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Leslie Leyland Fields is an award-winning author of eight books, a contributing editor for Christianity Today,a national speaker, a popular radio guest, and a sometimes commercial fisherwoman, working with her husband and 6 children in commercial fishing on Kodiak Island, Alaska where she has lived for 36 years. How ah ya?” he asked in his Massachusetts accent. Wanting something to claim from this visit, I suggested one more stop before we let him off — ice cream. He hadn’t asked the names of my children or spoken to them, except to ask the older ones about the weather in Kodiak. And that my own path, though at times it would feel lonely, would not be singular or solitary. To do good to someone who doesn’t deserve it. Privacy Policy | Term and Conditions. I turned my eyes slowly to follow his gaze, almost not wanting to look. Forms and Readiness of the Small Business Administration (“SBA”) and the Lender. Loans Over $2 Million: The SBA has indicated that it will review loans in excess of $2 million, and the SBA loan forgiveness applications have a box relating to PPP loans in excess of $2 million (including affiliates). I knew at the same time that forgiveness was a necessary passage for all sons and daughters. And anger at myself and him. 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. I worried most about the two youngest, one and a half and three, who thought all grandfathers were like their grandpa back home, an old man who wanted you to sit on his knee, who played hide-and-seek with you, and who asked you questions and gave you hugs. Seven Key Changes (Changes 1-3) 1. But gray areas remain. For more information, see the section below titled “Loans Over $2 Million” and see the article PPP Loans Over $2 million and the PPP Necessity Questionnaires. They didn’t know anything about him, and they never asked. FaithGateway is brought to you by HarperCollins Christian Publishing and is dedicated to helping you grow and share your faith. If you are on IBR or PAYE, you might get a big raise and your required monthly payments could become large enough that there is nothing left to forgive by the end. We expect more guidance. How can I still want? Changes to a business’s legal structure, a decrease in employee count, or eliminating a division or subsidiary after a borrower takes out a PPP loan might affect the borrower’s ability to receive full or partial loan forgiveness. Extended Coverage; Deadline for Forgiveness Application: The covered period of PPP loans was extended, so there is no need for a borrower to rush the loan forgiveness application process. It was blindingly white, as deep as it was wide, bodies massed on sand and in water. I just told them this man was my father. It was the expectation that Congress would overrule this position, but that has not happened to date. . We stood in line for our cones, then ate them under a tree as we watched the traffic. This is a surprise for most borrowers who were prepared to provide information about “necessity” at the “time of the application” but were not anticipating scrutiny about necessity over the period of use of the funds. 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. The American Institute of CPAs (AICPA) and Biz2Credit, Inc. have put together a PPP Forgiveness Tool, which some borrowers might find helpful to double check their bank’s calculator. Borrowers may submit a loan forgiveness application any time before the maturity date of the loan, which is either two or five years from loan origination. In addition, although the SBA and the U.S. Treasury Department have issued some guidance, we expect that more guidance might be needed for lenders to finalize their forgiveness processes. In addition, there might be other reasons, not to wait—see below. Furthermore, as the rules for PPP loan forgiveness contain so many gray areas, borrowers should also document how a conclusion was reached and what guidance they used to reach the conclusion. See “Key Consideration for PPP Documentation” and “A Guide to the SBA PPP Loan Forgiveness Review Process.”. I get this question so much, I wrote an entire article about it. If you wait an additional 16 weeks, there’s no telling how the guidelines might change and whether you’ll still qualify. We were not involved with the preparation of this tool. For more information, see PPP Loans Over $2 Million and the PPP Necessity Questionnaires. 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. 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. The Paycheck Protection Program Flexibility Act of 2020 (“PPPFA”) was enacted on June 5, 2020, and it extended the covered period from 8 weeks to the earlier of December 31, 2020, or 24 weeks from the date of the loan. I was bothering him. I did not want to, but I immediately thought of my father, that inanimate bulk of a human being who kept getting in the way. Worst of all, the government could discontinue these programs. Any more than $100,000 would mean your non-payroll expenses represent more than 40 percent of the total forgiveness amount. I kept asking questions, trying to store some of his words in my head to write down later, but they evaporated almost as soon as he spoke them. 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. When Should You Apply for PPP Loan Forgiveness? The SBA has a right to request that retained information as part of its review. To the extent a borrower would have deducted from the taxpayer’s income amounts spent on eligible expenses, the borrower should evaluate whether or not it might pay more in taxes than to pay back some or all of the original loan or how the taxpayer will pay the taxes due on those expenditures. “Can you sit?” I asked, looking up at my aged father as he stood above me. He knew nothing about them. How can God’s forgiveness be dependent upon my forgiveness? Four years later, I was reciting the Lord’s Prayer. If a borrower received its PPP loan before June 5, 2020, the PPPFA allows the borrower to elect to use an 8 week covered period. There are answers to this, I have found — profound answers that shake the very ground we stand on, answers that will likely affect all other relationships around us as well. I wanted to remember this moment, the last time I would see my father. Dr. Jill lives with her family in southern California. Why not live in joy and peace now? How Long Do I Have to Spend My Loan’s Proceeds While Remaining Eligible for Forgiveness? From squalls and stormy ocean to palm trees and traffic. These borrowers should also consider delaying to apply for forgiveness until some of these open issues are clarified. How can I forgive him for all the years past, for this moment even now? Do I Pay Off My Loans or Wait for Forgiveness from Sanders or Warren? SBA Timing: The SBA opened up its new platform to accept PPP forgiveness submissions from lenders on August 10, 2020, subject to extension if any new legislative amendments to the forgiveness process necessitate changes to the system. 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. We decided, finally, on a trip to the beach and loaded into the van, nine of us now, and drove to Sarasota Beach, on his suggestion. I understood as I set up the chair. “No, my hips are bad,” he said matter-of-factly. We had a little trouble finding this place,” I said with false brightness. Duncan and the kids ran ahead into the water while I scoped out a stamp of ground for our blanket. Lender Timing: Even if a borrower is ready to apply for forgiveness, its lender might not be ready to receive and review loan forgiveness applications. I’m slow and stubborn, and because my life is so busy, only gradually did I begin to reach this simple conviction: I must forgive my father. Guidance May Evolve: Because of the constantly evolving guidance with respect to loan forgiveness, borrowers should consider waiting before they file their loan forgiveness applications. But that does not mean a borrower should submit a loan forgiveness application as soon as possible. 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 … PPP Loans Over $2 million and the PPP Necessity Questionnaires, Frequently Asked Questions (FAQs) on PPP Loan Forgiveness, Interim Final Rule on Appeals of SBA Loan Review Decisions under the PPP, Interim Final Rule on Treatment of Owners and Forgiveness of Certain Nonpayroll Costs, Interim Final Rule on Additional Revisions to Loan Forgiveness and Loan Review Procedures Interim Rules, IRS Issues Guidance Regarding PPP Loan Forgiveness and Deductibility of Expenses, A Guide to the SBA PPP Loan Forgiveness Review Process, PPP Loans Over $2 Million and the PPP Necessity Questionnaires, PPP Loans and Changes of Ownership, Asset Transactions and Mergers, PPP Loans and Changes in Ownership, Asset Transactions and Mergers, Title I - Keeping American Workers Paid and Employed Act, Hospitals, Health Systems, Physician Groups, and Medical Technology, Title II - Assistance for American Workers, Families and Businesses, Environmental Regulation and Litigation ‎, COVID-19 + Native American & Alaska Native Law, Corporate Restructuring, Bankruptcy, and Litigation. 6. 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