Thursday, July 23, 2020, SBA issued a new Procedural Notice to lenders outlining the forgiveness process and providing some instructions as to the new portal that is being created for PPP lenders to use for submitting decisions on PPP borrower loan forgiveness applications to SBA and requesting payment of the forgiveness amount determined by the lender.
The loan forgiveness process outlined in the Procedural Notice is generally repetitive of a culmination of interim final rules previously issued by SBA. The Procedural Notice does clarify that PPP lenders are required to service PPP loans in accordance with 7(a) rules as found in SBA SOP 50 57, as amended. The SOP may be viewed here. After submission of a forgiveness decision to SBA, the lender must continue to service the loan as required.
SBA has partnered with a financial services technology provider – Goldschmitt-CRI – to make available a secure SaaS platform (the PPP Forgiveness Platform) to accept loan forgiveness decisions, supporting documentation, and requests for forgiveness payments. This platform makes available a user interface for Lenders to upload required data and documentation, monitor the status of the forgiveness request, and respond to SBA in case of an inquiry or if SBA selects the loan for review. SBA will post a link to the PPP Forgiveness Platform on its website. The PPP Forgiveness Platform will go live and begin accepting Lender submissions on August 10, 2020, subject to extension if any new legislative amendments to the forgiveness process necessitate changes to the system.
All PPP Lender Authorizing Officials (AOs) currently in the CAFS/ETRAN system will receive a welcome email from SBA (PPPForgivenessRequests@SBA.gov) with instructions on how to access this new platform. If an AO does not receive a welcome email, it should contact SBA’s PPP Lender Hotline at 833-572-0502 for instructions. AOs will automatically be empowered to create up to 10 additional users in the platform for purposes of submitting and monitoring forgiveness requests.
This platform will also allow Lenders to monitor the status of forgiveness payments and support Lender reconciliation. The Lender will use the platform to provide ACH credit information for the account owned by the lender of record (as listed in the SBA ETRAN system) where the lender wishes to receive the PPP forgiveness payments. If the ACH credit information or the routing number is invalid, the Lender will not receive a forgiveness payment.
Lenders are encouraged to read the full Procedural Notice, which can be found here.
In the meantime, WBA will continue its advocacy requesting Congress pass legislation to automatically forgive PPP loans where the loan amount is $150,000 or less. While separate bi-partisan legislation on this matter has been introduced, it is more likely that this automatic forgiveness legislation will be included as part of a CARES 2.0/Phase IV package deal. WBA understands that the Senate Majority Leaders and the Trump Administration have continued negotiations on this today and we are hopeful that something will be released soon. WBA is advocating along with the national trade groups on several aspects of this package deal including automatic forgiveness for loans $150,000 or less and an intermediate forgiveness process for loans under $1 million. Once the full package details are released, WBA will immediately share the information with members.
By, Ally Bates