SBA Releases Additional PPP Guidance: Forgiveness Application Resubmissions, Excess Loan Amount Errors

By Jessica Jeane, J.D. posted 01-17-2021 11:21 AM


Jessica L. Jeane, J.D.
Director of Public Policy & Strategic Communications
January 17, 2021

The U.S. Small Business Administration (SBA) has released additional Paycheck Protection Program (PPP) guidance regarding forgiveness application resubmissions and excess loan amount errors. 

PPP Loan Forgiveness Application Resubmission
SBA Procedural Notice, CONTROL NO.: 5000-20077, details the following:

  • the process for borrower resubmission of loan forgiveness applications using PPP Loan Forgiveness Application Form 3508S (SBA Form 3508S);
  • lender responsibilities to notify borrowers of (a) lender decisions to deny forgiveness in full, (b) SBA loan review decisions and borrower appeal rights to SBA’s Office of Hearings and Appeals (OHA), and (c) SBA remittance of loan forgiveness payments; and
  • lender responsibilities in the event of offset of PPP remittances to lenders by the Treasury Offset Program (TOP).
PPP Excess Loan Amount Errors

SBA Procedural Notice, CONTROL NO.: 5000-20078, details the effects of “excess loan amount errors” made by a borrower or lender in completing the following:

  • PPP Borrower Application Form (SBA Form 2483, SBA Form 2483-SD, or lender’s equivalent form), and
  • the PPP Lender Application Form (SBA Form 2484 or SBA Form 2484-SD) for First Draw PPP Loans and Second Draw PPP Loans. 

Note: An excess loan amount error is a borrower or lender error made in good faith that caused a borrower to receive a PPP loan amount exceeding the borrower’s correct maximum loan amount under the Coronavirus Aid, Relief, and Economic Security Act (CARES) Act (P.L. 116-136) and the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (Economic Aid Act), enacted under the Consolidated Appropriations Act, 2021 (P.L. 116-260). As written in the Procedural Notice, “a borrower may not receive loan forgiveness for any amount that exceeds the correct maximum loan amount permitted by statute for that borrower. This is true whether the excess loan amount was caused by borrower error or lender error.”

The PPP portal will fully open on Tuesday, January 19, 2021, to all participating PPP lenders to submit First and Second Draw loan applications to the SBA.

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