COVID-19 Guide for Your Business

Under current SBA guidance, to qualify for full Loan Forgiveness:

• You must use at least 60% of funds for eligible payroll costs
• You can use no more than 40% of funds for eligible non-payroll costs

You need to use the funds within the Covered Period, which is the period you chose between 8 and 24 weeks after the date of loan disbursement.

Your eligible Forgiveness amount may be affected by reductions due to compensation or employment changes.

The Covered Period begins on the date the loan was originally disbursed. It ends on a date selected by the Borrower that is at least 8 weeks following the date of loan disbursement and not more than 24 weeks after the date of loan disbursement. For example, if the Borrower received their PPP loan proceeds on Monday, April 20, 2020, the first day of the Covered Period is Monday, April 20, 2020 and the final day of the Covered Period is any date selected by the Borrower between Sunday, June 14, 2020 and Sunday, October 4, 2020.

Note if you have a first and second PPP loan, the Covered Period you  choose for each cannot overlap. This means when you submit a Forgiveness request for your 1st PPP loan, your chosen covered period end date cannot be later than the disbursement date of your 2nd PPP loan. 

Borrowers are generally eligible for forgiveness for the payroll costs paid and payroll costs incurred during the Covered Period (“payroll costs”). Payroll costs are considered paid on the day that paychecks are distributed or the Borrower originates an ACH credit transaction. Payroll costs are considered incurred on the day that the employee’s pay is earned. Payroll costs incurred but not paid during the Borrower’s last pay period of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. Otherwise, payroll costs must be paid during the Covered Period.

An eligible nonpayroll cost must be paid either during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the billing date is after the Covered Period.

It begins on the date loan funds were originally deposited into your account -- look for the ACH credit for SMALL BUSINESS N/A CREDIT PPD in your transaction history. 

Note if you have a first and second PPP loan, the Covered Period you  choose for each cannot overlap. This means when you submit a Forgiveness request for your 1st PPP loan, your chosen covered period end date cannot be later than the disbursement date of your 2nd PPP loan. 

Yes, for the amount of the loan that is forgiven, the SBA will remit both principal and interest accrued. 

The SBA does not require a separate account. 

Yes.

Yes, your eligibility shouldn’t be affected by this.  See FAQ 10 for the acceptable documents. 

No. However, mortgage interest payments do qualify as a non-payroll cost.

No. 

Payroll costs consist of compensation to your employees (whose principal place of residence is the United States) in the form of salary, wages, commissions, or similar compensation; cash tips or the equivalent (based on employer records of past tips or, in the absence of such records, a reasonable, good-faith employer estimate of such tips); payment for vacation, parental, family, medical, or sick leave; allowance for separation or dismissal; payment for the provision of employee benefits consisting of group health care coverage, life, disability, vision, and dental insurance contributions including insurance premiums, and retirement; payment of state and local taxes assessed on compensation of employees; and for an independent contractor or sole proprietor, wages, commissions, income, or net earnings from self-employment, or similar compensation. 

The SBA has shared the following guidance on what Payroll documents will be needed to verify the eligible cash compensation and non-cash benefit payments from the Covered Period consisting of each of the following:

• Company-prepared payroll statement document supported by cancelled checks or bank statements, or third-party payroll service provider reports documenting the amount of cash compensation paid to employees.
• Tax forms (or equivalent third-party payroll service provider reports) for the periods that overlap with the Covered Period:
  • Payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941); and
  • State quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported, to the relevant state.
• Payment receipts, cancelled checks, or account statements documenting the amount of any employer contributions to employee group health, life, disability, vision or dental insurance and retirement plans that the Borrower included in the forgiveness amount.

Nonpayroll costs eligible for forgiveness consist of:

• Covered mortgage obligations: payments of mortgage interest (not including any prepayment or payment of principal) on any business mortgage obligation on real or personal property incurred before February 15, 2020 (“business mortgage interest payments”)
• Covered rent obligations: business rent or lease payments pursuant to lease agreements for real or personal property in  force before February 15, 2020 (“business rent or lease payments”)
• Covered utility payments: business payments for a service for the distribution of electricity, gas, water, telephone, transportation, or internet access for which service began before February 15, 2020 (“business utility payments”)
• Covered operations expenditures: payments for any business software or cloud computing service that facilitates business operations, product or service delivery, the processing, payment, or tracking of payroll expenses, human resources, sales and billing functions, or accounting of tracking of supplies, inventory, records, and expenses
• Covered property damage costs: costs related to property damage and vandalism or looting due to public disturbances that occurred during 2020 that were not covered by insurance or other compensation
• Covered supplier costs: expenditures made to a supplier of goods for the supply of goods that are essential to the operations of the Borrower at the time at which the expenditure is made, and made pursuant to a contract, order, or purchase order in effect prior to the beginning of the Covered Period (for perishable goods, the contract, order, or purchase order may have been in effect before or at any time during the Covered Period)
• Covered worker protection expenditures: operating or capital expenditures that facilitate the adaptation of the business activities of an entity to comply with the requirements established or guidance issued by the Department of Health and Human Services, the Centers for Disease Control, or the Occupational Safety and Health Administration, or any equivalent requirements established or guidance issued by a State or local government, during the period starting March 1, 2020 and ending on the date on which the national emergency declared by the President with respect to the Coronavirus Disease 2019 (COVID-19) expires related to maintenance standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID-19, but does not include residential real property or intangible property.

Eligible nonpayroll costs cannot exceed 40% of the total forgiveness amount. An eligible nonpayroll cost must be paid either during the Covered Period or incurred during the Covered Period and paid on or before the next regular billing date, even if the billing date is after the Covered Period. Count nonpayroll costs that were both paid and incurred only once.

