Skip to main content Download Acrobat Reader 5.0 or higher to view PDF files.

Paycheck Protection Program Documentation Checklist


This Documentation Checklist is subject to change as the SBA provides more guidance. It will be regularly updated to reflect the current SBA requirements. This current documentation checklist aligns with the SBA’s requirements in the official Forgiveness Application.

We have also provided a list of optional documents that we suggest borrowers maintain should further detailed record-keeping become required.

Please note: You will be responsible for documenting your payroll, lease/mortgage interest, and utilities expenses for the duration of your Covered Period starting on the day the PPP funds were deposited to your account.

Rockland Trust will be responsible for assembling and submitting the request to the SBA. During our assembly of your request, we may identify issues with your request or documentation and if so, we will promptly notify you. If no issues exist and no additional documentation is needed, we will promptly submit the request to the SBA for the final forgiveness determination.

Please note, this guidance is subject to change based on further guidance published by the Treasury and SBA. We will endeavor to update this page to reflect additional guidance, however make no commitment to do so, and recommend visiting the SBA website(Opens in a new Window) to learn of any changes that occur.



Below is an overview of the required documentation for the PPP Forgiveness process. We’ll go through the:

We encourage you to review this to understand the requirements and process for submitting your Forgiveness application with Rockland Trust.


General Requirements

Borrowers completing the 3508S form are not required to submit documentation supporting their forgiveness calculation at the time of forgiveness application. However, borrowers are still required to follow program requirements when calculating their forgiveness amount and must retain all payroll documentation for four (4) years and all other documentation for three years. Documentation retained may include some of the documentation listed below.

Borrowers completing the 3508EZ or 3508 are required to submit specific documentation from the list below for cost categories that were used to calculate their requested forgiveness amount. Other documentation must be maintained but not submitted at the time of forgiveness application.  

For each category of eligible payroll and non-payroll costs, in general, the following is required.

  • Summary of expenditures in the category
  • Detailed support for expenditures in the category
  • Evidence of payment

 

Payroll: To help you organize your payroll before submitting for Forgiveness, we’ve created a PPP Payroll Summary Workbook that can be downloaded here.

You will need to submit documentation verifying the eligible cash compensation and non-cash benefit payments from the Covered Period (or Alternative Payroll Covered Period) consisting of each of the following:

Payroll Costs

  1. Payroll
    • Employee Compensation: an official third-party payroll provider report summarizing payroll from the Covered Period for each employee or an internal summary report showing aggregate compensation for each employee during the Covered Period with a total that corresponds to the amount for employee compensation on your application. Appropriate caps on employee compensation should be applied
    • Owner Compensation: a summary report showing amounts paid to each owner during the Covered Period with a total that corresponds to the amounts on your application for owner compensation and bank statements or cancelled checks documenting what the owner received during the Covered Period. A Schedule C federal tax return or W-2/K-1 related to income for each owner will also need to be provided to support the appropriate caps were applied on owner compensation  

  2. Payroll Tax Forms: Tax forms for the periods that overlap with the Covered Period (or Alternative Payroll Covered Period)
    • Payroll tax filings reported, or that will be reported, to the IRS; and
    • State quarterly business and individual employee wage reporting and unemployment insurance tax filings reports, or that will be reported, to the relevant state
    • For sole proprietors, the Schedule C tax form for the year that was used to calculate the loan amount

  3. Health Insurance and Retirement Contributions: Documentation supporting employer contributions included in the forgiveness amount to health insurance and retirement plans including receipts, cancelled checks or account statements.

  4. FTE Documentation:
    • 3508S Application
      • Borrowers that received a PPP loan of $150,000 or less and Borrowers of $150,000 or less that together with their affiliates received First Draw PPP Loans totaling $2 million or more or Second Draw PPP Loans totaling $2 million or more must adjust their “Requested Loan Forgiveness Amount” due to statutory requirements concerning reductions in either FTE employees or employee salary and wages.
      • Borrowers with loans over $150,000 and together with affiliates received First Draw PPP loan totaling $2 million or more or Second Draw PPP loans totaling $2million or more must also retain documentation supporting their FTE calculations. FTE documentation is not required to be submitted with the forgiveness application but should be maintained.
    • 3508EZ Application
      • FTE documentation is only required from borrowers who check the second option to qualify for the EZ form on the application, which reads as follows:
        • The Borrower did not reduce annual salary or hourly wages of any employee by more than 25 percent during the Covered Period or the Alternative Payroll Covered Period compared to the period between January 1, 2020 and March 31, 2020 (for purposes of this statement, “employees” means only those employees that did not receive, during any single period during 2019, wages or salary at an annualized rate of pay in an amount more than $100,000); and

