Paycheck Protection Program Loan Forgiveness FAQs

Yes, Congress continues to consider changes to the program as part of broader COVID-19 relief programs. On May 4, 2021, the Small Business Administration (SBA) announced that all PPP funds were exhausted; therefore, we are no longer accepting PPP loan origination applications. At the moment, we accept PPP forgiveness applications for the loans funded both in 2019 and 2020.

According to current SBA guidance, you may apply for forgiveness in advance of the end of your Covered Period in some situations:

Businesses without employees (other than the owners) may apply for loan forgiveness once you have used all the funds and have obtained the necessary documentation, even if your Covered Period is not over. This applies to all business structures where there were no employees at the time of PPP loan application, and you did not include any employee salaries in the computation of average monthly payroll in your PPP loan application.

Business owners with employees can apply once you have used all the PPP loan proceeds and have obtained the necessary documentation for your application.

• You should consider the timing of your forgiveness application relative to other safe harbor dates and related certifications.
• If you’ve determined that you have reduced employee salary or wages by more than 25%, and want to apply before the end of your Covered Period, you must project that reduction across the full duration of your Covered Period.

Please note that consistent with the latest Procedural Notice from the SBA, subject to certain limited exceptions, you may only submit one loan forgiveness application.

Once we render a decision on a borrower’s application and communicate it to the SBA, you cannot submit a second application.

Your loan forgiveness amount may be reduced if your average weekly FTE employees during the Covered Period or Alternative Payroll Covered Period was less than during your chosen reference period and doesn’t meet Full-time Equivalency (FTE) Reduction Exceptions and Safe Harbor rules.

As long as 60% of the total funds you received are used for eligible payroll costs and no greater than 40% of the funds are used for eligible non-payroll expenses, you may still qualify for full forgiveness.

No. You will need to register for each PPP loan separately within the FNB Forgiveness Portal in order to apply for loan forgiveness. Please note the borrowers must submit a loan forgiveness application for their first draw PPP Loan before the loan forgiveness application for their second draw PPP Loan, even if the calculated amount of the forgiveness on their first draw PPP Loan is zero.

The type of documentation required may vary depending on the nature of the cost for which you are seeking forgiveness. Please consult the SBA’s instructions for the types of documents you will be required to submit with your application. Additionally, when using our Forgiveness Portal, we will prompt you to upload the documents you will be required to submit. You must have uploaded all of the supporting documentation in order to submit your forgiveness application.

A complete listing of the documentation required by the SBA:

• Form 3508: See page six of the SBA PPP Loan Forgiveness Application Instructions for Borrowers (6-16-20)
• Form 3508EZ: See page four of the SBA Paycheck Protection Program EZ Loan Forgiveness Application Instructions
• Form 3508S: See page three of the PPP Loan Forgiveness Form 3508S Instructions

There are three different application forms the SBA has made available for applying for forgiveness. Within the FNB Forgiveness Portal, we will ask the appropriate eligibility questions to determine the right form for you. From there, we will ask questions to help you complete the relevant form. After you complete the required information for the Portal, we will submit your information on your behalf to the SBA using the appropriate form. We will also provide a completed version of the form in PDF format for you to save, print and store.

The three different forgiveness applications differ from one another regarding the required information, calculations and level of documentation required:

• The Long-Form (Form 3508) is the standard form for forgiveness and can be used by all Borrowers. This form requires the most information and the most documentation.
• The EZ-Form (Form 3508EZ) is for Borrowers who meet certain criteria regarding FTE reductions, Salary/Hourly Wage Reductions and generally requires less information and less documentation than the Long-Form.
• The Short-Form (Form 3508S) is only for Borrowers whose PPP Loans do not exceed $150,000 and whose total PPP Loan value together with their affiliates is less than $2 million. This is an abbreviated form that does not take into account FTE reductions or salary/hourly wage reductions.

Per SBA guidance, there are few acceptable types of documentation:

• Per Quarterly financial statements for the entity. If the financial statements are not audited, the applicant must sign and date the first page of the financial statement and initial all other pages, attesting to their accuracy. If the financial statements do not specifically identify the line item(s) that constitute gross receipts, the applicant must annotate which line item(s) constitute gross receipts.
• Quarterly or monthly bank statements for the entity showing deposits from the relevant quarters. The applicant must annotate, if it is not clear, which deposits listed on the bank statement constitute gross receipts (e.g., payments for purchases of goods and services) and which do not (e.g., capital infusions)
• Annual IRS income tax filings of the entity (required if using an annual reference period). If the entity has not yet filed a tax return for 2020, the applicant must fill out the return forms, compute the relevant gross receipts value, and sign and date the return, attesting that the values that are entered into the gross receipts’ computation are the same values that will be filled on the entity’s tax return.

