Academy Bank has been honored to participate in both rounds of the Paycheck Protection Program, through which we have successfully funded more than 2,350 PPP loans for our clients that have been crucial to assisting small businesses. Whether you are an existing client or a new one, we look forward to working with you and continuing our relationship into the future.
Disclaimers It is your sole legal responsibility to comply with all laws and regulations applicable to borrowers under the PPP. Academy Bank recommends that you closely review the latest laws, regulations and guidelines issued by the SBA with respect to the PPP (“Guidelines”). The Guidelines can be located on the SBA and Department of the Treasury websites: www.sba.gov and www.treasury.gov. Academy Bank cautions that the Guidelines are evolving and subject to change, clarification and/or periodic updates by the SBA. Academy Bank is not providing legal, tax or accounting advice with this application or any other correspondence related to PPP or otherwise. Individual facts and circumstances may vary from borrower to borrower which could impact answers regarding interpretations of Guidelines or other questions. You should consult with your legal, tax and accounting advisors to obtain advice regarding your specific situation. Our materials and communications should be considered in conjunction with, and not as a replacement or substitute for, your close review of the Guidelines. Update - March 5, 2021Academy Bank is currently working on originating new PPP first and second draw loans and working through the forgiveness process for PPP loans originated in 2020. We will look to start the forgiveness process on second draw loan sometime after 4/30/21. The payment deferral period is your covered period plus six months. We recommend you start preparing now for the upcoming forgiveness process. The next steps are to maximize your potential forgiveness, collect and maintain all documentation as to how your PPP loan proceeds were used, and then apply for PPP forgiveness. Under current SBA guidelines, the eight to twenty-four week forgiveness period starts on the date funds were advanced to your account. We will only accept applications completed through our online platform. For up-to-date rules, and Forgiveness applications please visit the SBA website. The instructions for the forgiveness applications include guidance as to what borrowers qualify for the S or EZ forms and what documentation you are required to collect and submit. Please continue to monitor the U.S. Treasury, SBA and Academy Bank websites for additional information related to the forgiveness process. Any guidance provided at this time is meant to help you prepare for the upcoming forgiveness process; however, it is subject to change. In preparation for the forgiveness process please start to compile the necessary documentation including but not limited to: Payroll (provide documentation for all payroll periods that overlapped with the Covered Period or the Alternative Payroll Covered Period):
Non-payroll (for expenses that were incurred or paid during the covered period and showing that obligations or services existed prior to February 15, 2020):
On 2/22/21 President Biden announced several changes to the SBA’s PPP program. This included allowing sole proprietors, independent contractors, and self-employed individuals to receive more financial support by revising the PPP’s funding formula for these categories of applicants. Many clients have inquired about revising their loan amounts based on the new guidance. However, at this time the new rules only apply to loans originated after the rules were issued by the SBA on 3/3/21 and not retroactively. Please be aware that data on PPP loans including business name and location is made public by the SBA. Based on this data, third parties have been able to send unsolicited offers to PPP borrowers. These offers/third parties are not endorsed in any way by Academy Bank. If you have any questions please reach out to your assigned banker or email us at pppforgiveness@academybank.com. Once again, we thank you for the opportunity to fund your PPP loan. We offer a complete line of business products including checking, money market, credit cards and Treasury Management services. We would welcome the opportunity to visit with you and earn more of your business. If you have any questions, please contact us at pppforgiveness@academybank.com. Also, please continue to check our website for updates regarding the PPP Forgiveness process. |
Disclaimers
It is your sole legal responsibility to comply with all laws and regulations applicable to borrowers under the PPP. Academy Bank recommends that you closely review the latest laws, regulations and guidelines issued by the SBA with respect to the PPP (“Guidelines”). The Guidelines can be located on the SBA and Department of the Treasury websites: www.sba.gov and www.treasury.gov. Academy Bank cautions that the Guidelines are evolving and subject to change, clarification and/or periodic updates by the SBA.
Academy Bank is not providing legal, tax or accounting advice with this application or any other correspondence related to PPP or otherwise. Individual facts and circumstances may vary from borrower to borrower which could impact answers regarding interpretations of Guidelines or other questions. You should consult with your legal, tax and accounting advisors to obtain advice regarding your specific situation. Our materials and communications should be considered in conjunction with, and not as a replacement or substitute for, your close review of the Guidelines.
