Paycheck Protection Program

The Small Business Administration Is No Longer Accepting New Paycheck Protection Program Loan Applications From Most Lenders, Including Comerica.

The Small Business Administration (SBA) has allocated its current program funding and is no longer processing Paycheck Protection Program (PPP) loan origination applications for non-community financial institution (CFI) lenders. In this case, CFI lenders are defined as community development financial institutions (CDFIs), community banks, credit unions and farm credit institutions with $1 billion or less in assets.

Some funds are currently set aside specifically for CFI lenders, which may be able to process a new loan request for you if your business meets their criteria. The program expiration for these lenders remains whichever comes first – May 31, 2021, or the exhaustion of their funds – so time is of the essence.

If you submitted a PPP loan application to Comerica but have not received an SBA loan approval yet, please monitor your email for updates. The SBA has informed us that applications that were in progress with the SBA when funds were exhausted will be reviewed, decided on and funded by the SBA based on funds availability and priority.

Stay informed by visiting SBA.gov or the U.S. Department of Treasury website.

 

Since the PPP was launched last spring, Comerica has helped our customers receive nearly 20,000 PPP loans. More than 1,000 Comerica colleagues have been hard at work supporting the PPP loan program. Our mission is to help customers in their efforts to keep their businesses open and their workforces intact.

Visit our PPP Highlights pages for more details on Comerica’s PPP funding efforts for 2020 and 2021 and all the ways we have helped our customers obtain these crucial loans.

 

Notification of Fraud Risk

On December 1, 2020, the SBA released detailed information about recipients of Paycheck Protection Program loans, Economic Injury Disaster Loans (EIDL) and Economic Injury Disaster Loan Advances. Unfortunately, when information like this is released publicly, there is often an increase in fraud attempts.

According to the SBA, some borrowers have received emails claiming to be from the SBA and threatening collection action against borrowers whom the email says failed to repay PPP loans by May 7, 2020. Some borrowers have also received emails asking for information under the pretext of a supposed “file review” by the SBA.

If you receive any email like this that does not come from an SBA.gov or Comerica.com address, the email is fraudulent.

PPP Loan Origination FAQ

 

General Program Questions

 

1) Why is it taking the SBA so long to process my PPP application?

The SBA is processing applications against different criteria in this round. When there is a mismatch in this data, the SBA returns a “hold code” back to the lender, and the applicant cannot receive SBA approval or a loan number until all hold codes are cleared.

We have a team that is dedicated exclusively to working on these error codes. We can resolve some of them on our own, while others necessitate contacting the applicant using the Message Center in the portal for follow-up information. For a list of hold codes and the resolution for each, you can review the SBA’s “Unresolved Borrower Resolution Process for Second Draw PPP Loans” document.

 

2) What should I do if I need to upload corrected supporting documents for my application, but the placeholder is full?

You can use one of the “Optional” placeholders.

 

3) I have been requested to provide a statement or affidavit to support my application. Can you please provide a sample form?

    The SBA has not provided specific guidelines or forms for these documents, outside of the “Unresolved Borrower Resolution Process for Second Draw PPP Loans” document. Because Comerica is an intermediary in this process, we cannot draft documents on behalf of the SBA or the applicant. However, we will submit any documentation you provide to the SBA and notify you if the SBA requires additional information.

 

4) I’m receiving an error that my tax identification doesn’t match either my supporting documents or what Comerica has in its systems. How do I resolve it?

The “Business TIN” provided on your PPP loan application must match the taxpayer ID or Social Security number issued to the individual or business entity applying for the PPP loan. If this is a Second Draw Loan and your First Draw Loan was under an incorrect tax ID, it will not pass the SBA validation checks once submitted and would also cause issues if you sought forgiveness for your PPP loan(s). Consequently, we will need to correct your information in the SBA’s systems before you apply. This does require ultimate approval from the SBA, which can take several weeks.

 

5) What should Borrowers with foreign applicant owners enter for a taxpayer identification number (TIN) and address on the application? It only accepts U.S. addresses.

- For this round, the SBA does not allow non-U.S. addresses for borrowers or owners; however, borrowers and owners may choose to enter a U.S. address of the business entity, if available.

- Applicants and owners must also have a U.S. employer identification number (EIN) or Social Security number (SSN).

- Non-citizen small business owners who are lawful U.S. residents may also use individual taxpayer identification numbers (ITIN) to apply. For more details on ITIN, please see the IRS ITIN site.

- While some borrowers may have been able to apply for a First Draw PPP Loan in 2020 without a U.S. address or U.S. EIN/SSN/ITIN for each owner, the validation rules used by the SBA in the current round will result in an application submitted without these details being rejected. If the SBA updates its guidance, we will update this FAQ accordingly.

