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As a top-10 Small Business Administration lender1, we used our expertise to help thousands of businesses quickly gain funds through the Paycheck Protection Program (PPP), a federally provided, forgivable loan that covers certain business costs. Now that the program has closed, we're here to guide you through loan forgiveness. Here, you'll find details including the eligibility criteria, how to apply and frequently asked questions.

Latest Updates

The Paycheck Protection Program (PPP) closed on May 31, 2021.

Ready to apply for forgiveness? Scroll down to Applying for loan forgiveness for more details.

Applying for loan forgiveness

KeyBank is now accepting PPP loan forgiveness applications for PPP loans issued in 2020, as many of these first loan repayments are coming due in September. All clients that were issued a PPP loan in 2020 through KeyBank have been sent an automated email with login information to our customer portal to apply for forgiveness. If you need your email with login resent to you, please contact your Relationship Manager directly.

Starting in August, KeyBank will begin accepting PPP loan forgiveness applications for PPP loans issued in 2021. All clients that were issued a PPP loan in 2021 through KeyBank will be sent an automated email with login information to our customer portal to apply for forgiveness in August.

To avoid having to make a repayment on your PPP loan, we recommend you apply for forgiveness as soon as possible, but in any event, no later than 16 months after your PPP loan proceeds were first disbursed to you.

Please make sure you have all the information and documents you need to apply for forgiveness with us online. Our digital PPP loan forgiveness application will ask you a series of questions to determine which forgiveness application form is best for your business.

You can prepare to apply by reviewing the information below:

  • Review current PPP loan forgiveness information.The SBA will forgive PPP loans under certain circumstances. To help you understand the criteria and to see if your loan may qualify, take time to read the information on this page. The SBA and U.S. Treasury have released Frequently Asked Questions on PPP Loan Forgiveness. The SBA and U.S. Treasury also continue to regularly update their Frequently Asked Questions about PPP.
  • Compile the information you need for our loan forgiveness application. In order to easily complete the application, gather this information and have it at the ready:
    • Payroll: Documentation verifying the eligible cash compensation and non-cash benefit payments from the covered period.
    • Full-time Equivalent Employees: Documentation showing the average number of FTE employees on payroll during the borrower’s chosen reference period, if using the standard form, or showing the average number of FTE employees on payroll employed by the borrower on January 1, 2020, and at the end of the covered period, if using the EZ form.
    • Non-payroll: Documentation verifying existence of the obligations/services prior to February 15, 2020 (if applicable), and eligible payments from the covered period.

Frequently asked questions2

Which application do I use to apply for forgiveness?

There are three forms of forgiveness applications: (1) a simplified form for loans of $150,000 or less (Form 3508S); (2) an EZ form (Form 3508EZ); and (3) the standard form (Form 3508).

Borrowers whose PPP loan is $150,000 or less will use the simplified form of loan forgiveness application.

For loans over $150,000, to use the EZ PPP loan forgiveness application, borrowers must:

  • Not have reduced the salaries or wages of their employees by more than 25% during the Covered Period compared to the most recent full quarter before the Covered Period, and not have reduced the number of employees or average paid hours of their employees between January 1, 2020, and the end of the Covered Period; OR
  • Have been unable to operate during the Covered Period at the same level of business activity as before February 15, 2020, as a result of health directives related to COVID-19 and not have reduced the salaries or wages of their employees by more than 25% during the Covered Period compared to the most recent full quarter before the Covered Period.

Any borrowers that do not fit in the above categories for the simplified form or the EZ form will complete the standard forgiveness application. Our digital forgiveness portal will accommodate all the application forms, and the portal will select the appropriate form based on questions answered by the borrower.

What supporting documentation do I need?

Find out more about what supporting documentation you need for the forgiveness application on our Paycheck Protection Program Forgiveness checklist.

What time period do I use to calculate the forgiveness amount?