For more information, reference the most recent Interim Final Rule (IFR) located at www.sba.gov or consult accounting/legal advisor.

SBA guidance provides the following information:

• For self-employed individuals other than farmers and ranchers, use IRS Form 1040 Schedule C; sum of Lines 4 and 7
• For self-employed farmers and ranchers, use IRS Form 1040 Schedule F; sum of Lines 1b and 9
• For partnerships, use IRS Form 1065; sum of Lines 2 and 8, LESS Line 6
• For S-Corps, use IRS Form 1120-S; sum of Lines 2 and 6, LESS Line 4
• For C-Corps, use IRS Form 1120; sum of Lines 2 and 11, LESS the sum of Lines 8 and 9
• For nonprofits, use IRS Form 990; sum of Lines 6b(i), 6b(ii), 7b(i), 7b(ii), 8b, 9b, 10b and 12 (Column A) of Part VIII
• For nonprofits, use IRS Form 990-EZ; sum of Lines 5b, 6c, 7b and 9 of Part I
• LLCs should follow the instructions that apply to their tax filing status in the reference periods

For more information, reference the most recent Interim Final Rule (IFR) located at www.sba.gov or consult accounting/legal advisor.

Under current SBA guidance, you may apply for forgiveness any time after you have used all of the loan proceeds for which you are requesting forgiveness and before the maturity date of the loan, which is either two or five years from loan origination.

The latest date you can apply for loan forgiveness is the maturity date of your PPP loan. Please note that you cannot request forgiveness for amounts you have already repaid. You should plan to apply for forgiveness before you need to start making payments. You will have until 10 months after the last day of the Covered Period or Alternative Payroll Covered Period to apply before you must make the first payment.

Yes. The amount of loan forgiveness can be up to the full principal amount of the loan plus any accrued interest. The actual amount of loan forgiveness is ultimately decided by the SBA and depends on a number of factors. You will be required to repay any portion of your loan that does not qualify for forgiveness.

Per the SBA’s update to the forgiveness guidelines, the covered period runs from the date the lender disburses the loan and ends on any date selected by the borrower that occurs no earlier than 8 weeks from the disbursement date, and no later than 24 weeks from the disbursement date. As the borrower, you must pick an end date that best suits your business. Once you enter the end date the portal will calculate the number of weeks in your covered period.

The SBA defines gross receipts as all revenue in whatever form received or accrued (in accordance with the entity’s accounting method) from whatever source, including from the sales of products or services, interest, dividends, rents, royalties, fees, or commissions, reduced by returns and allowances. Compare the identified 2020 quarter meeting to the reference quarter. The reduction in revenue between quarters must be 25% (without rounding up) or greater to meet the qualification. Any quarter of 2020 should be at least 25% lower than the same quarter in 2019; OR 2020 annual gross receipts compared to 2019 annual gross receipts. Entities that use a fiscal year to file taxes may document a reduction in gross receipts with income tax returns only if their fiscal year contains all of the second, third, and fourth quarters of the calendar year (i.e., have a fiscal year start date of February 1, March 1, or April 1).

Business was in operation:	2020	2019
All applicants	Any calendar quarter comparable to...	Same calendar quarter
In 2019	Annual gross receipts comparable to...	Annual gross receipts
3rd & 4th quarter 2019 only	Any calendar quarter comparable to...	Either 3rd or 4th calendar quarter
4th quarter 2019 only	Any calendar quarter comparable to...	4th calendar quarter
On Feb 15th, 2020 only	2nd, 3rd, or 4th calendar quarter comparable to 1st calendar quarter

 

For more information, reference the most recent Interim Final Rule (IFR) located at www.sba.gov or consult accounting/legal advisor.

Per SBA requirement, PO Box cannot be used for a business address. The applicant must submit a physical US address to apply.

No, you do not need to fill out a paper-based application. When you complete your forgiveness application using the FNB Forgiveness Portal, we will use the information you provide to submit that information electronically to the SBA. For your convenience, we will also create an electronic copy of your application that mirrors the paper-based application for you to download and save for your records.

