BankBCLP Frequently Asked Questions
- Can Forgivable Payroll Costs Exceed Loan Amount?
- Does Size of the Loan Affect Eligibility for Form 3508EZ?
- Who is Subject to Owner-Employee Compensation Forgiveness Limitations?
- Does a Borrower need its Lender’s Consent to a Change in Control Transaction?
- Is the Buyer Required to Assume the PPP Note in an Asset Sale?
Interim Final Rule and Other Rules
- IFR 1 – Initial IFR with General Guidance on PPP Eligibility (04/02/20)
- IFR 2 – Affiliation Rules for Faith-Based Organizations (04/03/20)
- IFR 3 – Self-Employment Guidance; Partners must File One Application with Partnership; Insider Loans; Gaming Businesses (04/14/20)
- IFR 4 – Extension of Safe Harbor; Hedge Funds / Private Equity Ineligible; Portfolio Companies Subject to Affiliation Rules; ESOPs Do Not Trigger Affiliation Rules; No Limitation on Legal Gambling Revenue for Eligibility (04/24/20)
- IFR 5 – Seasonal Employers (04/27/20)
- IFR 6 – Disbursements of Fees to Banks (04/28/20)
- IFR 7 – Corporate Groups and Non-Bank and Non-Bank Lenders; Limit Aggregate Loans to Affiliated Borrowers to $20 Million (04/30/20)
- IFR 8 – Nondiscrimination; Federal Work Study Students Exempt from Employee Count (05/05/20)
- IFR 9 – Extension of Limited Safe Harbor (05/08/20)
- IFR 10 – Lenders and Borrowers May Request an Increase in PPP Loan Amount Under Two Specific Scenarios: Partnerships and Seasonal Employers (05/13/20)
- IFR 11 – Electric Cooperative Are Eligible PPP Borrowers (05/14/20)
- IFR 12 – Foreign Affiliates Must Be Included for Purposes of Determining Whether a Borrower Has Less than 500 Employees (05/18/20)
- IFR 13 – Extension of Safe Harbor to May 18; Extension of SBA Form 1502 to May 22 (05/20/20)
- IFR 14 – Loan Forgiveness (05/22/20)
- IFR 15 – SBA Loan Review Procedures; Lender & Borrower Responsibilities (05/22/20)
- IFR 16 – Eligibility of Certain Telephone Cooperatives (06/05/20)
- IFR 17 – Revisions to First IFR (06/11/20)
- IFR 18 – Additional Revisions to First IFR (06/12/20)
- IFR 19 – Revisions to the Third and Sixth IFRs (06/17/20)
- IFR 20 – Reflect New 24-week Covered Period and Other PPP Flexibility Act Changes (06/22/20)
- IFR 21 – Additional Eligibility Revisions to First Interim Final Rule (06/24/20)
- IFR 22 – IFR on Certain Eligible Payroll Costs (06/25/20)
- IFR 23 – Appeals of SBA Loan Review Decisions Under the PPP (08/11/20)
- IFR 24 – Treatment of Owners and Forgiveness of Certain Nonpayroll Costs (08/24/20)
- IFR 25 – Additional Revisions to Loan Forgiveness and Loan Review Procedures (10/08/20)
- Applicable Affiliation Rules per SBA/Treasury
- Paycheck Protection Program Flexibility Act of 2020
Small Business Administration Guidance
- SBA Paycheck Protection Program Page
- SBA Forgiveness Portal
- SBA 7(a) Loan Checklist
- SBA SOP 50-10-5 (Lender and Development Company Loan Programs)
- SBA Instructions on Accessing CAFS System
- SBA Guidance on Participating Loans
- SBA Guidance on Whole Loans
- SBA List of Participating Lenders by State
- SBA Prohibition on Robot Processing Automation
- SBA Update on PPP Round 2
- SBA PPP Report Through 8/8/20
- SBA OIG Flash Report
- SBA Form 1502
- SBA Summary of Forgiveness Process
U.S. Department of the Treasury Guidance
- Treasury Paycheck Protection Program Page
- Treasury CARES Act Page
- Treasury PPP Overview
- Treasury Fact Sheet for Borrowers
- Treasury PPP Loan Calculation
- Treasury PPP Forgiveness Application (PDF Fillable)
- Treasury PPP Forgiveness Application Form EZ
- Treasury PPP Simplified Forgiveness Application for Loans $50,000 and Less
- Treasury Press Release on PPP Flexibility Act
- Treasury Guidance on Interplay between EIDL and PPP Applications
- Treasury Press Release on Disclosing PPP Borrowers
- Treasury Procedural Notice on PPP Loans and Changes of Control
Federal Reserve Guidance
Internal Revenue Service Guidance
SEC Guidance
Frequently Asked Questions
- Treasury FAQ
- Treasury Loan Forgiveness FAQ
- FAQ Regarding Participation of Faith-Based Organizations
- FinCEN FAQ
- FDIC FAQ
- IRS Payroll Deferral FAQ
- American Bankers Association FAQ
- Independent Community Bankers Association FAQ
BCLP Guidance
- Tax Effects on the Paycheck Protection Program
- Lender Obligations under the Paycheck Protection Program
- PPP Affiliation Guidelines
- PPP April 14 Interim Final Rule Guidance
- PPP Eligibility Requirements
- Public Company PPP Participants with Liquidity Alternatives Beware
- Administering the Paycheck Protection Program and Managing Litigation & Regulatory Risk in the U.S.
- Analysis of PPP Borrowers: Who Returned Funds?
- SBA Provides Guidance on Changes of Ownership of PPP Borrowers
- SBA Confirms Impact of PPP Flexibility Act on Outstanding Promissory Notes
- Four Things You May Have Missed About the PPP Changes of Ownership Notice
- PPP & Asset Sales: Is the Buyer Required to Assume the PPP Note?
National Trade Associations
- American Bankers Association PPP Resources
- American Institute of CPAs PPP Accounting Resources
- American Institute of CPAs Recommendations on Forgiveness
- American Institute of CPAs Forgiveness Calculator
- Independent Community Bankers Association COVID-19 Resources
- National Association of Government Guaranteed Lenders SBA Resources
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