SBA Issues Updated PPP Loan Forgiveness Applications and Updated PPP Guidance
The Small Business Administration (SBA) has issued updated Paycheck Protection Program (PPP) loan forgiveness applications as well as interim final rules on various aspects of the PPP. 
The PPP loan forgiveness applications were updated to include second draw loans, as well as update the limit for the simplified forgiveness form for loans up to $150,000 (previously limited to $50,000). The updated forms are as follows:
In addition to the updated forgiveness forms, the SBA also issued a comprehensive interim final rule (IFR) entitled, “Loan Forgiveness Requirements and Loan Review Procedures as Amended by Economic Aid Act.”
This IFR incorporates PPP second draw loans into the various IFRs and provides a question and answer approach to documents the SBA has previously released. In addition, the IFR incorporates changes made by the Economic Aid Act, including with respect to forgiveness of PPP second draw loans. 
Although the updated PPP loan forgiveness Form 3508S increased the loan size up to $150,000 for simplified loan forgiveness, loans greater than $50,000 are still subject to potential reduced forgiveness calculations as a result of reductions in full-time equivalents and/or decreased wages by greater than 25% for those making less than $100,000 on an annualized basis. Therefore, if you are using the simplified loan forgiveness form and your loan is between $50,000 and $150,000, you still need to consider whether or not you have any potential reduction in your forgiveness amount. 
If you have questions on the provisions contained in the Economic Aid Act, eligibility for a PPP second draw loan, or on your existing PPP loan forgiveness application, we have a team ready to assist you. Contact your ACT client service representative or email us at