Update – February 8, 2021
On December 21, the House and Senate passed the Coronavirus Response and Relief Supplemental Appropriations Act. President Trump signed the act into law on December 27. The SBA issued the initial Interim Final Rules (IFRs) on January 7. There are two IFRs -- one that details guidelines for PPP Second Draw loans, and one that updates/consolidates existing IFRs with the changes that were included in the Coronavirus Response and Relief Supplemental Appropriations Act.
Academy Bank started accepting PPP Second Draw applications from our existing PPP First Draw clients on January 17. To date we have received over 750 PPP Second Draw applications. Through January 31, the SBA reported PPP Second Draw funding of $72.7 billion which totals only 26% of the $284 billion allocated by Congress for PPP Second Draw loans.
During this round of PPP, the SBA made many changes to their platforms that allowed Academy Bank to process a majority of the second draw applications in a very efficient manner. However, the SBA also added many pre and post approval data validation routines that are causing delays in SBA approval on many PPP Second Draw applications that appear valid. This is an industry wide problem with an error rate as high as 30%. Both the ABA and AICPA have sent letters to the SBA urging them to address these problems. Academy Bank associates have been working long hours to clear these errors. However, it is a manual process and an many cases the SBA has not yet issued guidance as to what some of the errors mean and on how some of the errors can be cleared. To date Academy Bank has cleared many errors but we are still working on approximately 100 applications with data validation issues. Please be assured that we will continue to work to get all of the applications approved as soon as we can.
To date, Academy Bank has not fully rolled out the forgiveness process to our clients with loans less than $150,000 in anticipation of receiving changes from the SBA. The SBA issued updated forgiveness applications and rules in late January. Academy Bank has finished implementing these changes into our online platforms and we are currently finishing testing. We are looking to sending out personalized forgiveness links to PPP First Draw loans under $150,000 early the week of February 8. The changes significantly reduce the amount of time needed for you to apply in terms of calculations and uploading documents and significantly reduces the bank’s time in terms of review of documents and calculations. The Coronavirus Response and Relief Supplemental Appropriations Act does not change the forgiveness process for loans above $150,000. Academy Bank will resend the application link to those clients with First Draw loans above $150,000 who have not yet applied for forgiveness.
Forgiveness Application Process
- Complete the online Academy Bank application at any time during 24-week covered period once your PPP funds have been fully spent. Academy Bank will only accept applications electronically through the link received via email.
- The online application will automatically progress to the appropriate application (3508, 3508EZ, 3508S) based on the loan size and your answers to specific questions.
- For the 3508 and 3508 EZ - Once the application is submitted you will receive a separate email with a link to our document portal. This is where you will upload any of the required forgiveness documentation (detailed in the 3508 and 3508 EZ instructions). We will not be able to begin processing your forgiveness request until all required documentation has been uploaded.
- For the 3508 S ($150,000 and under) – Borrowers are no longer required to provide documents to the bank. However, the borrower must retain all records necessary to prove compliance with Paycheck Protection Program Rules for four years for employment records and for three years for all other records which the SBA may request if needed to evaluate the borrower’s eligibility for the PPP loan and for loan forgiveness.
- Once we have received the application, we will review your application, send the final version via DocuSign for the required borrower certifications and your signature and submit our decision within 60 days to the SBA.
- The SBA may take up to 90 days to issue a final decision. You will be notified if they request additional information.
- Once the SBA remits the loan forgiveness proceeds, we will notify you.
COVID-19 has had an unprecedented impact on our daily lives and the economy. With the COVID vaccines now becoming available and the additional stimulus from the government, hopefully we start to see the light at the end of the tunnel. Our bankers at Academy Bank are focused on delivering resources and information to help our clients navigate the PPP process. If you have any banking needs, please reach out to your assigned banker at any time. As always, if you have any questions at all, please contact us at pppforgiveness@academybank.com.
Disclosures:
It is your sole legal responsibility to comply with all laws and regulations applicable to borrowers under the PPP. Academy Bank recommends that you closely review the latest laws, regulations and guidelines issued by the SBA with respect to the PPP (“Guidelines”). The Guidelines can be located on the SBA and Department of the Treasury websites: www.sba.gov and www.treasury.gov. Academy Bank cautions that the Guidelines are evolving and subject to change, clarification and/or periodic updates by the SBA.