The amount of loan forgiveness the Borrower applies for may be subject to reductions as explained in PPP Schedule A.

• Business mortgage interest payments: Copy of lender amortization schedule and receipts or cancelled checks verifying eligible payments from the Covered Period; or lender account statements from February 2020 and the months of the Covered Period through one month after the end of the Covered Period verifying interest amounts and eligible payments.
• Business rent or lease payments: Copy of current lease agreement and receipts or cancelled checks verifying eligible payments from the Covered Period; or lessor account statements from February 2020 and from the Covered Period through one month after the end of the Covered Period verifying eligible payments.
• Business utility payments: Copy of invoices from February 2020 and those paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
• For the above 3, you also need to submit documentation verifying the existence of the obligations/services prior to February 15, 2020.
• Covered operations expenditures: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
• Covered property damage costs: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, and documentation that the costs were related to property damage and vandalism or looting due to public disturbances that occurred during 2020 and such costs were not covered by insurance or other compensation.
• Covered supplier costs: Copy of contracts, orders, or purchase orders in effect at any time before the Covered Period (except for perishable goods), copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
• Covered worker protection expenditures: Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, and documentation that the expenditures were used by the Borrower to comply with applicable COVID-19 guidance during the Covered Period.

Payroll costs are considered paid on the day that paychecks are distributed or that the Borrower originates an ACH credit transaction.

Payroll costs are considered incurred on the day that the employee’s pay is earned.

Payroll costs incurred but not paid during the Borrower’s last pay period of the Covered Period are eligible for forgiveness if paid on or before the next regular payroll date. Otherwise, payroll costs must be paid during the Covered Period. 

You must submit bank statement(s) showing a cash withdrawal that corresponds with each payroll date and amount. For example, the bank statement shows a $10,000 withdrawal on June 5 and you are requesting Forgiveness for $10,000 for its regularly scheduled payday on June 12.

You also must provide details about employee pay, such as a payroll summary sheet that shows each employee during each payroll period and then a total for the entire Covered Period.

The total annual amount of cash compensation eligible for Forgiveness may not exceed $100,000 per employee for all SBA Forms. 

• For example, if you’re using an 8-week Covered Period, you can receive Forgiveness for no more than $15,385 per employee. If you’re using an 24-week Covered Period, you can receive Forgiveness for no more than $46,154 per employee.

If you’re not using a full 24-week Covered Period, you must pro-rate compensation.

Additional guidance applies for certain groups:

• For C-corporation owner-employees, Forgiveness is capped by the prorated amount of their 2019 or 2020 employee cash compensation and employer retirement and health, life, disability, vision and dental insurance contributions made on their behalf.
• For S-corporation owner-employees, Forgiveness is capped by the prorated amount of their 2019 or 2020 employee cash compensation and employer retirement contributions made on their behalf. However, employer health, life, disability, vision and dental insurance contributions made on their behalf cannot be separately added; those payments are already included in their employee cash compensation.
• For owner-employee or self-employed individuals, Forgiveness is capped at 2.5 months’ worth of an owner employee or self-employed individual’s 2019 or 2020 compensation (up to a maximum of $20,833 per individual in total across all businesses).
• For Schedule C or F filers, Forgiveness is  capped by the prorated amount of their owner compensation replacement, calculated based on 2019 or 2020 net profit.
• For General partners, Forgiveness is capped by the prorated amount of their 2019 or 2020 net earnings from self-employment (reduced by claimed section 179 expense deduction, unreimbursed partnership expenses, and depletion from oil and gas properties) multiplied by 0.9235.
  • For self-employed individuals, including Schedule C or F filers and general partners, retirement and health, life, disability, vision or dental insurance contributions are included in their net self-employment income and therefore cannot be separately added to their payroll calculation.
• LLC members are subject to the rules based on their LLC’s tax filing status in the reference year used to determine their loan amount.

According to the SBA’s Instructions for PPP Schedule A, the following payroll costs are eligible for Forgiveness if paid or incurred during the Covered Period: 

• Employer contributions for employee health life, disability, vision, and dental insurance including employer contributions to a self-insured, employer-sponsored group health plans
• Employer contributions to employee retirement plans, including pension plans
• Employer state and local taxes assessed on employee compensation (e.g., state unemployment insurance tax)

The following are not eligible for Forgiveness: 

• Employee contributions -- either pre-tax or after-tax -- to health insurance and/or retirement plans
• Employer contributions made on behalf of a self-employed individual, general partners, or owner-employees of an S-corporation, because such payments are already included in their compensation
• Any taxes withheld from employee earnings

The SBA states the below categories are eligible if service began before February 15, 2020:

• phone
• internet 
• gas
• water
• electricity
• transportation

Please visit SBA.gov/PPP or Treasury.gov for any updates.

If you use Form 3508S for a first-draw PPP loan, you’re not required to upload documentation, but you  should retain for your records documents that substantiate your eligibility for the loan amount of Forgiveness requested.

If you use Form 3508S for a second-draw PPP loan of $150,000 or less, you are required to submit documentation supporting the gross receipts reduction certification on your PPP loan application. 

You should submit all documents showing you’ve met FTE, payroll and/or non-payroll guidelines for the full amount that you’re requesting Forgiveness. This means you may need to submit documents for multiple reporting periods. For example, to show payroll costs across multiple quarters, you may need to submit 2 or 3 quarterly filings of IRS Form 941s, state quarterly business and individual employee wage reports, or unemployment insurance tax filings.

If you work with a payroll provider, you may want to request a specialized, consolidated report for such instances.

You must submit additional documents to show the connection between that name and the legal name of your business. 

Yes, you must upload them with your supporting payroll cash-compensation documents.  