The loan forgiveness covered period is the period beginning on the date the lender disburses the PPP loan and ends on any date selected by the borrower that occurs during the period 8 weeks after the loan disbursement date and 24 weeks after the loan disbursement date (whichever time period is chosen, referred to as the "Covered Period" herein).

A borrower may submit a loan forgiveness application before the end of the Covered Period if the borrower has used all the loan proceeds for which the borrower is requesting forgiveness.

When will I know if my loan forgiveness application was approved?

Key must issue a decision to the SBA on a loan forgiveness application not later than 60 days after receipt of a complete loan forgiveness application from the borrower. After Key issues its forgiveness decision to the SBA, the SBA has 90 days to remit the forgiveness amount to Key.

What expenses are forgivable and what documentation do I need to submit for those expenses?

Payments of interest on debt obligations incurred prior to 2/15/2020 are a permitted use of PPP loan proceeds but do not count toward the forgiveness amount. Borrowers with loans of $150,000 or less will use the simplified forgiveness application, which does not require the borrower to submit supporting documentation with the forgiveness application (but the borrower must retain the documentation in its files for the required time frame).

Forgivable Expenses

Amount and Details

Documentation to be Submitted

Payroll costs

Payroll costs paid and incurred during the Covered Period.

Payroll costs are considered paid on the day that paychecks are distributed, or the borrower originates an ACH credit transaction. Payroll costs are considered incurred on the day that the employee’s pay is earned. Payroll costs incurred but not paid during the borrower’s last pay period of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. Otherwise, payroll costs must be paid during the Covered Period. Count payroll costs that were both paid and incurred only once.

Must be at least 60% of the forgiveness amount. Forgiveness amount will be reduced if the borrower reduced any employee salaries or hourly wages by more than 25% during the Covered Period as compared to the most recent full quarter before the Covered Period, unless prior salaries/wages are restored by 12/31/2020 (for a PPP loan made in 2020) or the last day of the Covered Period (for a PPP loan made in 2021).

Forgiveness amount will also be reduced if the borrower’s average weekly number of FTE employees during the Covered Period was less than during the borrower’s chosen reference period (can be 2/15/2019 – 6/30/2019; 1/1/2020 – 2/29/2020; or for seasonal employers, either of the preceding periods or a consecutive 12-week period between 2/15/2019 and 2/15/2020). The reduction will not apply if the borrower reduced its FTE employee levels from 2/15/2020 through 4/26/2020 and then restored its FTE employee levels by 12/31/2020 (for a PPP loan made in 2020) or the last day of the Covered Period (for a PPP loan made in 2021) in the pay period that included 2/15/2020. Employees who were fired for cause, who voluntarily resigned, or who voluntarily requested and received a reduction of their hours will not be counted against the borrower. Any positions for which the borrower made a good-faith, written offer to rehire an employee or to restore any reduction in hours during the Covered Period which was rejected by the employee will also not be counted against the borrower. If a borrower can, in good faith, document an inability to hire similarly qualified employees for unfilled positions on or before 12/31/2020 (for a PPP loan made in 2020) or the last day of the Covered Period (for a PPP loan made in 2021), the reduction in FTE employees will not be counted against the borrower.

The borrower is also exempt from the reduction in loan forgiveness based on a reduction in FTE employees described above if the borrower, in good faith, is able to document that it was unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020, and December 31, 2020 (for a PPP loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021), by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID-19.

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 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); 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 health insurance and retirement plans that the Borrower included in the forgiveness amount.

Documentation showing the average number of FTE employees on payroll during the borrower’s chosen reference period. 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. Borrowers that submit the EZ form of application because they did not reduce the salaries or wages of their employees by more than 25% during the Covered Period compared to the most recent full quarter before the Covered Period, and were unable to operate during the Covered Period at the same level of business activity as before February 15, 2020, as a result of health directives related to COVID-19 must provide the average number of FTE employees on payroll employed by the borrower on January 1, 2020, and at the end of the Covered Period.

Covered mortgage obligations

Payments of interest on any business mortgage obligation on real or personal property incurred before 2/15/2020.

