Q: Is a lender permitted to submit a PPP loan application to SBA through SBA’s electronic loan processing system before the lender has fulfilled its responsibility to review the required borrower documentation and calculation of payroll costs, and for Second Draw PPP Loans, review the required borrower documentation regarding revenue reduction?
A: No. Before a lender submits a PPP loan through SBA’s electronic loan processing system, the lender must have collected the information and certifications contained in the Borrower Application Form (SBA Form 2483, SBA Form 2483-C, SBA Form 2483-SD, or SBA Form 2483-SD-C) and the lender must have fulfilled its obligations set forth in paragraphs 3.b.(i)-(iii) of the first PPP Interim Final Rule, subsection C.3. of the consolidated interim final rule implementing updates to the PPP, orsubsection (h)(2)(i) of the interim final rule for Second Draw PPP Loans, as applicable. Please refer to the Interim Final Rules and FAQ #1 for more information on the lender’s responsibility regarding confirmation of payroll costs, and the interim final rule for Second Draw PPP Loans for the lender’s responsibility regarding confirmation of revenue reduction. Lenders who made PPP loans prior to April 14, 2020 and did not understand that these steps are required before submission into E-Tran did not need to withdraw applications submitted to E-Tran before April 14, 2020, but must have fulfilled l ender responsibilities with respect to those applications as soon as practicable and no later than loan closing.