No. You must request Forgiveness through the JPMorgan Chase online portal.

Yes. There is no prepayment penalty.

No, under amendments made to the CARES Act, your Economic Injury Disaster Loan (EIDL) Advance will not impact your Paycheck Protection Program (PPP) Forgiveness request amount.

Yes. Please keep in mind you may be subject to reductions in eligible Forgiveness amounts. 

The selected time period must be the same time period selected for purposes of completing PPP Schedule A, line 11.

• The average number of FTE employees on payroll per week you employed between February 15, 2019 and June 30, 2019;
• The average number of FTE employees on payroll per week you employed between January 1, 2020 and February 29, 2020; or
• In the case of a seasonal employer, the average number of FTE employees on payroll for any consecutive 12-week period between February 15, 2019 and February 15, 2020

Documents may include payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941) and state quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported. Documents submitted may demonstrate FTE for longer than the Covered Period.

If your loan is less than $50,000: No, however, this would not apply if you and your affiliates received PPP loans totaling $2 million or more

If your loan is between $50,000 and $150,000 : Yes, you need to calculate if you had a reduction in full-time equivalency employees or annual salary or hourly wages for any employee during the Covered Period that was more than 25% compared to your chosen reference period.

The 3508S is generally designed for you to request Forgiveness without providing supporting documentation for payroll costs, and FTE. However, you must retain all employment records/payroll documentation in its files for four years and all other documentation for three years after the date the loan forgiveness application is submitted to the lender, and permit authorized representatives of SBA, including representatives of its Office of Inspector General, to access such files upon request.

If your loan is more than $50,000, or if you and your affiliates received PPP loans totaling $2 million or more, your Forgiveness amount may be reduced if your average weekly FTE employees during your Covered Period was less than during your chosen reference period and subject to other qualifications.

You may be exempt from such a reduction if either of the FTE Reduction Safe Harbors applies. See the FTE Reduction Safe Harbor instructions available on page 11 of SBA Form 3508.

Yes, if using the full Form 3508 or 3508EZ, you may be exempt from any loan forgiveness reduction if you meet either Safe Harbor 1 or 2: 

FTE Reduction Safe Harbor 1: In good faith, you are able to document that you were unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020 and December 31, 2020 (or, for a PPP loan made after December 27, 2020, requirements established or guidance issued between March 1, 2020 and the last day of the Covered Period), by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards for sanitation, social distancing, or any other worker or customer safety requirement related to COVID-19.

FTE Reduction Safe Harbor 2:

• You reduced your FTE employee levels in the period beginning February 15, 2020, and ending April 26, 2020; AND
• You then restored your FTE employee levels to those in your pay period that included February 15, 2020 by not later than (i) December 31, 2020, for a PPP loan made before December 27, 2020, or (ii) the last day of the Covered Period, for a PPP loan made after December 27, 2020. 

Yes, you are generally eligible for any payroll costs paid or incurred during the Covered Period should be eligible for Forgiveness.  

JPMorgan Chase cannot provide any guidance on this question.

The SBA, in its discretion, may undertake a review at any time including after Forgiveness has been approved.  The Borrower must retain all employment records/payroll documentation in its files for four years and all other documentation for three years after the date the loan forgiveness application is submitted to the lender, and permit authorized representatives of SBA, including representatives of its Office of Inspector General, to access such files upon request.

We’ll allow only one authorized representative who will be required to attest to certain representations on behalf of the Borrower.  It does not have to be the same person who applied for the loan.

You have until your current loan maturity date to request Forgiveness, but your payments will begin after your deferral period ends. If you do not file for forgiveness, your deferral period will end  10 months after the last day of the maximum covered period of 24 weeks. Your covered period begins  on the day that we disbursed your PPP loan proceeds.

No, the  expiration date listed on all three forms does not affect when you will be able to request Forgiveness.  

You should have plenty of time to request Forgiveness once we start accepting Forgiveness requests again in March. If you submit a Forgiveness request within 10 months after the end of the 24-week covered period, you don’t have to make a payment until after the SBA remits a forgiveness payment, if any, or decides that you are not eligible for forgiveness. 

Yes, you may be eligible for Forgiveness on the portion of the loan used on eligible expenses during the Covered Period.

No. Businesses that received a PPP loan need to request Forgiveness through the bank that processed their loan. 

You will need to provide your Funded PPP Loan Amount, PPP Loan Disbursement Date, and 9-digit Business Tax Identification number (TIN) to access the online portal. Please contact your banker should you have any questions. 

Once in the portal, we will pre-fill your standard business information, as well as SBA PPP Loan Number, JPMorgan Chase PPP Loan Number, and NAICS Code.

You can use Form 3508S if you:

• Received a PPP loan of $150,000 or less

You may be able to use Form 3508EZ if you have a loan greater than $150,000 and meet at least one of the 2 criteria below:

• Did not reduce by more than 25% the salaries or wages of your employees earning $100,000 or less and did not reduce the number of employees or hours of your employees OR –
• Did not reduce by more than 25% the salaries or wages of your employees earning $100,000 or less and did experience reductions in business activity as a result of health directives related to COVID-19. Business activity reductions could have resulted directly or indirectly from compliance with COVID Requirements or Guidance from federal, state or local government shutdown orders that prohibited you from maintaining the same Full Time Equivalency (FTE) employee levels.

Otherwise, you may have to use Form 3508. 

No. You must submit a separate Forgiveness request for each PPP loan you have. For a second PPP loan in excess of $150,000, you must submit a Loan Forgiveness request for your first loan before or at the same time as your Loan Forgiveness request for your second loan even if the first Loan Forgiveness request is $0.