Academy Bank is not providing legal, tax or accounting advice with this application or any other correspondence related to PPP or otherwise. Individual facts and circumstances may vary from borrower to borrower which could impact answers regarding interpretations of Guidelines or other questions. You should consult with your legal, tax and accounting advisors to obtain advice regarding your specific situation. Our materials and communications should be considered in conjunction with, and not as a replacement or substitute for, your close review of the Guidelines.
Update - January 8, 2021
First, below are two important points regarding when the new PPP Second Draw loans may become available:
-
There will be a new application (2383-SD) for the PPP Second Draw loan. As of January 8, the SBA had not issued this application. Once issued, banks will have to incorporate the new application into their PPP processes. We have people ready to work on this once it is released.
-
As of January 8, Academy Bank had not been given an exact date as to when we will be able to fund PPP Second Draw loans. Right now the earliest expectation for this is late next week. Here is the US Treasury Press Release.
The legislation authorizes more than $900 billion in economic aid and implements many of the PPP improvements that Academy Bank and the banking industry have been expecting and we have highlighted in previous email updates. Below are the primary areas related to the PPP that are impacted by the legislation.
-
Forgiveness process on PPP loans less than $150,000
-
Simple one-page application
-
Clients do not have to provide supporting documentation to the bank for review
-
Clients must maintain employment records for four years and other records for three years
-
-
Makes additional expenses eligible for PPP loans can be used for
-
Repeals section of the CARES Act that required PPP borrowers to deduct the amount of their EIDL advance from their PPP forgiveness amount (the SBA has 15 days to issue rules to implement procedures on refunding of the EIDL amounts subtracted from previously forgiven loans). Deducting EIDL advances from Forgiveness Requests stopped on December 27, 2020.
-
Addresses tax deductibility of PPP funds spent on expenses
-
Authorizes $284.6 billion to reopen PPP for first-time borrowers and to issue second draw loans
-
2.5 times average monthly payroll based on 2019 calendar year or 12-month look-back. Maximum loan amount of $2 million.
-
NAICS 72 businesses (Accommodations and Food Services) can receive 3.5 times monthly payroll
-
300 or fewer employees
-
25% drop in revenue in any quarter of 2020 compared to the same quarter in 2019. Can also use full year 2020 over 2019.
-
The 60/40 cost allocation between payroll and non-payroll costs continues to apply to receive full forgiveness
-
Below are some items you can do now to help prepare for a PPP second draw loan:
-
Determine if you are eligible for a PPP second draw loan. Detailed eligibility requirements start on page 24 of the IFR for PPP Second Draw loans.
-
Collect documentation showing 25% or more decline in revenue.
-
For PPP Second Draw requests above $150,000, clients will be required to provide this documentation as part of the application process.
-
-
Determine which payroll period you will use to determine the PPP Second Draw loan amount (2019 or 2020).
-
Using the same payroll information that was used to determine the loan amount for the PPP First Draw will result in the quickest processing since no additional documentation or underwriting is needed. If you choose a different timeframe for the average payroll calculation, all of the supporting documentation (payroll records, 941s) must be provided to the bank and the bank must underwrite the new loan amount.
-
-
All PPP Second Draw clients will need to have an open Academy Bank deposit account for the PPP loan proceeds to be deposited into.
-
Watch your email for updates. We anticipate that once the new PPP Second Draw application is available, a link to apply will be directly emailed to clients who obtained a PPP First Draw loan through Academy Bank.
As you prepare for PPP Second Draw, the below sites give helpful summaries of the program:
Please keep in mind that the above are brief summaries and are provided in an effort to keep all of our clients updated. The guidelines are evolving and subject to change. It is your sole responsibility to comply with all laws and regulations applicable to borrowers under the PPP. Academy Bank recommends that you closely review the latest laws, regulations and guidelines issued by the SBA with respect to the PPP.