          The Borrower was unable to operate during the Covered Period at the same level of business activity as before February 15, 2020, due to compliance with requirements established or guidance issued between March 1, 2020 and December 31, 2020 (or, for a PPP loan made after December 27, 2020, requirements established or guidance issued between March 1, 2020 and the last day of the Covered Period) by the Secretary of Health and Human Services, the Director of the Centers for Disease Control and Prevention, or the Occupational Safety and Health Administration, related to the maintenance of standards of sanitation, social distancing, or any other work or customer safety requirement related to COVID-19.
    • If the borrower selected the second option to qualify for the EZ form, they would need to provide the following to support FTE calculations
      • 2019 Q4 941 tax filings, or a third-party payroll provider report for the first pay period of 2020 AND
      • Summary report of FTE for the end of the Covered Period showing the number of FTE employees
      • FTE calculations on summary reports should calculate an employee’s FTE by taking the average number of hours worked per week during the Covered Period divided by 40 for each employee
      • Tax documents may include payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941) and state quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported, to the relevant state. Documents submitted may cover periods longer than the specified time period.

    • 3508 Standard Application
      • Documentation for the Covered Period
      • A summary report for FTE for the end of the Covered Period showing the number of FTE employees
      • Tax documentation showing the number of employees on payroll at the end of the Covered Period
      • Documentation for the borrower’s chosen Reference Period
      • A summary report calculating the average number of FTE employees on payroll per month employed by the Borrower between February 15, 2019, and June 30, 2019
      • A summary report calculating the average number of FTE employees on payroll per month employed by the Borrower between January 1, 2020, and February 29, 2020; or
      • In the case of a seasonal employer, a summary report calculating the average number of FTE employees on payroll per month employed by the Borrower between February 15, 2019, and June 30, 2019; between January 1, 2020, and February 29, 2020; or any consecutive twelve-week period between February 15, 2019, and February 15, 2020
      • Tax documentation showing the number of employees on payroll during the reference period
    • FTE calculations on summary reports should calculate an employee’s FTE by taking the average number of hours worked per week during the Covered Period divided by 40 for each employee
    • Tax documents may include payroll tax filings reported, or that will be reported, to the IRS (typically, Form 941) and state quarterly business and individual employee wage reporting and unemployment insurance tax filings reported, or that will be reported, to the relevant state. Documents submitted may cover periods longer than the specified time period.


Nonpayroll Costs

  1. Business mortgage interest payments:
    1. Copy of lender amortization schedule and receipts or cancelled checks verifying eligible payments from the Covered Period; or
    2. Lender account statements from February 2020; and
    3. Lender account statements the months of the Covered Period through one month after the end of the Covered Period verifying interest amounts and eligible payments

  2. Business rent or lease payments:
    1. Copy of current lease agreement and receipts or cancelled checks verifying eligible payments from the Covered Period; or
    2. Lessor account statements from February 2020; and
    3. Lessor account statements from the Covered Period through one month after the end of the Covered Period verifying eligible payments

  3. Related Party Leases
    1. The SBA announced that rent and lease payments to businesses with any common ownership are eligible for loan forgiveness, but the amount of the loan forgiveness is limited to no more than the amount of mortgage interest paid on the property during the Covered Period that is attributable to the space being rented, and that the lease and the underlying mortgage were entered into prior to February 15, 2020.
    2. If your business is under a common ownership, you will need to ensure the amount you are requesting for Business Rent or Lease Payments is no more than the amount of mortgage interest paid on the property. Please provide the appropriate documentation supporting these calculations. The documentation required must also include evidence of the amounts actually paid.