Must be paid during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the billing date is after the Covered Period. Count covered mortgage obligations that were both paid and incurred only once.

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.

Covered rent obligations

Business rent or lease payments pursuant to lease agreements for real or personal property in force before 2/15/2020.

Must be paid during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the billing date is after the Covered Period. Count covered rent obligations that were both paid and incurred only once.

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.

Covered utility payments

Business payments for a service for the distribution of electricity, gas, water, transportation, telephone, or internet access for which service began before 2/15/2020.

Must be paid during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the billing date is after the Covered Period. Count covered utility obligations that were both paid and incurred only once.

Copy of invoices from February 2020 and those paid during the Covered Period along with the associated receipts, cancelled checks, or account statements verifying those eligible payments.

Covered operations expenditures

Payments for any business software or cloud computing service that facilitates business operations, product or service delivery, the processing, payment, or tracking of payroll expenses, human resources, sales and billing functions, or accounting or tracking of supplies, inventory, records and expenses.

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

Costs related to property damage and vandalism or looting due to public disturbances that occurred during 2020 that was not covered by insurance or other compensation.

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

Expenditures made by a borrower to a supplier of goods for the supply of goods that (A) are essential to the operations of the borrower at the time at which the expenditure is made; and (B) is made purchase to a contract, order, or purchase order (i) in effect at any time before the Covered Period; or (ii) with respect to perishable goods, in effect before or at any time during the Covered Period.

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

Operating or capital expenditures to facilitate the adaptation of the business activities to comply with requirements established or guidance issued by federal, state, or local government related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID-19.

Examples include the purchase, maintenance, or renovation of assets that create or expand (A) a drive-through window facility; (B) an air pressure ventilation or filtration system; (C) a physical barrier such as a sneeze guard; (D) an expansion of additional indoor, outdoor, or combined business space; and (E) health screening capability. Other examples include the purchase of particulate filtering facepiece respirators and other kinds of personal protective equipment.

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.

What qualifies as "payroll costs"?
  • Payroll costs consist of (1) Cash Compensation; (2) Non-Cash Compensation; and (3) Compensation to Owners (if applicable):
    • Cash Compensation:
      • compensation to employees (whose principal place of residence is the United States) in the form of salary, wages, commissions, or similar compensation
      • cash tips or the equivalent (based on employer records of past tips or, in the absence of such records, a reasonable, good-faith employer estimate of such tips)
      • payment for vacation, parental, family, medical, or sick leave
      • allowance for separation or dismissal
    • Non-Cash Compensation:
      • payment for the provision of employee benefits consisting of group health care coverage, including insurance premiums, and retirement
      • payment of state and local taxes assessed on compensation of employees
    • Compensation to Owners (if applicable):
      • Amounts paid to owner-employees/self-employed individual/general partners (for an independent contractor or sole proprietor, this includes wages, commissions, income or net earnings from self-employment)
  • The following are excluded from payroll costs:
    • Cash compensation of an individual employee in excess of $100,000, prorated as necessary
    • Federal employment taxes imposed or withheld during the applicable covered period, including the employee’s and employer’s share of FICA and Railroad Retirement Act taxes, and income taxes required to be withheld from employees*
      • *The SBA interprets this exclusion to mean that payroll costs are calculated on a gross basis, without subtracting federal taxes that are imposed on the employee or withheld from employee wages
    • Any compensation of an employee whose principal place of residence is outside of the United States
    • Qualified sick and family leave wages for which a credit is allowed under sections 7001 and 7003 of the Families First Coronavirus Response Act (Public Law 116–27).
  • If a borrower pays furloughed employees their salary, wages, or commissions during the covered period, those payments are eligible for forgiveness if they do not exceed an annual salary of $100,000, prorated as necessary.
  • The amount of loan forgiveness requested for owner-employees and self-employed individuals’ payroll compensation can be no more than 2.5 months’ worth (2.5/12) of an owner-employee or self-employed individual’s 2019 or 2020 compensation (up to a maximum of $20,833 per individual in total across all businesses). C-corporation owner-employees are capped by the pro-rated amount of their 2019 or 2020 (whichever year was used to calculate the loan amount) employee cash compensation and employer retirement and health care contributions made on their behalf. S-corporation owner-employees are capped by the pro-rated amount of their 2019 or 2020 (whichever year was used to calculate the loan amount) employee cash compensation and employer retirement contributions made on their behalf, but employer health insurance contributions made on their behalf cannot be separately added because those payments are already included in their employee cash compensation. Schedule C or F filers are capped by the pro-rated amount of their owner compensation replacement, calculated based on 2019 or 2020 net profit. General partners are capped by the pro-rated amount of their 2019 or 2020 net earnings from self-employment (reduced by claimed section 179 expense reduction, unreimbursed partnership expenses, and depletion from oil and gas properties) multiplied by 0.9235. No additional forgiveness is provided for retirement or health care insurance contributions for self-employed individuals, including Schedule C or F filers and general partners, as such expenses are paid out of their net self-employment income.
How do I calculate full-time equivalent (FTE) employees?