Interest began to accrue the day you received your PPP funds. If the SBA forgives any part of your loan, it will forgive the associated accrued interest, too.

Yes, regardless of which Form you use. You’ll need to fill out tables 1 and 2 of the worksheet to help calculate your payroll costs, but you should not upload the worksheet.

• All PPP borrowers, individually or together with their affiliates, that received PPP loans with an original principal amount of $2 million or greater will need to complete an SBA Form 3509 or 3510 Loan Necessity Questionnaire once the SBA notifies us that your loan is under review.
• Some PPP borrowers with loan amounts of less than $2 million, when required by the SBA, may also need to complete a Loan Necessity Questionnaire.

We will email you if the SBA notifies us that your loan is under review and requests additional documentation and completion of  the Loan Necessity Questionnaire, if applicable. Upon our request, you should return the completed Questionnaire to us within 10 business days of receipt of our email.

See FAQ 53 for more information.  You may want to contact your accountant, attorney or other trusted advisors to assist in completion.

PPP borrowers that have a 20% or more ownership interest (by vote or value) that held or holds the office of (i) President of the United States, (ii) Vice President of the United States, (iii) head of an Executive Department, (iv) member of the United States Congress, or spouse of any of the referenced offices at the time Borrower’s loan application was submitted to the PPP lender must complete and submit the 3508D to their lender within 30 days after submitting their Forgiveness application.  Impacted borrowers that submitted Forgiveness applications before December 27, 2020 must complete and submit to their  lender by January 26, 2021.  Executive Department means the respective Secretary of State, Treasury, Defense, Justice, Interior, Agriculture, Commerce, Labor, Health and Human Services, Housing and Urban Development, Transportation, Energy, Education, Veterans Affairs, Homeland Security.

See PPP Interim Final Rule - Loan Forgiveness Requirements and Loan Review Procedures as Amended by Economic Aid Act for more information.  You may want to contact your accountant, attorney or other trusted advisors to determine whether this is applicable to you.  If applicable, please send the completed 3508D to your banker.

We'll send you an email when 1) we've sent your request to the SBA and 2) when the SBA has made a decision. After you submit a complete request to us, it may take up to 60 days to review.

Once we  send your request to the SBA, it may take up to an additional 90 days for the SBA to review and authorize. Actual times will vary and timelines may be affected for a number of reasons, including if the SBA has additional questions or requests a loan review. 

You may be forgiven for all, some or none of your loan. You must repay the principal and accrued interest amount of the unforgiven portion of your loan. 

Yes, you may have the right to appeal. Please see  SBA Procedural Notice 5000-20077  and Interim Final Rule on Appeals of SBA Loan Review Decisions to understand the bases of claims. 

You will have a  monthly fixed payment over the remaining term of your loan.  

For loans made before June 5, 2020, the maturity is two years from the original funding date.  For loans funded on or after June 5, 2020, the maturity is five years from the original funding date.

Yes. You will have the opportunity to extend your current 2-year loan term to 5 years from the date of Loan Disbursement if the Small Business Administration (SBA) has remitted partial Forgiveness payment.

You’ll receive an email from JPMorgan Chase notifying you of your option for a maturity date extension and, if you elect, you will be provided a DocuSign link to electronically sign a new note.

No, the CARES Act as amended confirms the lender is only responsible for paying fees when a lender directly contracts with the agent.

Loan Forgiveness for the Paycheck Protection Program

We continue to invite clients with a PPP loan to request Forgiveness, generally starting with those who received funding first.

We’re working to get the simpler Form 3508S into our Forgiveness request process because it may help those of you with loans of $50,000 or less, though it’s still some weeks away. As a reminder, Form 3508S requires fewer calculations, and borrowers who qualify to use this form are exempt from reductions in loan Forgiveness amounts based on reductions in FTE employees or salary/hourly wages. If you have a loan that is $50,000 or less, you can wait for us to incorporate the 3508S requirements or use Form 3508EZ or 3508 once you receive your email invitation.

To prepare any Forgiveness request, we encourage you to review our helpful resources below.

Continue to check this page for updates and visit SBA.gov and Treasury.gov for full program details.

SBA PPP - LOAN FORGIVENESS FAQS

Guidance for questions concerning requesting Forgiveness from the SBA Paycheck Protection Program

Please visit SBA.gov or Treasury.gov for any updates.

We continue to invite clients with a PPP loan to request Forgiveness, generally starting with those who received funding first.

We’re working to get the simpler Form 3508S into our Forgiveness request process because it may help those of you with loans of $50,000 or less, though it’s still some weeks away. As a reminder, Form 3508S requires fewer calculations, and borrowers who qualify to use this form are exempt from reductions in loan Forgiveness amounts based on reductions in FTE employees or salary/hourly wages. If you have a loan that is $50,000 or less, you can wait for us to incorporate the 3508S requirements or use Form 3508EZ or 3508 once you receive your email invitation.

To prepare any Forgiveness request, we encourage you to review our helpful resources below.

Continue to check this page for updates and visit SBA.gov and Treasury.gov for full program details.

On October 8 2020, the Small Business Administration (SBA) released the simpler Form 3508S for borrowers who received a PPP Loan of $50,000 or less.  Borrowers who qualify may make fewer calculations and be exempt from reductions in loan Forgiveness amounts based on reductions in Full-time Equivalent (FTE) employees or salary or hourly wages.

If you have a loan that is $50,000 or less, you can wait for us to incorporate the 3508S requirements, likely early in the new year, or use Form 3508EZ or 3508 once you receive your email invitation. In either case, we recommend you complete the Forgiveness checklist now.

Note that if you and your affiliates have PPP loans totaling $2 million or more, you cannot use Form 3508S

If you want to request Forgiveness before the Form 3508S is incorporated, you must decide whether to use Form 3508EZ or 3508.

