Paycheck Protection Program (PPP) Loan Forgiveness
Frequently Asked Questions

The information contained in this page is based on laws, rules, regulations, and related guidance with respect to the Paycheck Protection Program (PPP), including updates based on the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act and guidance issued by the U.S. Small Business Administration (SBA). We will be updating this page with new information as we receive it. Please check back often and consider bookmarking this page. In the event of any discrepancies between the information on this site and the SBA’s site, please follow official SBA guidance.

About the PPP loan and loan forgiveness

What are the terms of the loan and are there any fees?

The term or period of the PPP loan is stated in your promissory note and is either two or five years.

The PPP loan will accrue interest at an annual rate of 1%.

No payment is due during the deferral period, which ends:

  1. On the date when the SBA makes a decision on your application for forgiveness, or;
  2. 10 months after the last day of the covered period, if you have not applied for forgiveness.

If your loan is forgiven, any interest accrued during the deferral period is eligible for forgiveness.

There is no penalty for loan pre-payment, however partial or full pre-payment may impact forgiveness.

After the deferral period, any balance that is not forgiven (including any accrued interest on the unforgiven portion) will become a term loan with monthly payments due up to the maturity date and with an annual interest rate of 1%.

For each payment of principal, interest, and/or fees that has not been paid in full within 15 (fifteen) days after its due date, you will be assessed a late charge of $15 or five percent (5%) of the amount due, whichever is greater.

There are no annual or documentation fees associated with the loan. However, if you are late on payments after the deferral period, you may be liable for late fees for any portion of the loan that is not forgiven.

You will receive a loan statement before any payment is due, so you can plan accordingly.

Please refer to the SBA site for more details on the covered period, the term of the loan and other loan forgiveness details.

What is the deferral period?

Your deferral period ends:

  1. On the date when the SBA makes a decision on your application for forgiveness, or;
  2. 10 months after the last day of the covered period, if you have not applied for forgiveness.

No payment of PPP loan principal, interest, and fees is due during the deferral period.

If you received your promissory note before June 5, 2020, it may indicate that your first payment is due 6 months from the date of the note. The PPP Flexibility Act (signed on June 5, 2020) extended the deferral period, so you can disregard the original 6 month period referenced in the promissory note.

You will receive a loan statement before any payment is due, so you can plan accordingly.

What are Economic Injury Disaster Loans (EIDL) and advances and how do they affect loan forgiveness?

Economic Injury Disaster Loans (EIDL) are direct loans, while EIDL advances are grants. The SBA set the maximum EIDL advance at $10,000. EIDL advances will no longer be deducted by the SBA from forgiveness amounts. You may be able to refinance EIDL loans funded between 1/31/2020 and 4/3/2020 with your first PPP loan. You cannot refinance an EIDL loan with a Second Draw PPP Loan. For any questions related to the SBA EIDL program, or to obtain an EIDL loan payoff amount, contact the SBA Disaster Loan Servicing Center at (800) 736-6048 or refer to the SBA.

Are PPP loans eligible for loan forgiveness?

PPP loans, in whole or in part, are eligible for loan forgiveness if funds were used for certain eligible business expenses. However, if you pay off your loan in full before you apply for forgiveness, you are no longer eligible for loan forgiveness. If part of the loan is not forgiven, you will be responsible to repay the amount not forgiven plus any accrued interest.

How does a change in ownership (e.g. merger, asset sale, stock sale, or transfer due to the death of a business owner) affect my PPP loan or loan forgiveness?

If you are considering a change of ownership for your business, which could include a merger, asset sale, stock sale or transfer due to the death of a business owner, please notify Wells Fargo as far in advance of the change of ownership transaction as possible. You will need to request prior approval from Wells Fargo before you initiate the change of ownership and provide a copy of the proposed change of ownership agreement and other relevant documents. If you do not obtain prior approval of any change of ownership, it will be considered a default event and may affect your ability to apply for PPP loan forgiveness.

To contact us about a change in ownership if you are a Wells Fargo Business Online ® user or a Wealth & Investment Management customer, please call 1-844-304-8911 . We will work with you to complete the process as quickly as possible, but we cannot make any assurances regarding the exact timing for completion of your request, due to the many variables involved.

Providing the requested documentation and responding to questions quickly ensures the best outcome. We anticipate that it will likely take a minimum of 30 days to fully complete the request. The timeframe will depend on our evaluation, your responsiveness during each step of the process, and applicable SBA requirements.