"Full-time equivalent employee" means an employee who works 40 hours or more, on average, each week. The hours of employees who work less than 40 hours are calculated as proportions of a single full-time equivalent employee and aggregated, as explained below. To calculate FTE employees, divide the average number of hours paid for each employee per week by 40, capping this quotient at 1.0. Borrowers may choose to calculate full-time equivalency in one of two ways for employees who were paid for less than 40 hours per week. First, the borrower may calculate the average number of hours a part-time employee was paid per week during the covered period. Second, for administrative convenience, borrowers may elect to use a full-time equivalency of 0.5 for each part-time employee.

Example: An employee who was paid 48 hours per week during the covered period would be an FTE employee of 1.0.

Example: If an employee was paid for 30 hours per week on average during the covered period, the employee would be considered an FTE employee of 0.75 (30 hours / 40 hours = 0.75). If an employee was paid for ten hours per week on average during the covered period, the employee would be considered an FTE employee of 0.25 (10 hours / 40 hours = 0.25). Alternatively, the borrower could elect to use 0.5 for each part-time employee for administrative convenience.

Borrowers may select only one of the two methods and must apply that method consistently to all part-time employees. In either case, the borrower must provide the aggregate total of all FTE employees by adding together all of the employee-level FTE employee calculations.

How do I calculate the required reduction in the forgiveness amount for a reduction in FTEs?

In general, a reduction in FTE employees during the Covered Period reduces the loan forgiveness amount by the same percentage as the percentage reduction in FTE employees. The borrower must first select a reference period: (i) February 15, 2019, through June 30, 2019; (ii) January 1, 2020, through February 29, 2020; or (iii) in the case of a seasonal employer, either of the two preceding methods or a consecutive 12-week period between February 15, 2019, and February 15, 2020. If the average number of FTE employees during the Covered Period is less than during the chosen reference period, the total eligible expenses available for forgiveness is reduced proportionally by the percentage reduction in FTE employees.

Example: If a borrower had 10.0 FTE employees during the reference period and this declined to 8.0 FTE during the Covered Period, the percentage of FTE employees declined by 20%. Thus, only 80% of otherwise eligible expenses are available for forgiveness.

Borrowers are exempted from the loan forgiveness reduction if the borrower is able to document in good faith (i) an inability to rehire individuals who were employees of the borrower on February 15, 2020; and (ii) an inability to hire similarly qualified individuals for unfilled positions on or before December 31, 2020 (for a PPP loan made in 2020) or the last day of the Covered Period (for a PPP loan made in 2021). Borrowers are also exempted from the loan forgiveness reduction if the borrower is able to document in good faith an inability to return to the same level of business activity as the borrower was operating at before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020, and December 31, 2020 (for a PPP Loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021), by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety. If an employee of the borrower is fired for cause, voluntarily resigns, or voluntarily requests a reduced schedule (an FTE reduction event) during the Covered Period, the borrower may count such employee at the same full-time equivalency level before the FTE reduction event when calculating the FTE employee reduction penalty. The borrower should maintain all documentation regarding any such terminations and schedule reductions.

