SBA Procedural Notice

SBA Procedural Notice

The Small Business Administration just released long-sought guidance on submitting the initial SBA Form 1502 for Paycheck Protection Program loans. Lenders are required to submit the form to report on PPP loans and collect the processing fees on fully disbursed loans.

In a new Procedural Notice, the SBA lays out how to create an account with the Fiscal Transfer Agent and use the portal to submit loan information. Lenders must use separate 1502 reports for PPP loans as opposed to regular 7(a) loans.

Under an interim final rule approved earlier this week, the deadline to submit the initial SBA Form 1502 for PPP loans is now the later of: (1) May 29, 2020, or (2) 10 calendar days after disbursement or cancellation of the PPP loan.

That interim final rule also extends the repayment date for the PPP certification safe harbor regarding the borrower’s need for the loan. Under that policy, any borrower that applied for a PPP loan prior to April 24 and repaid the loan in full by May 18 will be deemed by SBA to have made the required certification in good faith.