⁠Eligible expenses (payroll and nonpayroll)

What business expenses qualify for loan forgiveness?

To be eligible for loan forgiveness, the funds must be used for eligible costs incurred or paid during the covered period. You can choose a covered period of any length between 8-weeks (56 days) and 24-weeks (168 days), beginning on the date you received the loan proceeds.

Additional eligible costs were added as part of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, signed into law on December 27, 2020. These eligible costs are retroactive to any previous unforgiven PPP loans and include:

At least 60% of your total forgivable amount must be used for allowable payroll costs.

Refer to the SBA for a full list of eligible costs that can be forgiven under a PPP loan.

What is the covered period?

The covered period is the period in which loan funds must be used to qualify for loan forgiveness. You can choose a covered period of any length between 8-weeks (56 days) and 24-weeks (168 days), beginning on the date you received the loan proceeds.

Funds must be used for eligible costs incurred during the covered period.

Payroll costs for the covered period must be paid or incurred during the period to be eligible. If payroll costs are incurred during the last pay period within the covered period selected, but paid after the end of the covered period selected (but on or before the next regular payroll date), these payroll costs will still be eligible for forgiveness. (For example, this may happen when your pay cycle ended on the payday of Friday, October 2, but the covered period selected ended on October 1.)

Which types of payroll costs are eligible for loan forgiveness?

Eligible payroll costs include the following, if paid or incurred during the covered period:

Limitations for individual employees

The total amount of cash compensation eligible for forgiveness may not exceed a pro-rated annual salary of $100,000. This means the maximum you can claim for cash compensation is $46,154 for any individual employee during a 24-week covered period - the maximums are lower for periods of less than 24 weeks.

Eligible payroll costs are limited to employees whose principal place of residence is the United States. Payments to independent contractors are not eligible.

These caps relate to maximums that you can claim for cash compensation. In addition, borrowers may claim non-cash compensation for employer contributions for employee health insurance; employer contributions to employee retirement plans; and state and local taxes assessed on employee compensation, as explained in these FAQs.

Limitations for owner-employees, self-employed, and general partners

Compensation for owner-employees, self-employed individuals and general partners are also eligible for loan forgiveness based on certain PPP compensation formulas, and based on their business type.

For PPP, an owner-employee is defined as an owner who is also an employee (including where the owner is the only employee). Owner-employees with a less than 5% ownership stake in a C-corps or S-corps are not subject to the owner-employee compensation limitation.

Owner compensation falls under “Payroll costs”, and for a 24-week covered period it is capped at the lesser of 2.5 months of $100,000 annualized ($20,833) or 2.5 months of compensation, in the year that was used to calculate the loan amount (2019 or 2020) across all businesses in which they have an ownership stake - the maximums are lower for periods of less than 24 weeks. The PPP compensation formulas varies based on business type, as explained:

For self-employed individuals

If filing IRS 1040 Schedule C (or Schedule F), forgiveness is capped at 2.5 times the monthly net profit/loss in the year that was used to calculate the loan amount (2019 or 2020), as shown on Schedule C, line 31 (or Schedule F, line 34). Note that if your net profit in the year that was used to calculate the loan amount (2019 or 2020) was a net loss, the forgiveness amount will be zero.

For general partners

Forgiveness is capped at 2.5 months x the monthly self-employment earnings in the year that was used to calculate the loan amount (2019 or 2020) and as shown on IRS 1065 Schedule K-1 line 14a (reduced by Sec. 179 deduction, unreimbursed partnership expenses, and depletion from oil and gas properties) and multiplied by 0.9235, subject to a maximum of $20,833 per owner for a 24-week covered period - the maximums are lower for periods of less than 24 weeks. Only compensation paid during the covered period is eligible for loan forgiveness. Documentation of such payments do not need to be provided to the lender.

No additional forgiveness is available for retirement or health insurance contributions for self-employed individuals or general partners.

If you are in a general partnership and did not submit 2019 IRS Form 1065 K-1s when you initially applied for the PPP loan, you will need to include it with your forgiveness application.

For owner-employees of S-corps

The employee cash compensation of an S-corp owner-employee, defined as an owner who is also an employee, is also eligible for loan forgiveness up to a maximum of 2.5 months x their monthly employee cash compensation in the year that was used to calculate the loan amount (2019 or 2020). As explained previously, for a 24-week covered period the maximum forgiveness is $20,833 per owner - the maximums are lower for periods of less than 24 weeks.