You can request Forgiveness with SBA Form 3508S if you meet these two criteria below:

• Received a PPP loan of $50,000 or less, AND
• Together with your affiliates, didn’t receive PPP loans totaling $2 million or more.

You can request Forgiveness with SBA Form 3508EZ if you meet at least one of the three criteria below:

You can request Forgiveness with Form 3508 if you do not qualify to file either the SBA Form 3508EZ or 3508S.

• Here are additional updates from the SBA that apply to both PPP Loan Forgiveness Application Forms:  
  • You now have a 24-week Covered Period to spend loan funds starting the date loan funds were deposited into your account. If you were funded prior to June 5, you can still use the 8-week period and Alternative Payroll Covered Period.
  • You must use at least 60% of funds for eligible payroll costs to qualify for full Loan Forgiveness.
  • You can use up to 40% of funds for eligible non-payroll costs.
  • Payments are generally deferred until 10 months after your 8-week or 24-week Covered Period ends.
    • If you apply for Forgiveness in the deferral period, you won’t have to start making payments on unforgiven amounts until the SBA provides a decision on your request or remits funds.
    • If you do not apply for Forgiveness within the deferral period, you must begin making payments after your deferral period.

Before you request Loan Forgiveness, we recommend you do the following: 

Document your eligible payroll and non-payroll costs

• Your documentation should cover your payroll and non-payroll costs incurred or paid during your Covered Period or your Alternative Payroll Covered Period.

Below are the document types you may need to retain or submit when requesting Forgiveness through JPMorgan Chase. The documents required may differ depending on if you are using Form 3508EZ or 3508. For a complete list of documentation required, please see the Loan Forgiveness Application Instructions for Borrowers for Form 3508EZ and 3508.

We’ll email you when you can request Loan Forgiveness through JPMorgan Chase.  Please keep in mind:

• Forgiveness is not automatic, you must request it through JPMorgan Chase.
• For Chase Connect users, you will be able to sign into the forgiveness portal using your Chase Connect account. For non-Chase Connect users, you will be able to register for a forgiveness account in the portal.
• You should request Forgiveness only after you have spent all the funds that are eligible for Forgiveness.  
• We will pre-fill your standard business information on your Forgiveness request as well as:
  • SBA PPP Loan Number
  • JPMorgan Chase PPP Loan Number
  • PPP Loan Disbursement Date
•  You will need to certify and document that you used the loan funds for SBA-eligible purposes.
• You’ll be able to check your Forgiveness status online after you submit your request.
• Once the SBA makes a decision, we’ll email you.

It is your obligation, as the borrower, to understand the SBA's rules. Other eligibility requirements may apply.

We aren’t accepting new PPP Forgiveness requests or resubmissions right now while we make updates based on new guidance from the Small Business Administration (SBA). This should make it much easier for many borrowers with loans of $150,000 or less. Also, all borrowers may be able to include additional eligible non-payroll expense types to reach full forgiveness.

If you have submitted a Forgiveness request that does not require additional information, we will continue to process and submit your request to the SBA.

For all other clients including those with requests that require additional information, you will be asked to submit a new request when we start to accept Forgiveness requests. 

You can apply for a second PPP loan with us whether or not your first loan has been forgiven.

We’ll email you once we begin accepting Forgiveness requests again. You’ll have time to request Forgiveness before you need to start making payments.

Continue to check this page for updates and visit SBA.gov and Treasury.gov for full program details.

Guidance for questions concerning requesting Forgiveness from the SBA Paycheck Protection Program

1. What to Document
2. What to Prepare
   1.  Loan Forgiveness and Your Employees
      
   2. Loan Forgiveness and Change of Ownership
3. Requesting Loan Forgiveness
4. What to Expect After Requesting Forgiveness

Please visit SBA.gov or Treasury.gov for any updates.

What to Document

What to Prepare

Loan Forgiveness and Your Employees

Loan Forgiveness and Change of Ownership

Requesting Loan Forgiveness

What to Expect After Requesting Forgiveness

We're now allowing all clients with a 2020 PPP Loan through JPMorgan Chase to request Forgiveness.

We plan to start accepting Forgiveness requests for 2021 PPP loans in late Spring.

Please remember you have time to request Forgiveness.

Get ready by reviewing and acting on the helpful resources on this page.

Continue to check this page for updates and visit SBA.gov/ppp and Treasury.gov for full program details.

All borrowers:

• Must have an authorized representative who can borrow on behalf of the business.
• Must have an active JPMorgan Chase DDA / checking account
• Must have been in business as of February 15, 2020 and your business hasn’t been permanently closed
• If applying as a franchise, you will need to enter the SBA Franchise Identifier Code at the time of application. You can find that code at sba.gov/sba-franchise-directory.  If your franchise isn’t on the directory, please contact your local SBA District Office to help you get it added.
• You should review the requirements and guidance provided by the SBA for complete information regarding the PPP. The SBA continues to release updated guidance.  For the most updated  PPP rules, requirements and other information, visit SBA.gov and Treasury.gov. You may also want to contact your accountant, attorney or other trusted advisors.

First-time borrowers (including affiliates) in general:

• Generally, can have no more than 500 employees (or fewer for certain business types or more based on SBA size standards)
  • Accommodations and Food Services companies with NAICS code 72 can have no more than 500 employees per physical location.
• Can apply for a loan up to 2.5 times the business’ average monthly payroll costs, up to a $10 million loan maximum (and $20 million for a corporate group) 

Second-time borrowers (including affiliates) in general:

• Generally, can have no more than 300 employees.
  • Accommodations and Food Services companies with NAICS code 72 and certain news organizations can have no more than 300 employees per physical location.