  4. Business utility payments:
    1. Copy of invoices from February 2020; and
    2. Copy of invoices paid during the Covered Period; and
    3. Receipts, cancelled checks, or account statements verifying those eligible payments
  5. Operations software expenditures
    1. Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments.
  6. Supplier costs
    1. Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, and, for non-perishable goods, copies of related contracts, orders, or purchase orders in effect prior to the Covered Period.
  7. Worker protection expenditures
    1. Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, as well as documentation that the expenditures were used by the Borrower to comply with applicable COVID-19 guidance during the Covered Period.
  8. Property damage costs:
    1. Copy of invoices, orders, or purchase orders paid during the Covered Period and receipts, cancelled checks, or account statements verifying those eligible payments, as well as documentation that the costs were related to property damage and vandalism or looting due to public disturbances that occurred during 2020 and such costs were not covered by insurance or other compensation.

If you provide bank statements or reports to support your payroll or non-payroll expenditures, please circle the appropriate items on the statement to make the relevant costs easily identifiable.


Second Draw Loans Only

  1. Documentation showing the borrower’s certification of a 25% reduction in gross receipts for at least one quarter in 2020 relative to the same quarter in 2019
  2. Documentation may include the following:
    1. Preferred Method – Quarterly financial statements for the entity. If the financial statements are not audited, the Applicant must sign and date the first page of the financial statement and initial all other pages, attesting to their accuracy. If the financial statements do not specifically identify the line item(s) that constitute gross receipts, the Applicant must annotate which line item(s) constitute gross receipts
    2. Quarterly or monthly bank statements for the entity showing deposits from the relevant quarters. The applicant must annotate, if it is not clear, which deposits listed on the bank statement constitute gross receipts (e.g., payments for purchases of goods and services) and which do not (e.g., capital infusions)
    3. Annual IRS income tax filings of the entity (required if using an annual reference period).


Documentation that Must be Retained but Not Submitted with the Forgiveness Application:

  1. 3508S Form
    1. All Records: All records relating to the Borrower’s PPP loan, including documentation submitted with its PPP loan application, documentation supporting the Borrower’s certifications as to its eligibility for a PPP loan (including the Borrower’s gross receipt reduction certification for a Second Draw PPP Loan, if applicable), documentation necessary to support the Borrower’s loan forgiveness application, and documentation demonstrating the Borrower’s material compliance with PPP requirements.
  2. 3508EZ and 3508 Standard Applications
    1. PPP Loan Documentation: All records relating to the Borrower’s PPP loan, including documentation submitted with its PPP loan application, documentation supporting the Borrower’s certifications as to the necessity of the loan request and its eligibility for a PPP loan (including the Borrower’s gross receipt reduction certification for a Second Draw PPP Loan, if applicable), documentation necessary to support the Borrower’s loan forgiveness application, and documentation demonstrating the Borrower’s material compliance with PPP requirements.
    2. FTE Reduction Exceptions: Documentation regarding any employee job offers and refusals, refusals to accept restoration of reductions in hours, firings for cause, voluntary resignations, written requests by any employee for reductions in work schedule, and any inability to hire similarly qualified employees for unfilled positions on or before (i) December 31, 2020 for a PPP loan made before December 27, 2020 or (ii) the last day of the Covered Period for a PPP loan made after December 27, 2020.
    3. COVID-19 Operations Restrictions: Documentation supporting the certification, if applicable, that the Borrower was unable to operate between February 15, 2020, and the end of the Covered Period at the same level of business activity as before February 15, 2020 due to compliance with requirements established or guidance issued between March 1, 2020 and December 31, 2020 (or, for a PPP loan made after December 27, 2020, requirements established or guidance issued between March 1, 2020 and the last day of the Covered Period
  3. 3508 Standard Application Only
    1. PPP Schedule A or its equivalent
    2. Documentation supporting the listing of each individual employee in PPP Schedule A Worksheet Table 1, including the “Salary/Hourly Wage Reduction” calculation, if necessary.
    3. Documentation supporting the listing of each individual employee in PPP Schedule A Worksheet Table 2; specifically, that SBA Form 3508 (01/21) Page 8 Paycheck Protection Program Loan Forgiveness Application Form 3508 Revised January 19, 2021, OMB Control No.: 3245-0407 Expiration Date: 7/31/2021 each listed employee received during any single pay period in 2019 compensation at an annualized rate of more than $100,000
    4. Documentation supporting the PPP Schedule A Worksheet “FTE Reduction Safe Harbor 2”.

If you have any questions, contact your relationship manager or our Customer Information Center at 508.732.3826.
 
Back to Top

<< Back to Paycheck Protection Guidance