So the first wave of 1502 reporting is over. SBA Procedural Notice 5000-20028 was effective May 21, 2020, and required the initial Paycheck Protection Program 1502 Report to be submitted by May 29, 2020. Deadline met. So can you relax and wait for the PPP processing fee to be paid?
The Next Wave is Coming Fast. Get Ready. The first wave of reporting is over. What’s next? Let’s do a quick recap:
- For lenders that continue to process PPP applications, funds are still available. Note: Fully disbursed PPP loans must be reported to Colson Services within 10 calendar days of full disbursement.
- Lenders must continue to report all previously approved but cancelled PPP loans within 10 calendar days of cancellation.
- Fully disbursed or cancelled PPP loans can be reported on the same 1502 Report.
- Note: Cancelled loans also can be reported in E-Tran-Servicing.
- Reporting cancelled loans includes cancellations before initial disbursement, and after disbursement, loans that are cancelled or voluntarily terminated and repaid.
- If a cancelled loan is reported in E-Tran-Servicing, it should not also be reported on the 1502 Report.
Time to Relax? Not Yet:
- Lenders must continue to report PPP loans on a monthly basis regardless of whether the borrower made a payment in the current month. Remember, all PPP loan payments are deferred for 6 months.
- Lenders must continue to report PPP loans until the lender informs SBA that the loan is paid in full.
- For loans that are fully forgiven, lenders must report the loans as paid in full on the 1502 Report.
- If a balance remains after forgiveness, the lender must continue to report the loan and its current balance according to PPP requirements.
At JRB, 1502 Reporting is one of my specialties. I encourage you to read Procedural Notice 5000-20028 in its entirety. Feel free to contact me if you need assistance. From all of us at JRB, stay calm, stay safe.