re-establish SVOG eligibility.

January 29
SBA and Treasury just released new FAQs for questions 54-56 only
https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

January 28
SBA continues to issue news and guidance. Linked below are 4 procedural notices:
  For more information and updates, visit SBA.gov/PPP or Treasury.gov/CARES

January 27
SBA hold codes documentation as well as a lender's user guide. Both of these documents are currently posted on the SBA forgiveness platform. Please note that these documents WILL be updated over time.

Resolving First Draw PPP Loan Hold Codes User Guide as of 1/26/2021

January 20
SBA, in consultation with the Treasury Department, has recently released additional PPP guidance and resources:    For more information and updates, visit SBA.gov/PPP or Treasury.gov/CARES 

Tuesday, January 19
SBA Guidance opens today for all banks

Wednesday, January 13
The Small Business Administration just announced that it will reopen the Paycheck Protection Program loan portal to PPP-eligible lenders with $1 billion or less in assets at 9 a.m. (Eastern time) this Friday, Jan. 15. The SBA also said:
  • The portal will fully open to all participating PPP lenders on Tuesday, Jan. 19.
  • The reopening applies to both first- and second-draw applications.
  • The SBA plans to have dedicated service hours for smaller lenders after the portal fully reopens.
Earlier this week, the SBA granted dedicated PPP access to certain community financial institutions defined in the Economic Aid Act.
 
The SBA has also released resources for the next round of PPP lending, including instructions for accessing the updated lender portal, new application forms for first- and second-draw loans, and procedural notices on approved lender status and reimbursing lenders for EIDL advances deducted from forgiveness amounts.
 
Additional PPP resources are available here:

Below is a link to the Colorado Office of Economic Development and International Trade web page URL you can refer businesses to for PPP 3 assistance and other business relief programs.
 
COVID-19 Business and Nonprofit Resources | Colorado Office of Economic Development and International Trade
 
On this page is the hotline info for SBDC and MBO consultants.  They can take calls from small businesses and help them prep business financials and records to get ready to apply to PPP.   
 
The Small Business Navigator can direct you to resources and answer questions about COVID-19 specific funding. Hours are Monday through Friday from 8:00 am to 5:00 pm.
Hotline: (303) 860-5881
Email: oedit_sbnavigator@state.co.us

Sunday, January 11
Tonight the SBA has finally released the technical information lenders need to access the updated PPP loan portal system. As a reminder, the portal opens tomorrow only for "community financial institutions" which are defined by the CARES Act to mean CDFIs, MDIs, Certified Development Companies, and Microloan Intermediaries.

Tonight's release includes two presentations for accessing the updated loan portal system. CFI lenders will be able to submit First Draw loans to SBA either via an Application Programming Interface (API) tool or entry of application data via web screen method. The first presentation contains information regarding API technical information. The second presentation is the SBA Paycheck Protection Platform Lender Instructions -- Origination Systems User Guide.
 
CFI Lenders may use the SBA PPP Lender Hotline at 833-572-0502 and find more PPP Platform Resources at: https://forgiveness.sba.gov/.
 
Read the new Paycheck Protection Platform API Technical Information HERE.
 
Read the SBA Paycheck Protection Platform Lender Instructions -- Originations Systems User Guide HERE.
 
The SBA will continue to provide updates on operations the week of January 11 it also plans to dedicate specific times to process and assist the smallest PPP lenders with loan applications from eligible small businesses.

Friday, January 8
The SBA just released a series of forms and guidance for the next round of Paycheck Protection Program lending starting for certain lenders on Monday:
 
Updated First Draw Forms  
Second Draw Forms  
Guidance & Resources