The SBA on Saturday said it is working to ensure the Paycheck Protection Program appropriately accounts for the changes that businesses may have undergone since the beginning of the pandemic.

In a message noting it is receiving many lender questions on the PPP, the SBA said it is working to identify potential program and system updates recognizing changes in entity size, location or staffing, methods of operation, organizational structure, and changes in ownership.

The SBA also said it is working to improve the information provided to lenders about various issues and error messages and how lenders can help clear issues as expeditiously as possible.

The message also includes several reminders, such as:

  • The SBA may review any PPP loan, of any size, at any time, as the agency administrator deems appropriate.
  • If a borrower’s First Draw PPP Loan is under review by SBA, the lender will receive notification from SBA when the lender submits an application for a guaranty of a Second Draw PPP Loan and will not receive an SBA loan number until the issue related to the first-draw loan is resolved.
  • The Borrower’s Disclosure of Certain Controlling Interests Form 3508-D should be completed only by borrowers that received a PPP loan before Dec. 27, 2020, and that were controlled by certain government officials at the time the loan was made. Lenders should follow the instructions on the form for when the borrower should submit the form to the lender and when the lender should submit the form to SBA. For example, borrowers that submitted forgiveness applications to lenders before Dec. 27 should submit the form to their lender by tomorrow, Jan. 26. Timing for lender submission of the form to SBA depends on whether the lender has already submitted the forgiveness decision to SBA.

Additional information and resources are available on the SBA and Treasury PPP pages, ICBA's PPP and EIP News page, the Independent Bankers Association of Texas's matrix of PPP updates in the stimulus law, and ICBA's summary of the stimulus package's community banking provisions.