On May 15, 2020, the U.S. Small Business Administration (the SBA) released a loan forgiveness application (the Application) for borrowers who participated in the Paycheck Protection Program (the PPP). The Department of the Treasury (the Treasury) has stated that regulatory guidance regarding loan forgiveness is forthcoming. Until the Treasury and the SBA publish that guidance — likely in the form of an interim final rule and frequently asked questions — the Application provides some clarity around the loan forgiveness process.
Still, significant ambiguity remains around the loan forgiveness process. Borrowers seeking loan forgiveness should pay careful attention to the instructions and formulas set forth in the Application and the eventual guidance from the Treasury.
Below are some key insights based on our review of the Application.
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