Q: Is a Lender permitted to submit a PPP loan application to SBA through E-Tran before the Lender has fulfilled its responsibility to review the required borrower documentation and calculation of payroll costs?
A: No. Before a Lender submits a PPP loan through E-Tran, the Lender must have collected the same information and certifications contained in the Borrower Application Form and the Lender must have fulfilled its obligations set forth in paragraphs 3.b.(i)-(iii) of the PPP Interim Final Rule. Please refer to the Interim Final Rule and FAQ 1 for more information on the Lender’s responsibility regarding confirmation of payroll costs.
Lenders who did not understand that these steps are required before submission to E-Tran need not withdraw applications submitted to E-Tran before April 14, 2020, but must fulfill Lender responsibilities with respect to those applications as soon as practicable and no later than loan closing.8
8 Questions 26 – 28 published April 14, 2020.