The SBA released guidance on October 7, 2020, clarifying that lenders must give immediate effect to the extended deferral period for borrower payments of principal, interest, and fees on all PPP loans, requiring lenders to notify borrowers of the change to the deferral period, and confirming that no formal modification to the promissory note is required for this purpose. Loving daughter greeting long-lost father? Dr. Jill has gained a reputation for her gentle and insightful style of connecting with radio callers. He is utterly content with his ice cream, while his daughter sits beside him, starving to death — and the ice cream is  pretty good today, isn’t it? I got out slowly, carrying my youngest, and opened the side doors for the others. This is especially true for the self-employed and owner-employees whose compensation was capped at 2.5 months’ worth of 2019 net profit. Most Paycheck Protection Program (“PPP”) borrowers are working toward full forgiveness of their PPP loans and are anxious to get this process started. He was eighty-four, so I knew this would be my children’s only chance to meet him. Depending on the timeline of these changes, it might be beneficial to apply for forgiveness before the changes take place, especially if the borrower is relying on FTE Reduction Safe Harbor 2, which is tied to the date of the forgiveness application. I knew what to do. Some guidance was posted in August and October 2020 (see links below) and related to owner-employee compensation, the eligibility of nonpayroll costs, certain calculations for reductions in employee salary or hourly wages, and borrower submission of excess costs. Maybe you still see them and you just endure the bitter undertone, acidic remarks, apathy, etc. It was March 2006, our spring break. He was just as I remembered, but bigger, maybe forty pounds heavier than the last time. If any of these gray areas are critical for a borrower’s loan forgiveness, the borrower might want to consider waiting for additional guidance. Through some impetus I don’t remember now, I had decided we needed to go to Florida. Eight Weeks vs. 24 Weeks. Because of the many variables that affect each borrower differently, a borrower should consider discussing the loan forgiveness process with legal counsel before submitting the application. I put my toddler down and came and smiled, then hugged the strange man, patting him on the back with my fingers, keeping our bodies separate. I was bothering him. How do I play this scene? Forms and Readiness of the Small Business Administration (“SBA”) and the Lender. This article discusses the timing considerations and other items that might affect a borrower’s decision to submit the loan forgiveness application to its lender. The person may or may Necessity Questionnaires: Starting around October 26, 2020, the SBA asked some PPP lenders to provide certain questionnaires to PPP borrowers with loans over $2 million. Rather, the 60% number is to be applied on a proportional basis instead of a cliff, thus allowing borrowers to seek forgiveness even though less than 60% of the loan proceeds were used for payroll costs. Come join the conversation on our blog! I hadn’t seen my father for ten years. If you were funded on or after June 5, 2020, and have to wait the entire covered period, you won’t be able to apply for forgiveness until November 20 th at the earliest. I wanted to remember this moment, the last time I would see my father. I would not come back, I decided. The van stopped. I saw his dark skin, his head, nearly bald, distinctively square, with a barely visible neck. Borrowers with loans over $2 million should gather the requested information now in anticipation of the lender’s request. He wanted to sit in the sun, watch the water, and be quiet. Starting around October 26, 2020, the SBA asked some PPP lenders to provide certain questionnaires to PPP borrowers with loans over $ 2million. The question came as a deep puzzle to me, as it did to all my siblings. How can I forgive him for all the years past, for this moment even now? If you wait an additional 16 weeks, there’s no telling how the guidelines might change and whether you’ll still qualify. A borrower that, together with its affiliates, received PPP loans totaling $2 million or greater cannot used Form 3508S. They didn’t know anything about him, and they never asked. In the meantime, taxpayers would be best served analyzing the potential tax consequences of the Notice and preparing for those tax consequences now. You cannot wait for your father and mother to do this for you. We do not know if these forms are in final form. Don’t put off getting the “retained” documents together. More Guidance Is Expected: We are expecting more guidance in a number of areas. I had warned the four older kids, ages nine to sixteen, that he probably would not talk to them or even ask their names or ages. Do I Pay Off My Loans or Wait for Forgiveness from Sanders or Warren? He sat at the wooden picnic table with a slight smirk, looking utterly content. Whatever your motives, you are the one to do it. I kept hearing the commandment, Honor your father and your mother. “Good. We had flown in from Kodiak, Alaska, from the far northwest corner of the country to the far southeast corner. Patience and adequate preparation might be more than just virtues in the PPP loan forgiveness context; they might lead to financial benefits for borrowers as well. Maybe your heart breaks every time you think about them. And that my own path, though at times it would feel lonely, would not be singular or solitary. Your Turn He didn’t remember much, answering in short, vague sentences spoken sideways, his eyes always away, looking to the ocean. FaithGateway is brought to you by HarperCollins Christian Publishing and is dedicated to helping you grow and share your faith. In addition, if a borrower applies for forgiveness before the end of the covered period and has reduced any employee’s salary or wages in excess of 25%, the borrower must account for the excess salary reduction for the full covered period. It had taken us two days to get there. My lips taut, mouth clamped shut, containing as much emptiness and want as I could hold. If you truly believe, you are at the wrong end of mistake, admit it and try to remedy for the mistake. Had we really spent all that money to fly down here for just two hours? A request for forgiveness. Michael Lux January 16, 2020 Strategy , Student Loan Blog 1 Comment Editor’s Note: This article has been updated on January 16, 2020, to reflect Senator Warren’s plan to forgive … You cannot wait for them any longer. Two hours later, we were headed back, the day at the beach already exhausted. I had never talked about him to my kids. To do good to someone who doesn’t deserve it. I began to understand. In the past, the SBA has been very strict and unforgiving of “technical false certifications.”, Changes to Business Structure: Many borrowers have had to revise their business structure in the face of the pandemic. Maybe you’ve decided that you’re done feeling a shred of sadness or anger. In addition, there are legislative proposals to reduce this paperwork and streamline the process for loans under $150,000. Surely that’s a slip, a scribe’s slide of the pen. Dr. Jill lives with her family in southern California. Copyright © 2019 HarperCollins Publishers.
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