PPP Forgiveness Update June 12, 2020

Time for the weekly PPP update that I know you all look forward to! Our legislative bodies continue to make progress on passing and communicating changes to the forgiveness rules and process. This week saw President Trump sign into law the changes that were discussed in last week’s update. Further clarification has been given regarding some of those changes. Specifically, there are avenues for relief of the “headcount rule” for those companies that have either not recalled all of their previous employees due to lack of business and for those who have tried to recall workers but the workers have refused to return. Additional discussion around these topics will follow, at a later date. The interim rule also clarifies that if a borrower submits an application for forgiveness within 10 months of the end of the forgiveness period, the borrower will not have to make any payment on the loan before the date the SBA remits the forgiven amount to the lender. The rule also confirmed that the last day a lender can obtain approval for a PPP loan is June 30th.

Unfortunately, no ruling has been made yet regarding a de minimis loan level, under which a streamlined process for forgiveness would be applicable. As mentioned in the previous update, every state banking association has issued support for legislation creating this threshold. We in the banking industry remain hopeful that this will be implemented prior to the start of the forgiveness process.

CFB has made some changes to our forgiveness plan. With the period for new loans ending on June 30th, we have decided to begin accepting applications for forgiveness on July 1. Whether your loan was directly processed by CFB or processed through Windsor, we will be working with you to process forgiveness applications. With any luck, legislation will be passed streamlining the process for smaller loans. Regardless, we will be prepared with an accurate and efficient system to assist in applying for loan forgiveness. We also plan to present at least one and possibly more informational conference calls or webinars to assist those with questions. In the interim, we continue to encourage you to collect supporting documents such as payroll records, bank loan statements, rent and utility receipts and any other documentation supporting qualified expenses.

We thank you again for your business and your patience with this continually evolving process. Best wishes to all for a great weekend.

 

With thanks,

Robb Blume

CEO & President

Community First Bank of Indiana