The SBA forgiveness portal has now been updated to streamline the forgiveness process for borrowers who have a PPP loan of $150,000 or less. The following information outlines the steps for our customers to submit the new 3508S forgiveness form, as well as provides the details for those needing to apply for forgiveness for loans above $150,000. GreenStone PPP customers have been provided the unique URL to begin their loan forgiveness application.
LOANS OF $150,000 OR LESS
To assist our customers with the new process, the 3508S form has been updated in our third-party platform and is available for use at this time.
The 3508S form is a streamlined application where borrowers can attest to maintaining full time employees and properly using the funds for eligible payroll and non-payroll expenses. This application does not require any information to be submitted with the application. The application requires that borrowers maintain all supporting documents, detailed below under the 3508EZ form, for a period of 4 years. While this application is streamlined, it does not exclude the borrower from a potential SBA audit. If a borrower is subject to an SBA audit, all information will be required to be submitted within 10 days of request. If a borrower is concerned about this timeline, all necessary documents to support the application may be uploaded on the platform at the time of application.
3508S (Loan size: $150,000 or less) DOCUMENTATION and DETAILS Necessary to Submit your PPP Loan Forgiveness Application:
No supporting documentation will be needed when a borrower submits a 3508S forgiveness application. However, the application requires that borrowers maintain all supporting documents as detailed below under the 3508EZ and 3508 forms.
LOANS ABOVE $150,000
If the borrower’s loan is in excess of $150,000, the borrower may use the Form 3508EZ or Form 3508 only. The SBA has provided a checklist to determine eligibility to use the 3508EZ form and GreenStone's third-party platform will help determine if the borrower qualifies for this option. In the event the borrower does not qualify, the “long form”, Form 3508, will be the only option.
If the borrower is required to use the Form 3508EZ or Form 3508, the following documentation is expected to be provided at the time of the forgiveness application:
3508EZ (Loan size: greater than $150,000) DOCUMENTATION and DETAILS Necessary to Submit a PPP Loan Forgiveness Application
- SELF EMPLOYED OWNER REPLACEMENT COSTS: Owner replacement costs (payroll) will need to be supported by proof of payments (payment receipts or canceled checks) made to the owner. These amounts are limited based upon the covered period chosen.
- 8-week covered period: Limited to the lesser of 8/52nds of 2019 net self-employment income per your application or $15,385
- 24-week covered period: Limited to the lesser of 2.5/12ths of 2019 net self-employment income per your application or $20,833
- PAYROLL: Documentation verifying the eligible cash compensation and non-cash benefit payments from the Covered Period consisting of each of the following:
- Bank account statements or third-party payroll service provider reports (QuickBooks is not considered a third-party payroll service provider) documenting the amount of cash compensation paid to employees.
- Tax forms (or equivalent third-party payroll service provider reports) for the periods that overlap with the Covered Period:
- Payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941 or Form 943); and
- State quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported, to the relevant state.
- Payment receipts, cancelled checks, or account statements documenting the amount of any employer contributions to employee group health, life, disability, vision or dental insurance and retirement plans that the Borrower included in the forgiveness amount.
- If you checked only the second box on the checklist on page 1 of these instructions, the average number of full-time equivalent employees on payroll employed by the Borrower on January 1, 2020 and at the end of the Covered Period.
- NON-PAYROLL: Documentation verifying existence of the obligations/services prior to February 15, 2020 and, for all categories, eligible payments from the Covered Period.
- Business mortgage interest payments: Copy of lender amortization schedule and receipts or cancelled checks verifying eligible payments from the Covered Period; or lender account statements from February 2020 and the months of the Covered Period through one month after the end of the Covered Period verifying interest amounts and eligible payments.
- Business rent or lease payments: Copy of current lease agreement and receipts or cancelled checks verifying eligible payments from the Covered Period; or lessor account statements from February 2020 and from the Covered Period through one month after the end of the Covered Period verifying eligible payments.
- Business utility payments: Copy of invoices from February 2020 and those paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
- Covered operations expenditures: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
- Covered property damage costs: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, and documentation that the costs were related to property damage and vandalism or looting due to public disturbances that occurred during 2020 and such costs were not covered by insurance or other compensation.
- Covered supplier costs: Copy of contracts, orders, or purchase orders in effect at any time before the Covered Period (except for perishable goods), copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
- Covered worker protection expenditures: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, and documentation that the expenditures were used by the Borrower to comply with applicable COVID-19 guidance during the Covered Period.
3508 (Loan size: $150,000 or greater) DOCUMENTATION and DETAILS Necessary to Submit a PPP Loan Forgiveness Application
- All required documentation detailed in the “3508EZ DOCUMENTATION and DETAILS Necessary to Submit a PPP Loan Forgiveness Application” section is needed, in addition to the following:
- PPP Loan Forgiveness Calculation Form
- PPP Schedule A
- Full Time Equivalency documentation showing (at the election of the Borrower):
- The average number of FTE employees on payroll per week employed by the Borrower between February 15, 2019 and June 30, 2019;
- The average number of FTE employees on payroll per week employed by the Borrower between January 1, 2020 and February 29, 2020; or in the case of a seasonal employer, the average number of FTE employees on payroll per week employed by the Borrower between February 15, 2019 and June 30, 2019; between January 1, 2020 and February 29, 2020; or any consecutive 12-week period between February 15, 2019 and February 15, 2020.
The selected time period must be the same time period selected for purposes of completing PPP Schedule A, line 11. Documents may include payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941) and state quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported, to the relevant state. Documents submitted may cover periods longer than the specific time period.
Each application provides specific documents each borrower must maintain but is not always required to submit based on the application being used. It is highly recommended that the borrower review this section and confirm this documentation is readily available in the event of an SBA audit.
GreenStone is committed to providing our members the best service and experience during the forgiveness process and will continue to provide additional communication as key details of the PPP program change. Please visit the SBA website for additional information.
