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8 Steps to PPP Loan Forgiveness
The Paycheck Protection Program (PPP), which establishes forgivable loans administered by the Small Business Administration (SBA), is a part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Then, at the end of 2020, the CARES Act was improved by the passage of the Economic Aid to the Hard-Hit Small Businesses, Nonprofits, and Venues Act (new act). In addition to providing more funding to the PPP, the new act also greatly streamlined the forgiveness process for loans of $150,000 or less. Section 1106 of the CARES Act lays out the statutory rules relating to PPP loan forgiveness if your loan is greater than $150,000. In general, whether all or a portion of a PPP loan can be forgiven depends on the amounts for specified expenditures by the borrower during your chosen Covered Period. For these larger loans, you will need to complete up to eight distinct steps in order to secure the SBA’s forgiveness of your PPP loan. 1. Determine the correct form of application to use: 3508 standard form or 3508EZ. 2. Select the best Covered Period for forgivable expenses for your unique business situation. 3. Track forgivable costs during the Covered Period, which include: • Payroll and owner-compensation • Benefit costs, such as health care, company-paid life insurance and retirement contributions as well as local payroll taxes paid by the company • Certain facilities costs 4. Provide and retain required source documents for all
Covered Period costs submitted for forgiveness. 5. Consider, then apply, any reductions in forgiveness that can arise from reductions in FTE and/or wage levels. 6. Consider, then apply, either of the safe harbors related to step 5 above. 7. Complete the borrower certifications required by the SBA. 8. Submit your application to Heritage Bank. We will review your forgiveness application and forward to the
SBA for funding.
AN ESTIMATED
100,000+JOBS
WERE IMPACTED BY THESE LOANS
ROUND 1 4, 6 4 2 R O UND 2 1, 724 6,366 LOANS NEW CUSTOMERS $1.19 BILLION ROUND 1 $897. 4 M R OUND 2 $297.1 M
AVERAGE LOAN SIZE ROUND 1: $193,000 ROUND 2: $172,000 {
APPLICATION FOR FORGIVENESS
To seek forgiveness, a PPP loan borrower completes and submits one of three SBA forgiveness forms: • Form 3508 PPP Loan Forgiveness
Application (standard application) • Form 3508EZ PPP Loan Forgiveness
Application (simplified application) • Form 3508S PPP Loan Forgiveness
Application (for loans of $150,000 or less) All three applications are in the process of being electronically updated by the SBA to reflect the new act and can be used as of March 5, 2021. Of particular note, the new version of Form 3508S is greatly streamlined as it eliminates the calculation of forgiveness and instead relies exclusively on each applicant’s certifications regarding eligibility for the program and use of funds. Steps 4-6 on the previous page don’t apply, as no calculations need be made or presented on Form 3508S. For PPP loans in excess of $150,000, a PPP loan borrower may complete and submit on Form 3508 or the updated Form 3508EZ. Both forgiveness applications for larger loans consist of: (i) borrower information, (ii) the Covered Period selected, (iii) a summary of forgivable costs, and (iv) borrower representations and certifications. Form 3508EZ requires fewer calculations than the 3508. Borrowers can use Form 3508EZ if they meet at least one of the following three requirements: 1.The borrower is self-employed, does not have any employees and did not include any employee salaries in its PPP loan application. 2.The borrower did not reduce: (a) the number of its employees or the average paid hours of employees between January 1, 2020, and the end of the applicable Covered
Period (or employee reduction safe harbors were met related to the inability to re-hire employees or hire similarly qualified employees), and (b) any employee’s salary or wages by more than 25% during the applicable covered period when compared to the period from
January 1, 2020, to March 31, 2020. 3.The borrower did not reduce any employee salary or hourly wages by more than 25% during the applicable Covered Period when compared to the period from
January 1, 2020, to March 31, 2020, and the borrower was unable to operate at the same level of business activity as before February 15, 2020, during the Covered
Period due to compliance with applicable COVID-19 government requirements or guidance issued by CDC, OSHA or the Secretary of
Health and Human Services.
Heritage Bank uses an electronic portal for all forgiveness applications. The forgiveness portal includes an integrated application process, so we will not be accepting paper versions of the forms, either delivered to our offices or uploaded into the portal. Until that time, you may review the application forms and their instructions as a tool to help you plan and organize your forgiveness effort. Contact your relationship manager or visit HeritageBankNW.com for information.
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As a bank that’s “grown up” in the PNW, we’re lucky to live in a place surrounded by so many natural playgrounds. That’s also why we offer our customers a number of extras—like cell phone protection, roadside assistance and travel insurance—so you have peace of mind wherever your adventure takes you. Have you been to any of the places above? Share your story with #TravelWithHeritage!