You can also claim forgiveness for payments for employer state and local taxes paid by the borrower and assessed on the owner-employee’s compensation, and for employer retirement contributions to owner-employee retirement plan capped at the amount of 2.5x their monthly employer retirement contribution in the year that was used to calculate the loan amount (2019 or 2020).

These eligible non-cash compensation payments should be included on lines 7 and 8 of PPP Schedule A, Form 3508 or line 1 of Form 3508EZ, and do not count toward the $20,833 cap per individual owner. If you use Form 3508S, you will enter all eligible payroll and nonpayroll costs on a single line.

Employer contributions for health insurance are not eligible for additional forgiveness for S-corp employees having at least a 2% stake in the business.

To claim forgiveness, you must submit payroll documents detailing cash compensation paid to owner-employee(s) during the covered period selected, up to the eligible amount stated previously. Payments other than for cash compensation should be included on lines 6 through 8 of PPP Schedule A of the loan forgiveness application and do not count toward the $20,833 cap per individual.

For owner-employees of C-corps

The employee cash compensation of a C-corp owner-employee, defined as an owner who is also an employee, is eligible for loan forgiveness up a maximum of 2.5 x their monthly employee cash compensation in the year that was used to calculate the loan amount (2019 or 2020). For a 24-week covered period the maximum forgiveness is $20,833 per owner - the maximums are lower for periods of less than 24 weeks.

You can also claim forgiveness for payments for employer state and local taxes paid by the borrower and assessed on owner-employee compensation, for the amount paid by the borrower for employer contributions for owner-employee health insurance, and for employer retirement contributions to owner-employee retirement plan capped at the amount of 2.5x their monthly employer retirement contribution in the year that was used to calculate the loan amount (2019 or 2020).

To claim forgiveness, you must submit payroll documents detailing cash compensation paid to owner-employee(s) during the covered period selected, up to the eligible amount stated previously. Payments other than for cash compensation should be included on lines 6 through 8 of PPP Schedule A, of Form 3508 or line 1 of Form 3508EZ, and do not count toward the $20,833 cap per individual. If you use Form 3508S, you will enter all eligible payroll and nonpayroll costs on a single line.

In all cases

Owner compensation for a 24-week covered period is capped $20,833 (not to exceed 2.5 months of compensation in the year that was used to calculate the loan amount (2019 or 2020) across all businesses in which they have an ownership stake - the maximums are lower for periods of less than 24 weeks. Note that owner-employees with less than 5% ownership stake in C-or S-corps are not subject to these caps, but are still subject to the general employee limitation of $46,154 per employee during a 24-week covered period - the maximums are lower for periods of less than 24 weeks.

These caps relate to maximums that you can claim for cash compensation. In addition, borrowers may claim non-cash compensation for employer contributions for employee health insurance; employer contributions to employee retirement plans; and state and local taxes assessed on employee compensation, as explained in these FAQs.

Are health care and retirement benefits paid by the employer eligible costs for loan forgiveness?

For employees

Health care and retirement benefits paid or incurred during the covered period are eligible for forgiveness as payroll costs. Expenses paid by employees for such benefits are not eligible for forgiveness. Expenses for future periods that are accelerated into the covered period are also not eligible for forgiveness.

For self-employed individuals and general partners

Employer health insurance contributions and employer retirement contributions made on behalf of self-employed individuals or general partners are not eligible expenses.

For owner-employees of S-corps

Employer health insurance contributions are not included for owners (and their family members) having at least a 2% stake of an S-corp. Employer retirement contributions made on behalf of an owner-employee of an S-corp are eligible and do not count toward the cash compensation cap of $20,833 per individual, and are capped at the amount of 2.5x their monthly employer retirement contribution in the year that was used to calculate the loan amount (2019 or 2020).

For owner-employees of C-corps

Employer health insurance contributions and retirement contributions are eligible expenses. Retirement costs are capped at 2.5 x monthly employer retirement contribution in the year that was used to calculate the loan amount (2019 or 2020). These payments do not count toward the $20,833 cap per individual.

Can I use PPP fund to pay employees who are not currently able to work due to business being closed or for any other reason?

If you are not able to operate or are operating at a limited capacity when the PPP loan proceeds are received, you may choose to pay employees who are not able to work. This may help you maximize loan forgiveness, as current SBA guidance states that at least 60% of loan forgiveness must be attributable to payroll costs.

