Applying early for PPP loan forgiveness

June 23, 2020

New Paycheck Protection Program (PPP) guidance released Monday, June 22, declares that PPP recipients can apply for loan forgiveness early but doing so could cost them money.

A new interim final rule by the Small Business Administration makes revisions to previous guidance to reflect the Paycheck Protection Program Flexibility Act, which became law on June 5 and made significant changes to the PPP.

The interim final rule says that if a borrower applies for loan forgiveness before the end of the covered period and has reduced any employees’ salaries or wages by more than the 25% allowed for full forgiveness, the borrower must account for the excess salary reduction for the full eight-week or 24-week covered period, whichever one applies to its loan.

Under that guidance, PPP borrowers that apply early for loan forgiveness forfeit a safe-harbor provision allowing them to restore salaries or wages by Dec. 31 and avoid reductions in the loan forgiveness they receive. Learn more.

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