 

6) How do I get a copy of my PPP loan documents or forgiveness application?

Please review and follow the directions outlined in our DocuSign Document Download Guide.

Preparing for PPP Loan Forgiveness

To our 14,000+ customers who received SBA Paycheck Protection Program funding in 2020, we encourage you to stay on track to be eligible for loan forgiveness. Up to 100% of your loan may be forgiven if you meet program requirements, including using funds to pay for eligible business expenses.

 

What’s Next?

We know that you may have questions about forgiveness of your PPP loan, so we’re committed to keeping you informed about how and when to apply for loan forgiveness. We will continue to provide updates via email and here on our PPP website as the SBA releases further loan forgiveness guidance.

In the meantime, we encourage you to visit SBA.gov and the U.S. Department of Treasury website for more details about forgiveness eligibility. The SBA’s Frequently Asked Questions also contains helpful insights into the loan forgiveness process.

In addition, we recommend that you consult with an accounting professional for specific guidance when it comes to documenting eligible expenses for loan forgiveness. You should also review your PPP loan documents with your legal or financial advisors.

Loan Necessity Questionnaire:

On October 26, 2020, the SBA introduced a new questionnaire to be completed by any company that, together with its affiliates, received $2 million or more in PPP financing. This questionnaire is being used to gather information and assess certifications regarding the need for a PPP loan. When the SBA requests this from us, our SBA group, in turn, will request it from the borrower(s) within 5 business days of receipt of the SBA request.

The lender’s role in this process is to receive the files from the Borrower, ensure that the files are complete and submit them to the SBA. The lender does not play a role in reviewing the information for anything other than completeness. At any time, the SBA may request documents you have already submitted, or request additional information.

While the SBA is supposed to provide forgiveness decisions within 90 days, it has been exceeding this time frame on accounts subject to Loan Necessity Questionnaires. The SBA does not provide us with status updates other than requests for information and ultimate forgiveness decisions. If the SBA contacts us about your account, we will promptly let you know.

 

Apply for PPP Loan Forgiveness

At this time, we are only accepting forgiveness applications for loans made in 2020. We expect to begin accepting forgiveness applications for loans made in 2021 by the end of the second quarter. As a reminder, if a forgiveness application has not been submitted to the lender, the principal and interest deferral period will last until 10 months after the end of the borrower’s 24-week covered period, or approximately 15½ months before loan payments must begin.  We will continue to update the site as we finalize exact timing.

Click the Apply Now button below to get started.

2020 Loan Forgiveness Timeline Calculator 

Input your PPP loan information into the following fields to understand the forgiveness process timing including the covered period, last day to apply for forgiveness and first payment due date.

PPP Loan Forgiveness FAQ

Note that much of the information below is taken directly from the SBA and/or the SBA Paycheck Protection Program Loan Forgiveness Application. The information posted here is solely for your convenience and is not intended to be, and should not be, considered comprehensive or definitive. Consult the SBA PPP website and U.S. Department of the Treasury website for information related to loan forgiveness and the PPP program. Guidance and rules directly from the SBA and/or the U.S. Treasury will supersede any information below or in any FAQ posted here, to the extent of any conflict.

In addition to the FAQ information below, please feel free to use our Comerica Virtual Assistant in the lower right corner to quickly locate PPP forgiveness information. Please disable your ad blocker in order to access Comerica Virtual Assistant.

Learn more about:

General

 

1) Do I need to have a separate bank account for my PPP funds?

The SBA does not require a separate account.

 

2) Can the SBA still audit my loan after they’ve approved my loan’s forgiveness?

According to the “Documents that Each Borrower Must Maintain but is Not Required to Submit” section of the SBA’s PPP Forgiveness Application Instructions, “The Borrower must retain all such documentation in its files for six years after the date the loan is forgiven or repaid in full, and permit authorized representatives of SBA, including representatives of its Office of Inspector General, to access such files upon request.”

 

3) How do I change the Authorized Representative email address on file for my PPP loan?

Please contact your assigned Relationship Manager, Banking Center Manager or the Comerica Contact Center at 800.979.0850, Monday through Friday from 8 a.m. to 9 p.m. ET.

 

4) Why did I receive a Year End Interest Statement?

As a courtesy, Comerica sends these statements for all loans annually. These statements are not official tax documents, and you should consult your tax advisor for tax-related questions. The statements provide a consolidation of all interest and fees that were paid for all loans to a borrower (Obligor), regardless of which party paid them. This has caused some confusion, as all PPP loans had upfront loan fees that were paid by the SBA, so these statements were mailed to all PPP borrowers, regardless of whether they directly made any payments on the loan.

