2021 PPP FAQs

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 commences on the day that we disbursed your PPP loan proceeds

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.

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.

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, but you will only be eligible for partial Forgiveness on that loan. As a reminder, you must request Forgiveness separately for each PPP loan that you may have. For a second PPP loan over $150,000, you must submit a Loan Forgiveness request for your first loan before or simultaneously with a Loan Forgiveness request for your second loan even if the first Loan Forgiveness request is $0.

• 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.

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.

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

Yes. There is no prepayment penalty.

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

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.

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.

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.

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.

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

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.

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.

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 go to SBA.gov/PPP or Treasury.gov for any updates.

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

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 you work with a payroll provider, you may want to request a specialized report that may document a number of Payroll and FTE costs.
• If using 3508S to request Forgiveness on a loan $150,000 or less, you will not need to submit FTE documentation for Forgiveness, but should retain them for your records.

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.

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 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.

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

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.

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.

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.

No, you have until the maturity date of your loan to request Forgiveness.

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.

If the online Forgiveness request displays only the original loan amount — not the increase — in the "PPP loan amount" field, call us at 866-914-8679 when you’re ready to request Forgiveness.

You may be able to file an appeal petition directly with SBA’s Office of Hearings and Appeals within 30 calendar days of receiving the final SBA loan review decision. For details, refer to appeals.sba.gov. The SBA set up the process for PPP borrowers to work directly with it on appeals, so we can’t assist with the appeal.

You must first appeal the decision and then send a copy of the appeal petition to us at sba.ppp.file.review.request@chase.com. Interest will continue to accrue on the loan during any payment deferral period.

Yes. If the SBA chooses to review your PPP loan originated through Chase, they will notify us. In turn, we’ll email you from sba.ppp.file.review.request@chase.com about what additional documentation to submit. You should respond on a timely basis to all requests for additional information. If you have questions about the review, contact the SBA because we can’t give you guidance about how to answer the questions.

• We emailed eligible borrowers to let them know that they can ask the SBA to reconsider their approved PPP Forgiveness amount if it was less than their initial request. This is the result of new SBA guidance. Our email told eligible borrowers that they have 30 calendar days from receiving the email to email us if they want the SBA to review the amount.
• The email provides instructions to borrowers. The SBA hasn’t told us how long it will take to decide whether to review a loan or how long the review process might take.
• If the SBA decides to review the borrower’s Forgiveness amount, we will send the borrower additional instructions. The borrower should be prepared to promptly supply documentation to support both their PPP loan application and Forgiveness request.
• The SBA review may determine that the borrower’s Forgiveness amount should be:
  • The same as originally authorized.
  • More than originally authorized. If so, we’ll adjust the loan balance and payment schedule and return any overpayments to the borrower; or
  • Less than originally authorized, including potentially no Forgiveness if, for example, the SBA determines borrower is ineligible for the loan. We’ll adjust loan balance and payment schedule as needed.
• Borrower must continue to make any scheduled payments throughout this process.

Yes. If the SBA chooses to review your PPP loan originated through Chase, they will notify us. In turn, we’ll email you from sba.ppp.file.review.request@chase.com about what additional documentation to submit. You should respond on a timely basis to all requests for additional information. If you have questions about the review, contact the SBA through your local field office, which can be found: https://www.sba.gov/local-assistance/find