Borrowers with loans of $50,000 or less (except those that, together with their affiliates, received PPP loans totaling $2 million or more) are exempt from any reductions in the forgiveness amount based on reductions in FTEs.

How do I calculate the required reduction in the forgiveness amount for a reduction in employees’ salary or wages?

A reduction in an employee’s salary or wages in excess of 25% will generally result in a reduction in the loan forgiveness amount, unless an exception applies. For each new employee in 2020 and 2021, as well as each existing employee who was not paid more than the annualized equivalent of $100,000 in any pay period in 2019, the borrower must reduce the total forgiveness amount by the total dollar amount of the salary or wage reductions that are in excess of 25% of base salary or wages of the employee during the most recent full quarter during which the employee was employed before the Covered Period (subject to exceptions for borrowers who restore reduced wages or salaries). The instructions to the application instruct the borrower to compare the average annual salary or hourly wage during the Covered Period to the average annual salary or hourly wage during the most recent full quarter before the Covered Period. This reduction calculation is performed on a per employee basis, not in the aggregate. This reduction is performed based on the Covered Period.

Excerpt from application instructions:

Step 1. Determine if pay was reduced more than 25%.

  1. Enter average annual salary or hourly wage during Covered Period: ______________.
  2. Enter average annual salary or hourly wage during the most recent full quarter before the Covered Period: ______________.
  3. Divide the value entered in 1.a. by 1.b.: ______________.
    If 1.c. is 0.75 or more, enter zero in the column above box 3 for that employee; otherwise proceed to Step 2.

Example: A borrower has elected to use an eight-week Covered Period. This borrower reduced a full-time employee’s weekly salary from $1,000 per week during the reference period to $700 per week during the Covered Period. The employee continued to work on a full-time basis during the Covered Period with an FTE of 1.0. In this case, the first $250 (25% of $1,000) is exempted from the reduction. The borrower seeking forgiveness would list $400 as the salary/hourly wage reduction for that employee, which equates to the extra $50 weekly reduction multiplied by eight weeks in the covered period.

To ensure that borrowers are not doubly penalized, the salary/wage reduction applies only to the portion of the decline in employee salary and wages that is not attributable to an FTE reduction.

Example: An hourly wage employee had been working 40 hours per week during the borrower selected reference period (FTE employee of 1.0), and the borrower reduced the employee’s hours to 20 hours per week during the Covered Period (FTE employee of 0.5). There was no change to the employee’s hourly wage during the Covered Period. Because the hourly wage did not change, the reduction in the employee’s total wages is entirely attributable to the FTE employee reduction, and the borrower is not required to conduct a salary/wage reduction calculation for that employee.

Borrowers with loans of $50,000 or less (except those that, together with their affiliates, received PPP loans totaling $2 million or more) are exempt from any reductions in the forgiveness amount based on reductions in employee salaries or wages.

If I restore reductions in employee salaries/wages and FTE count, can I avoid a reduction in my loan forgiveness amount?

Yes. If employee salaries and wages were reduced between February 15, 2020, and April 26, 2020 (the safe harbor period), but the borrower eliminated those reductions by December 31, 2020 (for a PPP loan made in 2020), or eliminates those reductions by the last day of the Covered Period (for a PPP loan made in 2021), the borrower is exempt from any reduction in loan forgiveness amount that would otherwise be required due to reductions in salaries and wages. Similarly, if a borrower reduced FTEs during the safe harbor period and eliminated those reductions by the earlier of December 31, 2020 (for a PPP loan made in 2020), or eliminates those reductions by the last day of the Covered Period (for a PPP loan made in 2021), the borrower is exempt from any reduction in loan forgiveness amount that would otherwise be required due to reductions in FTE employees.

