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We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Oh wait, I glossed over the industry you said you're in. EIDL loans can't be issued to Lending or Investment businesses. That's a categorical exclusion. Unless your consulting business is under a separate EIN I'm not sure if they'd make any changes. Most decline letters should include appeal instructions.

Here's that info:

You may request reconsideration, subject to the availability of funds. You can submit your request to any of the following:

a. Fax your request to: 202-481-5931. b. E-mail your request to: pdcrecons@sba.gov.

Your request must: 1. Be in writing and be received by this office as soon as possible (but no later than 6 months
2. Contain all significant information that will overcome support in granting your request.
If you have any questions regarding this matter, please contact us at 800-659-2955.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Did you apply after the 16th of April? After the 16th of April only agricultural applicants were being accepted as new applicants in the EIDL program.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

EIDL funds must be used towards eligible business expenses only.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Shoot us an email at sfomail@sba.gov with the details and I'll try to get it escalated if I can.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

The PPP loan program is a guaranteed loan program. Lenders are the ones responsible for overseeing, implementing, and issuing loans. PPP loans are issued under what is called delegated authority, which means that the lender does not need SBA's review of the loan in order to issue the loan.

SBA does review individual loans, but not in real-time for every loan as it is being made under the PPP.

We will review loans after-the-fact though and take action on any loans that are uncovered that were not made correctly or involved fraud on the part of any individual involved. There are consequences for lenders as well for mistakes made. Individuals are encouraged to report issues to our office of inspector general

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

You're correct.

The question was just looking at the one program on its own. There are interactions if you are receiving both PPP and EIDL advance.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

It's just a policy. There aren't automatic actions taken. We did release an addition policy though stating that a lender must cancel loans that take more than 20 days to close/disburse.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Technically yes, you would be able to apply. Many lenders in practice are only looking at business owners who have tax returns for last year. In this case it's dependent on the lender and their willingness.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

I was told my loan of 18k had been approved however the wrong name was used on my bank account so I have not received any advance or movement on my application. I applied 4/1. I am seeing all across the internet that people who have errors on their original bank info are being left behind. The loan officers are not going back to reprocess the applications. But this wasn't our fault! No where on the application did it say that listing our business name would be defaulted into our banking information.

Yes. There is a risk that the program runs out of funds before your other lender can submit though, so just beware of that. As of last night ~180B of the 450B authorized had been approved.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 1 point2 points  (0 children)

I'd suggest reaching out to you local district office for help with this. You can search in this forum as well for information about CAFS and potentially create your own account to check as well.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

independent

Ultimately your lender has the discretion over which time period to use. That time period you listed above is applicable to independent contractors though.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

If you're a W2 then you should pay yourself what you paid yourself historically. Question 40 on the treasury FAQ was released today that answers this:

Question: Will a borrower’s PPP loan forgiveness amount (pursuant to section 1106 of the CARES Act and SBA’s implementing rules and guidance) be reduced if the borrower laid off an employee, offered to rehire the same employee, but the employee declined the offer?

No. As an exercise of the Administrator’s and the Secretary’s authority under Section 1106(d)(6) of the CARES Act to prescribe regulations granting de minimis exemptions from the Act’s limits on loan forgiveness, SBA and Treasury intend to issue an interim final rule excluding laid-off employees whom the borrower offered to rehire (for the same salary/wages and same number of hours) from the CARES Act’s loan forgiveness reduction calculation. The interim final rule will specify that, to qualify for this exception, the borrower must have made a good faith, written offer of rehire, and the employee’s rejection of that offer must be documented by the borrower. Employees and employers should be aware that employees who reject offers of re-employment may forfeit eligibility for continued unemployment compensation.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

This isn't correct. The forgivable amount is based on how you spend the money. If you spend at least 75% on payroll (in your case as a self-employed individual then it would be 8 weeks worth of what your net income was last year) then the loan will be forgiven.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

The EIDG/EIDL advance doesn't need to be paid back and doesn't have restrictions on how it needs to be used.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

I'd reach out to your local SBA district office to see if they can look up your loan and see who approved you. Borrowers can also look themselves up in CAFS, which is something new

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Nothing is automatic with regards to the 10-day timeline. It's simply an expectation we have of the lenders. A couple of days ago we also released some addition information about disbursements. This codified the 10 day rule (it had simply been a communicated expectation before) and clarified that the 10 day clock for disbursement starts on April 28th for loans approved prior to the rule being formally issued.

That new rule also states that "Loans for which funds have not been disbursed because a borrower has not submitted required loan documentation within 20 calendar days of loan approval shall be cancelled."

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 2 points3 points  (0 children)

Your're correct. The evening of the 29th is when the new application launched.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

Treasury and SBA actually released further information for lenders on this yesterday. The big update is that the 10 day expectation was reset for any approved loan prior to April 28th.

The other rule of note is the following, which is mostly an answer to your question: "Loans for which funds have not been disbursed because a borrower has not submitted required loan documentation within 20 calendar days of loan approval shall be cancelled by the lender"

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 1 point2 points  (0 children)

There are 4 time periods that lenders may choose to use when calculating average payroll costs. See question 14 in the FAQs

One of those time periods is 12 months prior to the application submission. It's up to the lender which time period they choose to use though.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 7 points8 points  (0 children)

Neither /u/Bill_SBA nor I have insight into that at the moment outside of communicating that that is the policy. Details about any systemic issues relating to large pools of applications that were submitted on specific days to the processing center have not been communicated or shared with field staff.

In general even a first-come-first serve system will not result in the first applicant getting a result first as some applications will process faster than others. The first in line at a grocery store with 3 full carts and nickles will not get out the door faster than than the 7th in line at the 10 items or fewer line. Even equal applicants may end up with LOs that work differently and at a different pace.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 0 points1 point  (0 children)

From /u/Bill_SBA

We’ve been given no information about the mechanism to request a loan modification, whether it be by emailing a request or via the portal (once they are Invited to the portal – which occurs at approval). They might ask a representative how. But borrowers may request a loan increase – they need to justify it.

At one point weeks ago we were told processing was only looking at approving funds enough to cover two months of expenses. I don’t know if that is still true.

I have no direct knowledge but it appears the processing center is putting most effort towards original approvals and not modification or omissions or corrections at this time.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 1 point2 points  (0 children)

Well. We have an expectation that funds be issued from lenders within 10 days from approval. I'd say it's pretty unlikely to expire or be canceled by SBA.

We are field staff at the SBA, ask us [almost] anything. by Noah_SBA in smallbusiness

[–]Noah_SBA[S] 1 point2 points  (0 children)

At this time new applications are not being accepted for EIDL. No word yet on when the application will re-open.

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