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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 eight-week or 24-week 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 as well as the Forgiveness Request Process page to understand the requirements and process for submitting your Forgiveness application with Rockland Trust.


General Requirements

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
  • For costs other than compensation, evidence the services, loans or leases were in place as of February 15, 2020

 

3508 EZ Form

To learn more about whether you might qualify for the EZ form, please review the EZ Forgiveness Application Eligibility section of our website. 

Forms and Schedules:

  1. PPP Loan Forgiveness Calculation Form 3508EZ

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:

  1. Payroll Reports: Bank account payments or third-party payroll service provider reports documenting the amount of cash compensation paid to employees

  2. Tax Forms: Tax forms for the periods that overlap with the Covered Period (or Alternative Payroll Covered Period)
    1. Payroll tax filings reported, or that will be reported, to the IRS; and
    2. State quarterly business and individual employee wage reporting and unemployment insurance tax filings reports, or that will be reported, to the relevant state

  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: Documentation supporting the average number of full-time equivalent employees on payroll employed by the borrower on January 1, 2020 and at the end of the Covered Period
    1. 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 did not reduce the number of employees or the average paid hours of employees between January 1, 2020 and the end of the Covered Period. (Ignore reductions that arose from an inability to rehire individuals who were employees on February 15, 2020 if the Borrower was unable to hire similarly qualified employees for unfilled positions on or before December 31, 2020. Also ignore reductions in an employee’s hours that the Borrower offered to restore, and the employee refused.)


Nonpayroll:
Documentation verifying the existence of the obligations/services prior to February 15, 2020 and eligible payments from the Covered Period

  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

If you provide 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.

 

Standard Form

Forms and Schedules:

  1. PPP Loan Forgiveness Calculation Form
  2. PPP Schedule A

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:

 

  1. Payroll Reports: Bank account statements or third-party payroll service provider reports documenting the amount of cash compensation paid to employees

  2. Tax forms: Tax forms for the periods that overlap with the Covered Period (or the Alternative Payroll Covered Period)
    1. Payroll tax filings reported, or that will be reported, to the IRS; and
    2. State quarterly business and individual employee wage reporting and unemployment insurance tax filings reports, or that will be reported, to the relevant state

  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: Documentation showing (at the election of the borrower)
    1. Traditional employer
      1. The average number of FTE employees on payroll per week employed by the Borrower between February 15, 2019 and June 30, 2019; or
      2. The average number of FTE employees on payroll per week employed by the Borrower between January 1, 2020 and February 29, 2020;

    2. Seasonal employer
      1. The average number of FTE employees on payroll per week employed by the Borrower between February 15, 2019 and June 30, 2019; or
      2. The average number of FTE employees on payroll per week employed by the Borrower between January 1, 2020 and February 29, 2020; or
      3. Any consecutive 12-week period between May 1, 2019 and September 15, 2019

    3. Documents may include 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 reported, or that will be reported, to the relevant state. Documents submitted may cover periods longer than the specific time period.

  1. FTE Safe Harbor Provision
    1. Paycheck Protection Flexibility Act expands the Safe Harbor for rehiring employees by allowing that forgiveness will not be affected by a reduction in employees if the borrower is able to document the following:
      1. its inability to return to the same level of business activity as it was operating at before February 15, 2020, due to compliance with Covid-19 requirements, or
      2. its inability to rehire individuals who were employees on February 15, 2020, or
      3. its inability to hire similarly qualified employees for unfilled positions on or before December 31, 2020.

    2. If you meet the requirements of the Safe Harbor Provision, you will need to formally document the circumstance in order to be exempt from forgiveness reductions due to the situation

Nonpayroll: Documentation verifying existence of the obligations/services prior to February 15, 2020 and eligible payments from the Covered Period

 

  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

 

If you provide a 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.

 

Sole Proprietors

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:

  1. Payroll Reports: Bank account payments or third-party payroll service provider reports documenting the amount of cash compensation paid during the Covered Period (or Alternative Payroll Covered Period)
    1. Sole Proprietors may pay themselves out of the PPP loan funds to compensate any lost profit due to the effects of the Pandemic. Documentation of this payment may include cancelled checks or ACH credit transactions out of the PPP loan account.
    2. It should be noted that forgiveness amounts for sole proprietors and owner’s compensation are limited to no more than $15,385 for an 8-week Covered Period, or for a 24-week Covered Period no more than 2.5 months of 2019 Schedule C net profit subject to a cap of $20,833.

  2. Tax Forms: Tax forms for the periods that overlap with the Covered Period (or Alternative Payroll Covered Period)
    1. Payroll tax filings reported, or that will be reported, to the IRS; and
    2. State quarterly business and individual employee wage reporting and unemployment insurance tax filings reports, or that will be reported, to the relevant state; and
    3. 2019 Form 1040 Schedule C

Nonpayroll: Documentation verifying the existence of the obligations/services prior to February 15, 2020 and eligible payments from the Covered Period. For nonpayroll expenditures, Sole Proprietors must have claimed or be entitled to claim a deduction for such expenses on their 2019 Form 1040 Schedule C for them to be a permissible use during the Covered Period or Alternative Payroll Covered Period.

 

  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

 

If you provide 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.

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