Are there caps or exclusions from the definition of payroll costs or owner compensation?

You must exclude the following:

Also, the compensation of any individual employee is capped at an annual salary of $100,000, which translates to $46,154 per employee during a 24-week covered period - the maximums are lower for periods of less than 24 weeks.

For a 24-week covered period, the maximum amount of loan forgiveness you can claim as compensation for owner-employees, self-employed individuals and general partners is the lower of 2.5 months of compensation earned in the year that was used to calculate the loan amount (2019 or 2020) or $20,833, which is the 2.5-month equivalent of $100,000 per year - the maximums are lower for periods of less than 24 weeks.

Remember, in order to be eligible for 100% loan forgiveness, at least 60% of the PPP loan must be used for eligible payroll costs.

If you apply early, before the end of the covered period, the same pro-rated maximum applies. This means if you apply after the 16th week (as an example), the maximum you can claim for cash compensation for any individual employee will be $100,000/52 x 16 weeks = $30,769.

These caps relate to maximums that you can claim for cash compensation. In addition, borrowers may claim non-cash compensation for employer contributions for employee health insurance; employer contributions to employee retirement plans; and state and local taxes assessed on employee compensation, as explained in the FAQs.

What type of nonpayroll costs are eligible for loan forgiveness?

Eligible nonpayroll costs include:

Additional eligible costs were added as part of the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, signed into law on December 27, 2020. These eligible costs are retroactive to any previous unforgiven PPP loans and include:

To be eligible, nonpayroll costs must be paid during the covered period, or incurred during the covered period and paid on or before the next regular billing date, even if the billing date is after the covered period.

Self-employed individuals must have claimed or be entitled to claim a deduction for these nonpayroll expenses on your Form 1040 Schedule C (or Schedule F) in order to claim them as expenses eligible for loan forgiveness.

Rent payments to a related party are eligible for loan forgiveness, but limited to no more than the amount of mortgage interest owed on the property during the Covered Period that is attributable to the space being rented by the business.

While rent or lease payments to a related party may be eligible for forgiveness, mortgage interest payments to a related party are not eligible for forgiveness.

For home-based businesses, you may only include the share of covered nonpayroll expenses that were deductible on your tax filings in the year that was used to calculate the loan amount (2019 or 2020).

Potential reductions in loan forgiveness and details on Safe Harbor

Are there possible reductions to my PPP loan forgiveness amount?

Forgiveness is based in part on maintaining employees and maintaining wages paid, or rehiring and reinstating employee wage levels, if previously reduced. To maximize forgiveness, you may choose to rehire and restore wages sooner to increase eligible payroll costs that fall into the covered period.

If you had a reduction in full-time equivalency (FTE) or wage level, your forgiveness amount may be reduced. You may be exempt from these reductions if you restored FTE and wage levels on or before December 31, 2020 (or, for a PPP loan made after December 27, 2020, the last day of the Covered Period). These two types of reductions and exemptions, including Safe Harbors are explained in the Safe Harbor FAQ.

You may also be exempt from these reductions if you can document that you are not able to rehire employees or hire replacement employees for unfilled positions or cannot return to normal business activities because of COVID related safety requirements.

How do I determine if I have had an FTE reduction?

Loan forgiveness may be reduced if the number of average weekly FTE employees during the covered period was less than during the FTE reduction reference period selected.

You can select an FTE reduction reference period of either:

You are exempt from such a reduction if the FTE Reduction Safe Harbor applies. Safe Harbors are explained in the Safe Harbor FAQ.

You may be exempt from these reductions if you restored FTE on or before December 31, 2020 (or, for a PPP loan made after December 27, 2020, the last day of the Covered Period).

You may also be exempt from these reductions if you can document that you are not able to rehire employees or hire replacement employees for unfilled positions or cannot return to normal business activities because of COVID related safety requirements.

What does full-time equivalency (FTE) employee mean?

Full-time equivalency (FTE) employee generally means an employee who works 40 hours or more, on average, each week. For part-time employees who work less than 40 hours, calculate their FTE as a proportion of 40 hours. For example, if an employee worked 32 hours per week on average, the employee should be counted as 0.8 FTE. Alternatively, SBA offers a simplified method that assigns all part-time employee as 0.5, if that is preferable.

Only employees whose place of residence is in the United States should be included.

