CARES Act: What Just Happened? Week of September 28, 2020

Kranz receives updates on the CARES Act and how businesses respond to the impacts of the coronavirus through communications with our consultants, valued clients, partner firms, and legal and tax service providers. In our commitment to keeping you informed, we hope that sharing this information is valuable to you.

PPP FAQ and Interim Final Rule Updates

Between the beginning of April and the end of August, the Treasury issued 24 Interim Final Rules and answers to 51 specific PPP related questions which provided guidance and clarification about the program’s deadlines, forms, qualifying expenses, calculations, lender requirements, borrower appeal rights, and other vital topics. If you haven’t taken visited the Treasury website since August, you may be a little worried about doing so now. But know that there have been no updates by the Treasury to any material after August 24. There have also been no new FAQs since August 11.

Loan Forgiveness Update

Since the beginning of August, when the SBA opened its PPP Loan Forgiveness Portal, over 96,000 forgiveness applications have been processed by lenders and submitted to the SBA. To date, however, none of those have been approved. Those applications represent roughly 2% of the 5.2 million loans issued through the PPP. In the news this week, the Treasury has committed to approving most of those requests within the next two weeks except for loans above $2 million, which will require added review.

About $130 billion remains in unallocated PPP funding, but lawmakers have yet to agree on how it should be used for additional small business relief. The key policy under discussion is whether or not to allow small businesses, hit particularly hard by the crisis, to receive a second PPP loan, a step that would require their first loans to be forgiven. Separately, legislation has been introduced in both the House and Senate to streamline forgiveness for loans less than $150,000, granting blanket forgiveness with a simple attestation that the funds were used per guidelines. In a recent survey by the National Federation of Independent Business of PPP borrowers, 84% said they have fully utilized their PPP loan funds, and 44% said they would apply for a second PPP loan if one becomes available.

Legislative Progress on PPP

The House and Senate have been unable to agree on the amount and provisions of an additional round of economic stimulus. However, there is still hope it may occur before the general election on November 3. Highlights of the two plans as they pertain to the PPP are as follows:


  • Loans of $50,000 or less would be automatically forgiven
  • A simplified forgiveness application (see comments in section above) would be provided for loans between $50,000 and $150,000
  • $15 billion would be allocated to smaller lenders
  • 50% of the PPP funding authorized but unused would be distributed to businesses with year-over-year revenue declines
  • Specific PPP funding would be allocated to companies with ten employees or less in low and moderate-income areas


  • Loans of $150,000 or less would be automatically forgiven
  • Documentation requirements on FTEs and use of funds for covered expenses would be eliminated for borrowers with loans between $150,000 and $2 million
  • A second PPP loan would be available for small businesses with 300 employees or less and have experienced at least a 35% drop in year-over-year quarterly 2020 revenue. Loans would be capped at $2 million, less than the $10 million limit on initial PPP loans
  • Covered expenses would be expanded to include specific software and COVID-related costs
  • $50 million provided for audits of PPP loans
  • Creates a shield for businesses and other organizations against COVID-related claims

Lender Administration of PPP Forgiveness Applications

On August 10, the SBA launched its web portal for PPP lenders to submit their borrower loan forgiveness application decisions. Borrowers may submit their loan forgiveness application to the lender once their loan covered period has ended (or before that if all loan funds have been expended). They must apply before ten months after the end of the covered period.

Since our last update three weeks ago, many lenders, including several among the top ten shown below, have begun accepting borrowers’ forgiveness applications. Of particular concern and interest for many lenders, especially the highest loan volume lenders, will be what the Treasury and Congress ultimately decide regarding lower dollar value loans. There is continued hope among lenders and borrowers as well, that Congress will be simplifying the forgiveness process by granting automatic forgiveness to borrowers with loan amounts less than $150,000. Many lenders are also developing internal strategies and sufficient staff levels to enable them to process applications efficiently. Here is the current application processing status for the fifteen lenders with the highest dollar value of loans as taken from the Treasury’s website.

(Updates since September 11 are underlined, lenders accepting forgiveness applications are in bold.)

  • JP Morgan Chase Bank – Not accepting applications and referring borrowers to their “Requesting Forgiveness through Chase” video which covers timelines, definitions, eligible costs, and documentation requirements.
  • Bank of America – Not accepting applications and will advise borrowers when their application portal becomes available, although no estimate of that date is provided.
  • PNC Bank – Not accepting applications as they continue to develop their digital PPP Forgiveness Application which is expected to launch in late August.
  • Trust Bank – Date for accepting applications has been moved from September 21 to the beginning of October
  • Wells Fargo Bank – Not accepting applications as they continue to develop their digital PPP Forgiveness Application. No estimate of when that will be accomplished is provided.
  • TD Bank – Accepting forgiveness applications through their online portal which opened in September.
  • KeyBank – Website provides no information on the status of their application acceptance process or timeline.
  • S. Bank – Not accepting applications. Directs borrowers to use their online application portal expected to be available in early October.
  • Zions Bank – Accepting forgiveness applications through their online portal which opened in July
  • M&T Bank – Not accepting applications as they await new guidance from the SBA. As of September 30 they were in the process of testing their application portal.
  • Huntington Bank – Accepting forgiveness applications through their online portal which opened in September.
  • Cross River Bank – Uses loan service provider, Scratch, to accept and process applications. Scratch online portal became available in September.
  • Fifth Third Bank – Began accepting applications this month through their online portal. Borrowers will be notified in phases through the end of September of the date they specifically can submit their forgiveness application.
  • Citizens Bank – Online application portal accepting applications.
  • BMO Harris Bank – Borrowers with loans greater than $150,000 can submit forgiveness applications through their online portal which became available in September. Borrowers with loans less than $150,000 are not allowed to submit forgiveness applications as the bank awaits new guidance from the SBA.

Additional Resources

We recommend the following websites for additional information and guidance:

How Kranz Can Help

Kranz is ready to provide assistance with preparing accounting documentation for your PPP forgiveness application, and submitting a subsequent PPP loan request if they become available. If you have questions or would like help, please get in touch. Learn more about our other services here.