The first IFR (RIN 1505-AC69) provides guidance on obtaining PPP loan forgiveness and clarifies the instructions for the Forgiveness Application (Form 3508). The most significant provisions of the IFR are that the SBA permits the use of bonuses and hazard pay and allows the use of PPP loan proceeds for costs paid or incurred during the covered period. Other items contained in the IFR are described below.
The second IFR (RIN 3245-AH47) involves lender requirements if the SBA reviews a loan or Forgiveness Application and that lenders will not be entitled to loan processing fees for any PPP loan where the borrower is found to be ineligible by the SBA – the lender will be required to repay the SBA any fees previously paid. Other details of the IFR are noted below.