When counting FTE reductions, you will not be penalized for:

In these cases, loan forgiveness will not be reduced.

How would an FTE reduction affect my PPP loan forgiveness?

In general, your loan forgiveness is reduced by the same percentage as the percentage reduction in FTE employees. This is calculated by comparing the average weekly FTE employees during the covered period with the FTE reduction reference period selected.

For example, if you had 10.0 FTE employees during the FTE reduction reference period and this declined to 8.0 FTE employees during the covered period, the percentage of FTE employees declined by 20%, and therefore only 80% of otherwise eligible expenses will be forgiven.

You are exempt from such a reduction if the FTE Reduction Safe Harbor applies. Safe Harbors are explained in the Safe Harbor FAQ.

You may be exempt from these reductions if you restored FTE on or before December 31, 2020 (or, for a PPP loan made after December 27, 2020, the last day of the Covered Period). These types of reductions and exemptions, including Safe Harbors are explained in the Safe Harbor FAQ.

You may also be exempt from these reductions if you can document that you are not able to rehire employees or hire replacement employees for unfilled positions, as explained in the Safe Harbor FAQ.

When calculating FTE reduction, you must include all employees (including those earning more than $100,000).

If you've terminated an employee during the covered period, your FTE count will be impacted if you don’t rehire them or don’t have an exemption reason. If an employee was terminated for cause, voluntarily resigned, or voluntarily requested a reduction of hours, you may count that employee at the same FTE level as before.

How does the FTE Reduction Safe Harbor work?

The Safe Harbor exempts or protects you from the reduction in loan forgiveness due to decrease in FTE employee levels. You are exempt from the reduction in loan forgiveness if both of the following conditions are met:

You may also be exempt from these reductions if you can document that you are not able to rehire employees or hire replacement employees for unfilled positions or cannot return to normal business activities because of COVID related safety requirements.

Will forgiveness be reduced if I laid-off or reduced the hours of an employee, but then offered to rehire the same employee for the same salary and same number of hours?

No. If you offered to rehire or offered to restore the employee’s hours at the same salary or wages, you will not have an FTE reduction for that employee.

In calculating your PPP loan forgiveness amount, you may exclude any reduction in FTE employee headcount attributable to a particular employee if:

You may also be exempt from these reductions if you can document that you are not able to rehire employees or hire replacement employees for unfilled positions or cannot return to normal business activities because of COVID related safety requirements.

If I had a reduction in employees’ salary or wages, or terminated an employee, how does that affect my PPP loan forgiveness?

Loan forgiveness may be reduced when there was a reduction in an employee’s salary or wages from January 1, 2020 to March 31, 2020, (the salary reduction reference period) in excess of 25%, unless an exception applies. There is a salary or hourly wage reduction safe harbor if you restored salary/wage levels on or before December 31, 2020 (or, for a PPP loan made after December 27, 2020, the last day of the Covered Period).

For each person employed during the covered period selected, start with the employee’s average annual salary or hourly wage during the covered period selected, and calculate whether that employee had a reduction in excess of 25% compared to the salary reduction reference period. Do not count the salary reduction for employees who were already counted in the FTE reduction.

For more details on the salary reduction calculations, please refer to the directions on page 4 of Form 3508 Loan Forgiveness Application Instructions. No salary reduction calculations are required if you’re using Form 3508S or Form 3508EZ.

This salary reduction penalty does not apply for any employee who was paid more than an annualized equivalent of $100,000 in any pay period in the year that was used to calculate the loan amount (2019 or 2020).

In summary, if the average annual salary or hourly wage for each employee working during the covered period selected was at least 75% of their average annual salary or hourly wage in the salary reduction reference period, there is no salary/hourly wage reduction.

Will forgiveness be reduced if I restored an employee’s salary or wage reductions?

No. If certain employee salaries and wages were reduced between February 15, 2020 and April 26, 2020, (the Safe Harbor period), but those reductions were eliminated on or before December 31, 2020 (or, for a PPP loan made after December 27, 2020, the last day of the Covered Period), you are exempt from any reduction in loan forgiveness due to those reductions in salaries and wages.

What am I required to confirm or certify as part of my PPP loan forgiveness application?

On the PPP forgiveness application, you or an authorized representative must certify to all of the following:

For a full description of the certifications, please refer to Form 3508S, Form 3508EZ, or Form 3508 found on the SBA site.