As your forgiveness application moves through the PPP forgiveness process, you will receive automated emails when there is a change in the status of your forgiveness application.

While this information is required for your application, the FNB Forgiveness Portal will pre-populate the SBA number, loan number and lender number for you.

No, based on the SBA’s changes to the forgiveness guidance, you do not need to apply for forgiveness within 60 days of funding.

You may allow your authorized representative to register in our Forgiveness Portal. Once registered, your authorized representative may complete the forgiveness application. As your designated representative, they will receive all communications regarding the forgiveness application going forward. Please note that an individual’s signature as an “Authorized Representative” is a representation to us and the U.S. government that the signer is authorized to make the certifications contained in the application.

No, you can only submit one forgiveness application. Using the FNB Forgiveness Portal, you can always start your application and then save your progress to complete it later. Keep in mind, a completed application, including the required documentation, must be completed and submitted through our Forgiveness Portal before it can be reviewed and submitted to the SBA.

While FNB will be able to assist you with understanding how to use and access FNB’s Forgiveness Portal, we are unable to provide any guidance or clarifications on the government forms, instructions, or the interpretation of those items. For assistance with this type of question, please consult a qualified accounting or legal advisor.

Once registered for the FNB Forgiveness Portal, you will be able to access all your submitted documentation within the online Document Center. You can use this section to find the completed government form, uploaded payroll documents, uploaded nonpayroll documents, and your uploaded FTE/Staffing documents. Please note that once you submit your application, you will no longer be able to edit, add or remove documents unless instructed to do so by your banker.

You should contact your banker or relationship manager in order to make changes to your previously submitted forgiveness application. Please note that we may not be able to support changes to your application or supporting documents if your forgiveness application has already been reviewed and submitted to the SBA.

Yes. We encourage you to review your application in detail before you submit your application to us. Prior to submitting your application to FNB, you will be able to view the completed government application form. Simply click on the link entitled “Loan Forgiveness Application” on the submission step. This link will open a PDF of the applicable government form for you to print, save and review.

While you can save and resume your forgiveness application at any time, you must be sure to click “Save & Proceed” or “Save & Go Back” on each page to ensure your data has been saved.

If you are using the long-form application (SBA 3508) and would like to perform the forgiveness calculations yourself, you should select the "manual entry" option and enter the Schedule A Worksheet 1 and Worksheet 2 Boxes 1-5 manually in our Portal.

Alternatively, we can guide you through the process of entering your staffing and payroll information and perform the relevant calculations for you using the “guided entry” option. Choose this option if you would like to use our guided experience to enter your information.

The SBA has indicated that it takes, on average, up to 180 minutes to complete the full forgiveness application. Your time may be more or less depending on a number of factors, including: the availability of the required information and documentation, the SBA form version that you are eligible to use, and your familiarity with using online systems. With the FNB Forgiveness Portal, you can always save your progress and log in again to continue your application.

If you wish to apply for forgiveness without the online portal, please consult with your banker, or reach out to your nearest branch. The only option to apply is through the online portal. If you wish to apply for forgiveness without the online portal, please consult with your banker or reach out to your nearest branch. If you are Amish, we will handle those on a one off basis.

You will not have to make any payments on your loan until we receive the SBA’s decision on your application for loan forgiveness. Once you have submitted your complete forgiveness application, the review process can take as long as 150 days – 60 days for FNB to complete our lender review process and up to 90 days for the SBA to complete their review under the current guidelines. If you do not apply for loan forgiveness within 10 months after the last day of your Covered Period, you must begin making payments on your loan at that time.

All loans are subject to the new provisions outlined in the PPP Flexibility Act, regardless of the loan agreement language. Therefore, as long as you apply for loan forgiveness within 10 months after the end of your Covered Period, loan payments will be deferred until we receive the SBA’s decision on your application.

You will be responsible for interest accrued on the portion of the loan that does not qualify for forgiveness. Interest accrual begins on the date of disbursement.

Per SBA’s updated forgiveness guidelines, an EIDL advance is potentially a forgivable amount and should not be subtracted from your requested forgiveness amount as it was in prior guidance. If you have already received forgiveness, you will be reimbursed for any EIDL advances that were deducted from their forgiveness payment, as per SBA guidance. For any EIDL refinancing questions please contact your banker.

