Lender PPP Loan Applications Document Requirements

Can Lenders submit PPP loan applications to the SBA before the lender has reviewed the required borrower documentation and calculation of payroll costs?

No. Lenders are required to collect the information and certifications contained in the Borrower Application Form and the lender must have fulfilled its obligations set forth in the PPP Interim Final Rule. Lenders who submitted these applications without fulfilling these obligations do not need to withdraw their application, but must fulfill these obligations as soon as possible, and before loan closing.

Linked here and pasted below is the text from the official question and answer document published by the Department of the Treasury, which you should reference:

https://home.treasury.gov/system/files/136/Paycheck-Protection-Program-Frequently-Asked-Questions.pdf

Below is the official question from Q28 as of May 14, 2020

28. Question: 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?

Below is the official answer from Q28 as of May 14, 2020

Answer: No. Before a lender submits a PPP loan through E-Tran, the lender must have collected the 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.

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