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PAYCHECK PROTECTION PROGRAM FINAL RULE
On the evening of April 2nd, the SBA released the much-anticipated Interim Final Rule for the Paycheck Protection Program (PPP). The program's details have been the subject of considerable speculation. Now that the Final Rule is established- at least on an interim basis - we can expect a great rush to get applications processed and loans closed. However, after studying the PPP information in detail, we are left with many unanswered questions.
The following are a few of the unresolved issues:
- What is the delivery method for sending applications to the SBA? The usual method of uploading applications and other information to the SBA is through the Capital Access Financial System (CAFS) or E-Tran System. Lenders must be registered and active on these systems in order to communicate with the SBA. The systems required a recertification of users, both the Authorizing Official and Partners (Users) every 2 years. If your certification is not current, it will have to be reestablished. The E-Tran System has been severely overloaded recently, to the frustration of lenders.
Assuming the existing ETRAN System is the upload mechanism, we have heard rumors that a new, second E-Tran System will be available for use in this new loan program (PPP).
- What form of SBA Authorization will be used for the PPP loan program?
- What form of SBA Note will be used for the PPP loan program?
Be assured that we are working diligently to gather answers to these questions and will provide information to you as soon as it is made available.
The following documents are provided for your convenience and further understanding, but please note that the content is subject to change.
SBA PPP Interim Final Rule
SBA Form 2483 – PPP Borrower Application Form
SBA Form 2484 – PPP Lender Application Form: PPP Loan Guaranty
PPP Program Ownership Addendum
PPP SBA Loan - CARES Act Calculation Sheet
(NOTE: Excel workbook downloads to your computer and contains two worksheets: Loan and Forgiveness Worksheet and Financial Data Needed Worksheet)
We appreciate your patience as we continue to keep you advised of current and developing information from the SBA. Please contact Arne Monson, President, or your Account Executive with any questions or needed clarifications.