The Small Business Administration announced that it has tentative plans to begin accepting lender forgiveness decision information on August 10 using a new “PPP Forgiveness Platform.”[1] Note that this platform is intended solely for lenders—borrowers will submit their forgiveness application to their lender. Once the lender has made a determination on forgiveness, the lender then transmits data to the SBA.

The date is tentative because, as of the July 23 release date of the notice, Congress was considering legislation that could make various changes to the PPP loan program yet again.

The SBA Procedural Notice provides the following information about this new platform:

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. The PPP Forgiveness Platform is available only to PPP Lenders, not PPP borrowers.

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.[2]

While borrowers will not be using this system, final approval of forgiveness cannot take place until lenders are able to send the data to the SBA and the SBA approves the lender’s determination to grant forgiveness. So borrowers will not get a final determination of the status of any forgiveness application until after both the lender begins accepting such applications and the SBA begins accepting the data from the lenders.

The following morning the AICPA published an article online in the Journal of Accountancy that made the case that borrowers likely shouldn’t be rushing to apply for forgiveness in any event. The article outlines points made in the AICPA Town Hall presented on the same day the SBA notice was published.[3]

The article quotes Kari Hipsak, CPA, CGMA, an AICPA manager, as noting that the real deadline for applications will not come until 10 weeks after the covered period ends:

“There’s no need to rush through the forgiveness,” she said. “A lot of businesses, I think, want to put the forgiveness behind them, but there are still a lot of unanswered questions. And so as long as there’s not a deadline to have this application submitted, other than 10 months after the end of the covered period, it’s really a business decision.”[4]

The article goes on to note other items related to PPP loan forgiveness that indicate not rushing to apply for forgiveness may be the most prudent approach:

There is a lack of clarity about how broad the utilities class of expenses is.
We expect additional guidance regarding the many exceptions a borrower may qualify for to mitigate or eliminate the FTE reduction of forgiveness, including the new one added by the Paycheck Protection Program Flexibility Act.
We need clarification regarding how self-employed borrowers document paying their income replacement payroll cost for 2020.
It will be important to take time and clearly document the necessary items prior to the application, instead of having to rush to assemble significant amounts of additional documentation a lender may request.[5]

[1] SBA Procedural Notice, “Procedures for Lender Submission of Paycheck Protection Program Loan Forgiveness Decisions to SBA and SBA Forgiveness Loan Reviews,” July 23, 2020, https://www.sba.gov/sites/default/files/2020-07/5000-20038.pdf (retrieved July 24, 2020), p. 4

[2] SBA Procedural Notice, “Procedures for Lender Submission of Paycheck Protection Program Loan Forgiveness Decisions to SBA and SBA Forgiveness Loan Reviews,” p. 4

[3] Jeff Drew and Ken Tysiac, “PPP forgiveness: No need to rush, and other tips,” Journal of Accountancy website, July 24, 2020, https://www.journalofaccountancy.com/news/2020/jul/ppp-loan-forgiveness-tips.html (retrieved July 24, 2020)

[4] Jeff Drew and Ken Tysiac, “PPP forgiveness: No need to rush, and other tips,” Journal of Accountancy website, July 24, 2020

[5] Jeff Drew and Ken Tysiac, “PPP forgiveness: No need to rush, and other tips,” Journal of Accountancy website, July 24, 2020