covid-19

PAYCHECK PROTECTION PROGRAM

Details on the new Paycheck Protection Program (PPP) aimed at helping struggling small businesses impacted by the COVID-19 pandemic.

Most recently updated PPP FAQs

  • A155) What are the restrictions on a change of ownership when a PPP loan is fully satisfied?

  • A156) What are the restrictions on a change of ownership when a PPP loan is not fully satisfied?

  • A157) When SBA prior approval is required for a change of ownership, what must the PPP lender submit to the SBA?

  • A158) Regardless of whether or not SBA approval is required, what requirements apply to the entity and its owners in a change in ownership?

  • A159) Do payments required for the provision of group health care benefits, including insurance premiums, include vision and dental benefits?

  • A160) What consideration should the lender give to the forgiveness payments made to the bank by SBA when PPP loan forgiveness has been approved in whole or in part?

  • A161) What effect does the payment or nonpayment of fees of an agent or other third party have on SBA’s guarantee of a PPP loan or SBA’s payment of fees to lenders?

  • Are payroll costs that were incurred during the covered period or the alternative payroll covered period but paid after the covered period or the alternative payroll covered period eligible for loan forgiveness?

  • A163) Are payroll costs that were incurred before the covered period but paid during the covered period eligible for loan forgiveness?

  • A164) Are borrowers required to calculate payroll costs for partial pay periods?

  • A165) For purposes of calculating cash compensation, should borrowers use the gross amount before deductions for taxes, employee benefits payments, and similar payments, or the net amount paid to employees?

  • A167) What expenses for group health care benefits will be considered payroll costs that are eligible for loan forgiveness?

  • A169) How is the amount of owner compensation that is eligible for loan forgiveness determined?

  • A170) Are any individuals with an ownership stake in a PPP borrower exempt from application of the PPP owner-employee compensation rule when determining the amount of their compensation that is eligible for loan forgiveness?

  • A171) Are nonpayroll costs incurred prior to the covered period, but paid during the covered period, eligible for loan forgiveness?

  • A172) Are nonpayroll costs incurred during the covered period, but paid after the covered period, eligible for loan forgiveness?

  • A173) If a borrower elects to use the alternative payroll covered period for payroll costs, does the alternative payroll covered period apply to nonpayroll costs?

  • A174) Is interest on unsecured credit eligible for loan forgiveness?

  • A175) Are payments made on recently renewed leases or interest payments on refinanced mortgage loans eligible for loan forgiveness if the original lease or mortgage existed prior to February 15, 2020?

  • A176) Covered utility payments, which are eligible for forgiveness, include a “payment for a service for the distribution of . . . transportation” under the CARES Act. What expenses does this category include?

  • A177) Are electricity supply charges eligible for loan forgiveness if they are charged separately from electricity distribution charges?

  • A178) Are amounts attributable to the business operation of a tenant or sub-tenant of the PPP borrower or, in the context of home-based businesses, household expenses, eligible for forgiveness?

  • A179) Are rent payments to a related party eligible for loan forgiveness?

  • A180) If a seasonal employer elects to use a 12-week period between May 1, 2019 and September 15, 2019 to calculate its maximum PPP loan amount, what period in 2019 should be used as the reference period for calculating any reductions?

  • A181) Will a borrower be subject to a reduction to its forgiveness amount due to a reduction in FTE employees during the covered period if the borrower offered to rehire one or more laid off employees but the employees declined?

  • A182) In calculating FTE reduction exceptions in Table 1 of the PPP Schedule A Worksheet on the Loan Forgiveness Application (SBA Form 3508 or lender equivalent), do borrowers include employees who made more than $100k in 2019 (those listed in Table 2)?

  • A183) How do borrowers calculate the reduction in their loan forgiveness amount arising from reductions in employee salary or hourly wage?

  • A184) For purposes of calculating the loan forgiveness reduction required for salary/hourly wage reductions in excess of 25% for certain employees, are all forms of compensation included or only salaries and wages?

  • A186) If a borrower submits a timely loan forgiveness application, does the borrower have to make any payments on its loan prior to SBA remitting the forgiveness amount, if any?

  • A187) Can PPP lenders use scanned copies of documents, E-signatures, or Econsents for loan forgiveness applications and loan forgiveness documentation?

  • A188) When a borrower submits SBA Form 3508S or lender’s equivalent form, the lender shall:

  • A189) Should the lender report loan forgiveness to the IRS for loans forgiven under the PPP?

  • A190) What is the impact of SBA’s lien requirements on EIDL loans over $25,000 on a borrower’s ability to obtain other financing for business operations?

  • A191) SBA will deduct the amount of any EIDL advance received by a PPP borrower from the forgiveness amount remitted to the lender. How will a lender know the amount of the EIDL advance that will be automatically deducted by SBA?

  • A192) How should a lender handle any remaining balance due on a PPP loan after SBA remits the forgiveness amount to the lender?

  • A193) What should a lender do if a borrower received an EIDL advance in excess of the amount of its PPP loan?

Helpful Resources and External Guidance

Industry Updates

Service Providers Are Here To Help

    MK Decision

    MK Decision helps community banks to offer banking services digitally via remote implementation.

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    FINSYNC

    Members of ICBA can use FINSYNC's online loan application to support the PPP Loan with no upfront costs and same day implementation, which comes complete with a portal for processing PPP loans more efficiently and tools to help you track loan forgiveness eligibility, among other benefits.

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    NXTSoft

    NXTsoft Launches solution to resolve the many headaches associated with SBA E-Tran system: OmniConnect CARES Queue Streamlines the PPP Loan Submission Process for Financial Institutions

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    Abrigo

    With two-day implementation, Abrigo enables banks to serve their communities using our automated PPP loan origination system that is integrated into E-Tran, providing them with software to handle the inundation of loan requests and help small businesses and the self-employed pay their employees during the coronavirus crisis.