• Can apply for a loan up to 2.5 times the business’ average monthly payroll costs, up to a $2 million loan maximum (and $4 million for a corporate group).
  • Accommodations and Food Services companies with NAICS code 72 can borrow up to 3.5 times the business’ average monthly payroll costs, up to a $2 million loan maximum. 
• Must have experienced a revenue reduction of 25% or greater in 2020 relative to 2019.  In general, a borrower may calculate this revenue reduction by comparing quarterly gross receipts for one quarter in 2020 with the gross receipts for the same quarter in 2019.  A business that does not file quarterly or was not in operation for all four quarters of 2019 may still qualify; see the SBA guidelines for details.
• Used or will use the full amount of the first PPP loan for authorized purposes on or before the expected date of disbursement of the second PPP Loan

All borrowers must submit:

• Payroll statement or similar documentation showing business operations as of February 15, 2020
• Evidence of payroll costs for 2019 or 2020 (whichever you used to calculate your PPP loan amount).
  • Review the SBA guidelines on documentation for first-time borrowers and second-time borrowers

If you file IRS Form 1040 Schedule C or 1040 Schedule F:

You must upload all of the following:

• 2019 or 2020* (whichever you used to calculate loan amount) Form 1040 Schedule C or Form 1040 Schedule F
  • If you file IRS Form 1040 Schedule F, you must also upload IRS Form 1040 Schedule 1
  • If you are using 2020 information to calculate your loan amount, you may submit a draft of your IRS Form 1040 Schedule C or 1040 Schedule F to support your loan request. 

Have no employees:

• 2019 or 2020* (whichever you used to calculate loan amount) IRS Form 1099-MISC detailing nonemployee compensation received (box 7), IRS Form 1099-K, invoice, bank statement or book of record that establishes you are self-employed.
• A 2020 invoice, bank statement or book of record to establish you were in operation on or around February 15, 2020.

Have employees:

• 2019 or 2020* (whichever you used to calculate loan amount) documentation related to gross wages and tips paid to your employees, which may include :
  • Form 941 (or other tax forms or equivalent payroll processor records containing similar information) and state quarterly wage unemployment insurance tax reporting forms from each quarter in 2019 or 2020* (whichever you used to calculate loan amount); or
  • equivalent payroll processor records or IRS Wage and Tax Statements.

• Documentation of any retirement or group health, life, disability, vision, and dental insurance contributions
• If are a farmer or rancher, IRS Form 943 should be provided in addition to, or in place of, IRS Form 941, as applicable.
• A payroll statement or similar documentation from the pay period that covered February 15, 2020 must be provided to establish you were in operation on February 15, 2020.

If you file IRS Form 1065 (Partnership):

You must upload all of the following:

• 2019 or 2020* (whichever you used to calculate loan amount) IRS Form 1065 (including K-1s) 
• If the partnership has employees:
  • 2019 or 2020* (whichever you used to calculate loan amount) documentation related to gross wages and tips paid to your employees, which may include:
    • IRS Form 941 and state quarterly wage unemployment insurance tax reporting form from each quarter in 2019 or 2020 (whichever you used to calculate loan amount); or
    • equivalent payroll processor records or IRS Wage and Tax Statements.
  • Records of any retirement or group health, life, disability, vision, and dental insurance contributions.
  • A payroll statement or similar documentation from the pay period that covered February 15, 2020 must be provided to establish the partnership was in operation and had employees on that date.
• If the partnership has no employees, an invoice, bank statement or book of record establishing the partnership was in operation on February 15, 2020 must instead be provided.

If you file IRS Form 1120-S (S-Corp) or Form 1120 (C-Corp)

You must upload all of the following:

• 2019 or 2020* (whichever you used to calculate loan amount) documentation related to gross wages and tips paid to your employees, which may include:
  • IRS Form 941 and state quarterly wage unemployment insurance tax reporting form from each quarter; or 
  • equivalent payroll processor records or IRS Wage and Tax Statements.
• 2019 or 2020* (whichever you used to calculate loan amount) IRS Form 1120, IRS 1120-S or other documentation of any retirement and group health, life, disability, vision and dental insurance contributions
• A payroll statement or similar documentation from the pay period that covered February 15, 2020 to establish you were in operation and had employees on that date.

If you file IRS Form 990 (Non-profit):

You must upload all of the following:

• 2019 or 2020 (whichever you used to calculate loan amount) documentation related to gross wages and tips paid to your employees, which may include:
  • IRS Form 941 and state quarterly wage unemployment insurance tax reporting form from each quarter; or 
  • equivalent payroll processor records or IRS Wage and Tax Statements.
• 2019 or 2020* (whichever you used to calculate loan amount) IRS Form 990 Part IX or other documentation of group health, life, disability, vision, and dental insurance  contributions.
• 2020 Q1 IRS Form-941, a payroll statement or similar documentation from the pay period that covered February 15, 2020 to establish you were in operation and had employees on that date.

*If using 2020 to calculate loan amount, this is required regardless of whether you have filed a 2020 tax return with the IRS.