No. Under current guidance, the SBA will not accept loan forgiveness applications from borrowers that have fully repaid their PPP loan(s). If partially repaid, you will be responsible to repay any portion of the loan that was not forgiven by the SBA and any accrued interest on that unforgiven portion.

If you have already registered for access to the FNB Forgiveness Portal and are having trouble logging in, please contact your banker during regular business hours, or email us at PPPCustomerSupport@fnb-corp.com for all PPP related inquiries or to request same business day call back. Our normal business hours are Monday through Friday, 9:00 AM - 4:00 PM ET. Please note, all inquiries submitted after 4 PM ET will be addressed the following business day.

1. Make sure you are using an up-to-date web browser.
2. Our Portal only supports the following file types: Portable Document Format (.pdf), Microsoft Word (.doc, .docx), Microsoft Excel (.xls, xlsx, csv), JPEG images (.jpg, jpeg), and Portable Network Graphics images (.png). 
3. The maximum file size allowed is 25MB per document. If the file size is greater than 25MB, you can separate the file into multiple files to upload again.

It could take up to five months for FNB and the SBA to review most complete applications. Actual times will vary. You will not have to start making payments until the SBA provides a decision on your request or remits the funds.

For loans made before June 5, 2020, the maturity is two years. For loans funded on or after June 5, 2020, the maturity is five years.

SBA guidance indicates that the maturity date for loans made before June 5, 2020, is two years unless the Borrower and lender mutually agree to extend the term of the loan to five years.

Yes, if you wish to dispute the SBA decision on the amount approved or the disapproval of their PPP loan forgiveness, you must follow the instructions detailed in the Interim Final Rule. Unfortunately, in accordance with the SBA rules, FNB cannot assist you with this process.

FNB is committed to making the transition as smooth as possible for former Howard Bank customers. You will still be able to apply for forgiveness using Howard Bank Forgiveness Portal. The login credentials created at origination of your 2021 second draw PPP loan will stay the same when applying for forgiveness.

For assistance, please contact your banker during regular business hours or email us at hb-pppquestions@fnb-corp.com.

No, Crowe portal was used only for a first draw PPP loans and no longer accessible. Please be sure to use Howard Bank Forgiveness portal to apply for the forgiveness of your second draw PPP loan and use the same credentials that you have created when applied for the second draw (2021) PPP loan. There are no portal invitations to apply for forgiveness on a 2021 PPP loan. If you cannot recall your login credentials, please email us at hb-pppquestions@fnb-corp.com.

Yes, FNB has agreed to continue using Howard Bank Forgiveness Portal to process second draw PPP loans originated with Howard Bank.

No, the same credentials created when applying for the second draw (2021) loan on Howard Bank Forgiveness Portal can be utilized to access forgiveness application.

For assistance, please contact your banker during regular business hours or email us at hb-pppquestions@fnb-corp.com.

Howard Bank Forgiveness Portal recommends using an updated version of Google Chrome or Edge; however, any browser should work with the platform.

If you forgot your password, use the “Forgot Password?” prompt to reset it. You’ll need the registered email.

• Start by clicking on the “Begin Forgiveness” prompt on Howard Bank Forgiveness Portal homepage
• Enter “EIN or SSN” & “SBA Loan Number”
• Click on “Find your loan” to find your existing portal account

Your SBA loan number is stated on the origination note of your second draw PPP loan. If you are unable to locate this documentation, email us at hb-pppquestions@fnb-corp.com.

Yes, a borrower may work on more than one forgiveness application (if applicable) using the same login credentials.

No, the 'Ask an Accountant' feature is not available for Howard PPP customers.

To address a mistake, you may utilize the message center to notify the reviewer. Additionally, you can email us at hb-pppquestions@fnb-corp.com.

Please note that we may not be able to support changes to your application or supporting documents if your forgiveness application has already been reviewed and submitted to the SBA.

Yes. The Howard Bank Forgiveness Portal does have password requirements when resetting a password. The password must contain:

• one number,
• one uppercase,
• one lowercase letter,
• one special character and
• 8 or more characters.

Howard Bank Forgiveness Portal only supports the following file types: Portable Document Format (.pdf), Microsoft Word (.doc, .docx), Microsoft Excel (.xls, xlsx, csv), JPEG images (.jpg, jpeg), and Portable Network Graphics images (.png).

The maximum file size allowed is 35MB per document. If the file size is greater than 35MB, you can separate the file into multiple files to upload again.