To date, Academy Bank has not fully rolled out the forgiveness process to our clients with loans less than $150,000 in anticipation changes from the SBA. The proposed changes should significantly reduce the amount of time needed for you to apply in terms of calculations and uploading documents and significantly reduces the bank’s time in terms of review of documents and calculations. The SBA has 24 days from when President Trump signed the law to issue regulations and the one-page forgiveness application implementing the changes to the forgiveness process. Once the SBA issues these regulations, Academy Bank will review and make necessary changes to our platforms and processes. These are the last material changes we expect; once our platforms are updated, we will send out the forgiveness invitations to our remaining PPP clients with loans of $150,000 and less. The Coronavirus Response and Relief Supplemental Appropriations Act does not appear to change the forgiveness process for loans above $150,000. While we wait for the SBA to issue new rules/regulations to implement the legislation, we will continue to process all applications received using the existing rules and guidance from the SBA.
Our recommendation at this time is for our clients with PPP loans of $150,000 and less to continue to wait for these most recent changes from Congress to be fully implemented by the SBA that will make the forgiveness process much easier. However, if there are extenuating factors that necessitate a forgiveness application at this time, please contact your assigned banker or email us at pppforgiveness@academybank.com to request a customized link to our forgiveness platform. Academy Bank will only accept PPP Forgiveness applications through its online platform via the direct link we email to you. Completion of the Forgiveness process is not a requirement for the PPP Second Draw loan.
We will continue to monitor the SBA for PPP Second Draw application guidance. Once issued, we are committed to incorporating the guidance in to our processes and getting our clients PPP Second Draw loans. Please continue to check Academy Bank’s website for current and previous updates regarding the PPP Forgiveness process and PPP Second Draw Loans.
COVID-19 has had an unprecedented impact on our daily lives and the economy. With the COVID vaccines now becoming available and the additional stimulus from the government, hopefully we start to see the light at the end of the tunnel. Our bankers at Academy Bank are focused on delivering resources and information to help our clients navigate the PPP process. If you have any banking needs, please reach out to your assigned banker at any time. As always, if you have any questions at all, please contact us at pppforgiveness@academybank.com.
Update - December 29, 2020
As many of you are certainly aware of, Congress has had ongoing negotiations since June on an additional COVID stimulus package that many of our clients desperately need. On December 21, the House and Senate passed the Coronavirus Response and Relief Supplemental Appropriations Act. President Trump signed the act into law on December 27. The legislation authorizes more than $900 billion in economic aid and implements many of the PPP improvements that Academy Bank and the banking industry have been expecting and that we have highlighted in previous email updates.
Below are the primary areas related to the PPP that are impacted by the legislation.
-
Forgiveness process on PPP loans less than $150,000
-
Simple one-page application
-
Clients do not have to provide supporting documentation to the bank for review
-
Clients must maintain employment records for four years and other records for three years
-
-
-
Makes additional expenses eligible for PPP
-
Repeals section of the CARES Act that required PPP borrowers to deduct the amount of their EIDL advance from their PPP forgiveness amount (SBA has 15 days to issue rules to implement)
-
Addresses tax deductibility of PPP funds spent on expenses
-
Authorizes $284.6 Billion to reopen PPP for first time borrowers and to issue second draw loans.
-
2.5 times average monthly payroll based on 2019 calendar year or 12 month look back. Maximum loan amount of $2 Million.
-
NAICS 72 businesses (Accommodations and Food Services) can receive 3.5 times monthly payroll
-
-
300 or fewer employees
-
25% drop in revenue in any quarter of 2020 compared to the same quarter in 2019
-
The 60/40 cost allocation between payroll and non-payroll costs continues to apply to receive full forgiveness
-
Please keep in mind that the above is just brief summary and is provided in an effort to keep all of our clients updated. The PPP-related items in the Coronavirus Response and Relief Supplemental Appropriations Act must be implemented by the SBA through new rules and regulations that will be forthcoming.
The Coronavirus Response and Relief Supplemental Appropriations Act also authorizes $284.6 billion in additional funds for PPP second draw loans. The SBA has 10 days to issue new regulations to implement this part of the Coronavirus Response and Relief Supplemental Appropriations Act. As Academy Bank receives additional information regarding the details of the PPP Second Draw loan, we will keep our PPP clients updated via email and updates to our website.
Please continue to check Academy Bank’s website for current and previous updates regarding the PPP Forgiveness process.
As we approach the New Year, first and foremost, all of us here at Academy Bank hope you stay safe and healthy, and that you enjoy the holidays.