Insights

MPL General Counsel Corner – PPP Loan Forgiveness – A Tale of Two Cities

May 22, 2020

Hi Everyone:

The million-dollar question (bad analogy, but the best I can come up with): What does the loan forgiveness process look like?  I have chatted with several lenders and the most common response has been:  “we are working on it”.

Here is what I know:

  1. The Lenders have 60 days from the submission of the forgiveness application to provide an answer to the borrower.
  2. The Lenders will be making an initial determination, which will then be submitted to the SBA for ultimate approval and funding (also falls in the 60 day timeline).
  3. Paperwork submission and review will not be uniform in terms of the way you send it to the Lender.
    • One lender email that I recently reviewed mentioned a link to a portal will be used for document submission.
    • Another lender is not certain if they will use internal staff or outsource the document review to a third-party consultant.  They have also not decided how the document submission will work.
  4. I have included a few useful links for PPP forgiveness guidance from the US Chamber of Commerce, Trout CPA and RKL.
    1. US Chamber of Commerce:  PPP Guide to Loan Forgiveness
    2. Trout:  Loan Forgiveness Worksheet
    3. RKL:  PPP Forgiveness & Cashflow Link

The long and short is that this process will likely not be uniform at the start, but hopefully will improve over time.  It will also be a “Tale of Two Cities” as the larger (>$2M) PPP loans will be scrutinized and questioned more versus the smaller (<$2M) PPP loans.

I hope you get out and enjoy your Memorial Day this weekend.

Here are some other things that may be important or relevant for you:

Please see all of our prior updates at the this link or if you would like to be added to our email list, please click here

As always, please don’t hesitate to email myself (jsanders@mpl-law.com), Andy Miller (amiller@mpl-law.com), Christian Miller (cmiller@mpl-law.com) or anyone in our office with questions or comments.  

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