The borrower is also exempt from the reduction in loan forgiveness based on a reduction in FTE employees if the borrower, in good faith, is able to document that it was unable to return to the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020, and December 31, 2020 (for a PPP Loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021), by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety.

Borrowers with loans of $50,000 or less (except those that, together with their affiliates, received PPP loans totaling $2 million or more) are exempt from any reductions in the forgiveness amount based on reductions in FTEs or employee salaries or wages.

What documentation do I need to keep in my files?
  • In addition to the documentation listed above that is required to be submitted to us for the EZ version and the standard application form, borrowers must maintain the following documentation:
    • For standard application form:
      • PPP Schedule A Worksheet or its equivalent and documentation supporting the content of the Schedule A Worksheet, including the listing of each individual employee in Table 1 and 2 of such worksheet and the FTE employee information in such worksheet.
      • For EZ version of application:
        • Documentation supporting the certification that annual salaries or hourly wages were not reduced by more than 25% during the Covered Period relative to the most recent full quarter before the Covered Period. This documentation must include payroll records that separately list each employee and show the amounts paid to each employee during the most recent full quarter before the Covered Period, and the amounts paid to each employee during the Covered Period.
        • Documentation supporting the certification, if applicable, that 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 (other than any reductions that arose from an inability to rehire individuals who were employees on February 15, 2020, if the borrower was unable to hire similarly qualified employees for unfilled positions on or before December 31, 2020, (for PPP loans made in 2020), or the last day of the Covered Period (for PPP loans made in 2021). This documentation must include payroll records that separately list each employee and show the amounts paid to each employee between January 1, 2020, and the end of the Covered Period.
        • Documentation supporting the certification, if applicable, that the borrower was unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020, and December 31, 2020 (for a PPP loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021) by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards of sanitation, social distancing, or any other work or customer safety requirement related to COVID-19. This documentation must include copies of the applicable requirements for each borrower location and relevant borrower financial records.
      • For EZ version and standard application form:
        • Documentation regarding any employee job offers and refusals, refusals to accept restoration of reductions in hours, firings for cause, voluntary resignations, written requests by any employee for reductions in work schedule, and any inability to hire similarly qualified employees for unfilled positions on or before December 31, 2020 (for a PPP loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021).
        • Documentation supporting the certification, if applicable, that the borrower was unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020, and December 31, 2020 (for a PPP loan made in 2020), or the last day of the Covered Period (for a PPP loan made in 2021) by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards of sanitation, social distancing, or any other work or customer safety requirement related to COVID-19. This documentation must include copies of the applicable requirements for each borrower location and relevant borrower financial records.
      • For all borrowers:
        • All records relating to the borrower’s PPP loan, including documentation submitted with its PPP loan application, documentation supporting the borrower’s certifications as to the necessity of the loan request and its eligibility for a PPP loan (including the borrower’s gross receipt reduction certification for a Second Draw PPP Loan, if applicable), documentation necessary to support the borrower’s loan forgiveness application, and documentation demonstrating the borrower’s material compliance with PPP requirements.
    • Borrowers using the simplified application form must retain all employment records/payroll documentation for four years and all other documentation for three years after the date the loan application is submitted to the lender. Borrowers using the EZ version or standard application form must retain all documentation for six years after the date the loan is forgiven or repaid in full. Borrowers must permit authorized representatives of the SBA to access such files upon request.
Where can I find additional information?

All the information shared here is based on guidance released by the SBA. Please visit sba.gov or treasury.gov for any updates.

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1

Source: U.S. Small Business Administration (SBA) 7(a) lender by dollar volume through February 2020.

2

The information presented here should not be considered legal or accounting advice, and should not substitute for legal, accounting, or other professional advice in which the facts and circumstances may warrant. We encourage you to consult legal counsel as it pertains to your own unique situation(s) and/or with any specific legal questions you may have.

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