First-time borrowers only:

• If you received an EIDL loan between January 31, 2020 and April 3, 2020, have the following information about the EIDL loan available:
  • Date loan received
  • Loan number
  • Principal amount
  • Outstanding principal balance of the EIDL loan as of the date of the PPP application 
  • Amount of any separate EIDL advance received

Second-time borrowers only:

• Documentation that shows the business experienced a revenue reduction of 25% or greater in 2020 relative to 2019. 
  • For loans $150,000 or less: It is not necessary for you to provide documentation regarding decline in gross receipts at the time you submit your application, however such documentation will be required at the time of seeking loan forgiveness or upon SBA request. 
  • For loans greater than $150,000
    • You may substantiate your certification of a 25% gross receipts reduction by providing one of the following:
      • Audited quarterly financial statements for the entity;
      • Unaudited quarterly financial statements that have been signed and dated in accordance with SBA guidance;
      • Quarterly or monthly bank statements for the entity showing deposits from the relevant quarters, annotated as necessary in accordance with SBA guidance; or
      • Annual IRS income tax filings of the entity (which is required if you are using an annual reference period); 

NOTE: Reference question 4 of recent SBA guidance for details on how to sign and annotate the above-referenced documentation before submitting.

• Per SBA guidelines, gross receipts should include affiliates.  If this applies to you, provide the total combined gross receipts and details for affiliates included.

Disclaimer: This material is for general informational purposes only and may not apply to all borrowers. You should review the requirements and guidance provided by the SBA for complete information regarding PPP. The SBA continues to release updated guidance: visit SBA.gov and Treasury.gov.

47. Question: An SBA interim final rule posted on May 8, 2020 provided that any borrower who applied for a PPP loan and repays the loan in full by May 14, 2020 will be deemed by SBA to have made the required certification concerning the necessity of the loan request in good faith. Is it possible for a borrower to obtain an extension of the May 14, 2020 repayment date?

Answer: Yes, SBA is extending the repayment date for this safe harbor to May 18, 2020, to give borrowers an opportunity to review and consider FAQ #46. Borrowers do not need to apply for this extension. This extension will be promptly implemented through a revision to the SBA’s interim final rule providing the safe harbor.

46. Question: How will SBA review borrowers’ required good-faith certification concerning the necessity of their loan request?

Answer: When submitting a PPP application, all borrowers must certify in good faith that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” SBA, in consultation with the Department of the Treasury, has determined that the following safe harbor will apply to SBA’s review of PPP loans with respect to this issue: Any borrower that, together with its affiliates20, received PPP loans with an original principal amount of less than $2 million will be deemed to have made the required certification concerning the necessity of the loan request in good faith.

SBA has determined that this safe harbor is appropriate because borrowers with loans below this threshold are generally less likely to have had access to adequate sources of liquidity in the current economic environment than borrowers that obtained larger loans. This safe harbor will also promote economic certainty as PPP borrowers with more limited resources endeavor to retain and rehire employees. In addition, given the large volume of PPP loans, this approach will enable SBA to conserve its finite audit resources and focus its reviews on larger loans, where the compliance effort may yield higher returns.

Importantly, borrowers with loans greater than $2 million that do not satisfy this safe harbor may still have an adequate basis for making the required good-faith certification, based on their individual circumstances in light of the language of the certification and SBA guidance. SBA has previously stated that all PPP loans in excess of $2 million, and other PPP loans as appropriate, will be subject to review by SBA for compliance with program requirements set forth in the PPP Interim Final Rules and in the Borrower Application Form. If SBA determines in the course of its review that a borrower lacked an adequate basis for the required certification concerning the necessity of the loan request, SBA will seek repayment of the outstanding PPP loan balance and will inform the lender that the borrower is not eligible for loan forgiveness. If the borrower repays the loan after receiving notification from SBA, SBA will not pursue administrative enforcement or referrals to other agencies based on its determination with respect to the certification concerning necessity of the loan request. SBA’s determination concerning the certification regarding the necessity of the loan request will not affect SBA’s loan guarantee.

20 For purposes of this safe harbor, a borrower must include its affiliates to the extent required under the interim final rule on affiliates, 85 FR 20817 (April 15, 2020).

43. Question: FAQ #31 reminded borrowers to review carefully the required certification on the Borrower Application Form that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant.” SBA guidance and regulations provide that any borrower who applied for a PPP loan prior to April 24, 2020, and repays the loan in full by May 7, 2020, will be deemed by SBA to have made the required certification in good faith. Is it possible for a borrower to obtain an extension of the May 7, 2020 repayment date?

Answer: SBA is extending the repayment date for this safe harbor to May 14, 2020. Borrowers do not need to apply for this extension. This extension will be promptly implemented through a revision to the SBA’s interim final rule providing the safe harbor. SBA intends to provide additional guidance on how it will review the certification prior to May 14, 2020.

Please remember that you also certified you understood that knowingly making a false statement to obtain a guaranteed loan from SBA is punishable under the law, including under 18 USC 1001 and 3571 by imprisonment of not more than five years and/or a fine of up to $250,000; under 15 USC 645 by imprisonment of not more than two years and/or a fine of not more than $5,000; and, if submitted to a federally insured institution, under 18 USC 1014 by imprisonment of not more than thirty years and/or a fine of not more than $1,000,000.   

The Treasury, SBA and the media have been focused on PPP loans and issues around borrower eligibility. 

Throughout this process, we have relied on your certifications regarding eligibility. Federal agencies, legislators and media have been focused on PPP loans, including borrower eligibility.  If you do not currently believe that your business is eligible for PPP funding (even if you’ve previously certified as to eligibility on your PPP loan application), you should consider taking action now. Please note that we anticipate that when applying for PPP loan forgiveness, borrowers will be required to make the same or similar certifications as to eligibility as those made during the application process.

If you have received PPP funding and now feel you may not be eligible: The Treasury and SBA have indicated that your prior certification as to eligibility will be deemed to have been made in good faith if you repay your PPP loan in full by May 14, 2020. To arrange for repayment by the May 14th deadline, please contact your banker no later than May 11th.