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    ProfitStars Lending Network

    The Jack Henry Lending Paycheck Protection Program Portal is a quick and easy solution for connecting Small Business borrowers to SBA certified banks.

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    Wolters Kluwer

    With Paycheck Protection Program supported by TSoftPlus, you can immediately start processing compliant PPP loans, with no upfront costs.

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    NewTek

    Newtek Business Finance Solutions is now offering Paycheck Protection Program loans to small business owners.

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    Lendsmart

    At this time we are happy to offer our solution free of charge for 3 months and deferred payments, and we will also offer our solution at a substantially discounted rate.

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    Q2

    Help small businesses get the loan assistance they need with a fast, easy, mobile-first application.

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    Holtmeyer & Monson

    H&M will submit the completed loan application to the SBA for approval and guarantee issuance and provide loan closing services with detailed documentation instructions.

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    Teslar

    The free Teslar Unite – PPP module assists community bankers with the SBA CARES Act PPP loan application process via an integrated web portal that allows small business customers to easily download the PPP loan application, fill it out, upload it and track the status of the loan.

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    OnDeck

    ODX enables banks to digitally originate business credit and deposit products - allowing business owners to open accounts and apply for loans without physically coming into a branch.

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    Fundation

    Fundation's white-labeled SBA Paycheck Protection Plan application for your community banks small business customers (use code 4242 for mobile verification).

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    StreetShares

    Community banks can now launch Business Lending-as-a-Service, in 7 days or less with all fees waived.

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    Botdoc

    Botdoc is allowing up to 15 users to use Botdoc for free for 60 days to help community bankers begin securely exchanging documents within 15 minutes, even when working remotely.

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    Finastra

    Finastra is taking action to optimize business lending platforms for the CARES Act and PPP funding.

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    Qcash Financial

    QCash Financial is waiving fees and implementation costs to get our digital small dollar lending solution broadly distributed.

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    Cirrus Secure

    Our secure loan document collection platform enables collaboration and workflow automation to support dispersed teams.

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    Botdoc

    Botdoc is allowing up to 15 users to use Botdoc for free for 60 days to help community bankers begin securely exchanging documents within 15 minutes, even when working remotely.

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    Lendsmart

    At this time we are happy to offer our solution free of charge for 3 months and deferred payments, and we will also offer our solution at a substantially discounted rate.

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    Credit Plus Inc.

    Business and personal credit reports, account monitoring, and portfolio monitoring are a few of our main services.

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    Intellicredit by QwickRate

    Now is the time to adopt aggressive new approaches to discover and monitor portfolio credit quality—both in aggregate and transactionally—including loans affected by COVID-19.

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    nCino

    The cloud-based nCino Bank Operating System incorporates government-defined requirements into loan decision workflows and provides critical insights and analytics to help institutions better understand exposure, manage risk and ensure compliance.

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    Fraud.net

    To help manage risks, Fraud.net is offering its Email Authentication tool-free for three months to community banks and their commercial banking customers.

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    Botdoc

    Botdoc is allowing up to 15 users to use Botdoc for free for 60 days to help community bankers begin securely exchanging documents within 15 minutes, even when working remotely.

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    Venminder

    COVID-19 and TPRM Consideration Resources website offers a wide range of resources including webinars, articles, checklists, and more.

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    CRiskCo

    ICBA member banks may white-label and deploy the system in under a week to support virtual meetings with free access from March 1 through June 30.

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    DefenseStorm

    Cybersecurity services provide monitoring and proactive KnowBe4 training tools to protect against phishing attempts to ensure safety and soundness is maintained.

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    Ncontracts

    Ncontracts's pandemic/business continuity resource page contains educational materials and Ncontinuity, the comprehensive Business Continuity Management tool, has been updated with workflow tools specific to the pandemic.

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    Quantivate

    Quantivate has developed a Pandemic Plan Template that includes a plan structure overview, pandemic planning phases, planning checklists for executive, operations, and more.

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    Iron Mountain

    Digital document management and timely destruction.

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    Deluxe

    Provides content from experienced community bank C-suite members to help community banks prepare for and navigate what is on the near-term horizon.

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    Griffin Technologies

    Via behavioral insights and search keyword re-targeting, Griffin Technologies provides community banks an affordable option to reach small business owners searching for small business loans and similar services.

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    In/Pact

    White labeled, our platform can be branded by the ICBA member bank and they can feature specific local charities such as food banks that are helping those most affected by COVID-19.

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    KapitalWise

    KapitalWise artificial intelligence (AI) platform analyzes data from a variety of sources with the goal of detecting changes in their financial condition, predicting their characteristics and preferences.

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    Kasasa

    Kasasa will waive monthly licensing fees on website and online account opening solutions for new banks joining through June 1, 2020.

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    Avannis

    With the COVID-19 crisis, banks currently utilizing their ICBA membership benefit receive programs including sensitive and understanding verbiage, followed by a commitment and desire to keep the lines of communication open.

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    Main Street Inc.

    Sample social post copy, downloadable imges, and resource links to communicate with account holders.

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    Dell

    Dell offers “Work From Home Bundle Specials” that include 5% discounts on commonly used telecommuting equipment.

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    VGM Forbin

    Ringcentral communication platform allows remote phone systems and video conferencing capabilities with remote roll-outs within 24-48 hours.

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    Agora Services

    To help community banks during COVID-19, we have waited our setup fee and will defer billing for three months.

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    Fintel Connect

    We work with the banks to acquire new customers for the digital account opening products on a performance basis.

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    Finzly

    Finzly is offering a free account opening solution for community banks to enable customers to continue receiving their banking services.

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