Bulletin Board Magazine 2020, Volume 2

o Paper files versus computer files? It does not hurt to have the company’s source documents for this issue maintained in multiple formats and media. • The loan application process will be online with the lender who funded you. Look for announcements that the application submissions are now being accepted. If you are unsure or think you have lost track, call your lender. Keep updating your key financial professionals. Call the accountants or the bankers. Leverage their current experience to ensure timely submittal and completeness. o While this statement is self-promotion,

• The loan forgiveness approval clock starts once the lender receives a completed forgiveness application from you. The lender has 60 days to process and issue their opinion on forgiveness to the SBA. The lender has four choices in classifying forgiveness. 1) Approved in Full 2) Approved in Part 3) Denied) 4) Denied without prejudice. While seemingly straight forward, there are two items to be concerned about. An approval in part is a further reduction of the actual amount of the loan forgiven. As an example, your business received $10,000 in funding, because of facts and circumstances you calculate a loan forgiveness amount of $9,000. You indicate that $1,000 should be converted to a loan. Approval in part means the lender is denying an amount greater than $1,000. Maybe they are denying an additional $1,000, so your business would be left with a loan of

$2,000. The SBA receives one of the four decisions issued by the lender for your loan and has 90 days to conduct an SBA loan review and then notify the lender of its acceptance of the lender’s classification. However, the SBA may have independently selected your loan for review for audit outside of the loan forgiveness process. If that occurs, the lender must deny without prejudice your application. Until the results of the SBA audit are concluded, the clock stops ticking on your loan forgiveness application. o Should loan forgiveness become a dispute, appeals can occur provided the issue is raised in a reasonable period of time. In writing to the lender within 30 days when the lender issues the denial. A subsequent SBA denial, after receiving an approval from the original lender, can be appealed to the SBA’s Office of Hearings and Appeals within 30 days as well. Continued ›

you must have your business CPA engaged in this process and provide him timely updates of your usage of funds and forgiveness application process. Allow him time to review and select what’s documented, how much and for when.

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