31. Question: Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?

Answer: In addition to reviewing applicable affiliation rules to determine eligibility, all borrowers must assess their economic need for a PPP loan under the standard established by the CARES Act and the PPP regulations at the time of the loan application. Although the CARES Act suspends the ordinary requirement that borrowers must be unable to obtain credit elsewhere (as defined in section 3(h) of the Small Business Act), borrowers still must certify in good faith that their PPP loan request is necessary. Specifically, before submitting a PPP application, all borrowers should review carefully the required certification that “current economic uncertainty makes this loan request necessary to support the ongoing operations of the applicant.” Borrowers must make this certification in good faith, taking into account their current business activity and their ability to access other sources of liquidity sufficient to support their ongoing operations in a manner that is not significantly detrimental to the business. For example, it is unlikely that a public company with substantial market value and access to capital markets will be able to make the required certification in good faith, and such a company should be prepared to demonstrate to SBA, upon request, the basis for its certification. 

Lenders may rely on a borrower’s certification regarding the necessity of the loan request. Any borrower that applied for a PPP loan prior to the issuance of this guidance and repays the loan in full by May 7, 2020, will be deemed by SBA to have made the required certification in good faith.

The Emergency Rental Assistance appropriates $25 billion through the Treasury to states, US Territories, tribes, and large cities (“grantees”) to provide financial assistance and housing stability services to eligible rental households.

The National Low Income Housing Coalition created a guide that contains state and city resources for COVID-19 pandemic hardship rental housing assistance. This resource may be helpful should your tenants need to seek assistance. In referencing the National Low Income Housing Coalition guide, understand that we do not provide any assurance regarding eligibility. Information contained in the guide is subject to change, so you should check back regularly for updates. Other resources may be available.

_{The information in this content is not advice on legal, tax, investment, accounting, regulatory or other matters. You should consult your own financial, legal, tax, accounting, or similar advisors. Further, additional resources may exist. Nothing contained herein shall change or modify the provisions of your loan with JPMorgan Chase or any other financial product and service you may have.}

• Eligible Households: To be eligible, a household must be obligated to pay rent on a residential dwelling and (i) have one or more household members who qualify for unemployment benefits or experienced financial hardship due to the pandemic, (ii) have one or more household members who can demonstrate a risk of experiencing homelessness or housing instability (e.g., past due utility/rent notice or eviction notice), and (iii) the household’s income is not more than 80% of the area median income (p. 2278-79). Landlords and property owners may apply on behalf of their tenants but must notify the tenant and obtain their consent (p. 2270-71).
• Prioritization of Emergency Rental Assistance: Grantees must prioritize eligible applicant households with (i) household incomes of 50% or less of the area median income and/or (ii) one or more household members who have been unemployed for 90 days or more (p. 2267-68)
• Use of Emergency Rental Assistance Funds: 90% of funds received by the grantees must be used to provide financial assistance to eligible households (e.g., payment of rent, rental arears, utilities/home energy costs, and other housing related expenses incurred due to COVID-19) (p. 2264). Assistance shall be provided for a maximum of 12 months, except that a grantee may provide assistance for an additional 3 months of prospective rent if necessary, to ensure housing stability (subject to availability of funds) (p. 2264) The remaining 10% may be used for housing stability services, including case management, (p. 2267) or administrative costs (e.g., data collection and reporting requirements) (p. 2268). Unused funds will be recaptured by the Treasury on September 30, 2021 to be reallocated among other grantees. Funds remain available through December 31, 2021 (p. 2270).
• Eviction Moratorium: (Sec. 502) extends the CDC eviction moratorium until January 31, 2021 (p. 2281).

The Emergency Rental Assistance appropriates $25 billion through the Treasury to states, US Territories, tribes, and large cities (“grantees”) to provide financial assistance and housing stability services to eligible rental households.

The National Low Income Housing Coalition created a guide that contains state and city resources for COVID-19 pandemic hardship rental housing assistance. This resource may be helpful should your tenants need to seek assistance. In referencing the National Low Income Housing Coalition guide, understand that we do not provide any assurance regarding eligibility. Information contained in the guide is subject to change, so you should check back regularly for updates. Other resources may be available.

_{The information in this content is not advice on legal, tax, investment, accounting, regulatory or other matters. You should consult your own financial, legal, tax, accounting, or similar advisors. Further, additional resources may exist. Nothing contained herein shall change or modify the provisions of your loan with JPMorgan Chase or any other financial product and service you may have.}

• Eligible Households: To be eligible, a household must be obligated to pay rent on a residential dwelling and (i) have one or more household members who qualify for unemployment benefits or experienced financial hardship due to the pandemic, (ii) have one or more household members who can demonstrate a risk of experiencing homelessness or housing instability (e.g., past due utility/rent notice or eviction notice), and (iii) the household’s income is not more than 80% of the area median income. Landlords and property owners may apply on behalf of their tenants but must notify the tenant and obtain their consent.
• Prioritization of Emergency Rental Assistance: Grantees must prioritize eligible applicant households with (i) household incomes of 50% or less of the area median income and/or (ii) one or more household members who have been unemployed for 90 days or more.
• Use of Emergency Rental Assistance Funds: 90% of funds received by the grantees must be used to provide financial assistance to eligible households (e.g., payment of rent, rental arears, utilities/home energy costs, and other housing related expenses incurred due to COVID-19). Assistance shall be provided for a maximum of 12 months, except that a grantee may provide assistance for an additional 3 months of prospective rent if necessary, to ensure housing stability (subject to availability of funds). The remaining 10% may be used for housing stability services, including case management, or administrative costs (e.g., data collection and reporting requirements). Unused funds will be recaptured by the Treasury on September 30, 2021 to be reallocated among other grantees. Funds remain available through December 31, 2021.
• Eviction Moratorium: The Center for Disease Control’s federal eviction moratorium extends through March 31, 2021.