SBA / Treasury FAQ – 28. 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?

Compliance > CARES Act
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
 
____________
Footnote:
 
8 Questions 26 – 28 published April 14, 2020.
 
 
This Q&A was based on information contained from the Treasury Department’s April 2020 issuance “Paycheck Protection Program Loans, Frequently Asked Questions,” which has been updated from time to time.  This CARES Act / SBA / PPP related issuance may be found here:  https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf
 

Add Feedback