In addition, interest that was forgiven on loans that completed the forgiveness process in 2020 is included in these statements. The following should help interpret the statements. Note that this guidance pertains specifically to PPP loans. If you have other loans with Comerica, there may be more information included in the statement that is related to those loans. The Year End Interest Statement has five categories:

1. Interest Paid: This amount represents all interest paid on all obligations associated with the Obligor referenced on the statement, including those paid on your behalf from the SBA (Forgiveness and Debt Relief, if applicable).

2. Late Charges Paid: Not applicable for PPP loans in 2020

3. Prepayment Penalty Paid: Not applicable for PPP loans in 2020

4. Service Charges Paid: Not applicable for PPP loans in 2020

5Loan Fee Paid: All PPP loans had an origination fee, which was paid directly by the SBA; however, it was attributed to each loan.

Loan Size                                     SBA-Paid Loan Fee on Initial Balance

<$350,000                                                          5%

>$350,000 and <$2,000,000                            3%

>$2,000,000                                                       1%

 

5) What should I do if I suspect fraud related to my PPP loan?

If you experience a situation where you suspect fraud related to your PPP loan, please report it to both Comerica and the SBA Office of the Inspector General using the contact information below.

Comerica

Email: ReportFraud@comerica.com

Telephone: 877.881.8955

SBA Office of the Inspector General

Online Submission Form

Email: oighotline@sba.gov

Telephone: 800.767.0385

 

6) How do I send a secure email through the Comerica Bank Secure Message Center?

Please reference the links below for assistance in sending an encrypted and secure email through the Comerica Bank Secure Message Center.

Sending and Retrieving Secure Email

Secure Email FAQs

Technical Details for Comerica Secure Email

 

7) How do I get a copy of my PPP loan documents or forgiveness application?

Please review and follow the directions outlined in our DocuSign Document Download Guide.

 

Qualifying for Loan Forgiveness

 

8) Is PPP loan forgiveness automatic?

No. You must request and apply for forgiveness.

 

9) Can I request loan forgiveness from Comerica Bank for an SBA PPP loan?

Yes. If you received a PPP loan through Comerica, you must request forgiveness through our Paycheck Protection Program Portal.

 

10) Will accrued interest on the forgiven amount on a PPP loan also be forgiven?

If some or all of the PPP loan is ultimately forgiven, the SBA will pay the interest that has accrued with respect to the forgiven amount. Accrued interest on any unforgiven balance remaining will be included in your payments that will become due at the end of the deferral period.

 

11) Who is authorized to apply for PPP loan forgiveness?

When it comes time to apply, the application for PPP loan forgiveness must be completed, certified and signed by an Authorized Representative of the borrower.

An Authorized Representative is a person who has the power and authority to apply for and sign the PPP loan forgiveness application and other document(s) required for PPP loan forgiveness on behalf of the borrower; and who is authorized to sign and to make certifications for and on behalf of the borrower and on behalf of each owner of 20% or more of the borrower’s equity.

 

12) When does the Covered Period begin for spending so that it may be eligible for loan forgiveness?

Please refer to the definitions of Covered Period and Alternative Payroll Covered Period on the instructions for the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

13) When do I need to use the loan proceeds to be eligible for forgiveness?

Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on the instructions for SBA PPP loan forgiveness applications. Also refer to FAQ 5 above as to your Covered Period. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

14) If I spent my loan funds within the Covered Period, could I receive forgiveness on both the loan amount and the interest?

Yes, for the portion that meets all the SBA rules and if the SBA approves your request for loan forgiveness.

 

15) Can I apply for loan forgiveness if I did not use all of my loan funds during the Covered Period?

You may apply for partial forgiveness if you did not use all of your loan proceeds for eligible expenses during the Covered Period, if you meet all SBA rules and if the SBA approves your request for loan forgiveness for that amount. Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on instructions for the SBA Paycheck Protection Program loan forgiveness application. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

16) What spending might qualify for forgiveness?

Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on the instructions for the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

17) Do mortgage principal and prepayments qualify for forgiveness?

Please refer to the definition of Eligible Nonpayroll Costs on the instructions for the SBA's PPP loan forgiveness application. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

Applying for loan forgiveness

 

18) How will I apply for loan forgiveness?

Comerica is utilizing an online portal for accepting forgiveness applications. The requirements of the portal mirror those of the SBA’s paper applications; however, the electronic format will facilitate automating the calculations and streamlining the process of submitting the application to Comerica and, in turn, to the SBA, as well as the required review process by both parties. Working with the SBA’s form of application is a good preparation for the forgiveness process; however, we are not accepting forgiveness applications outside of our online portal.

 

19) When can I apply for loan forgiveness through Comerica?

At this time, we are only accepting forgiveness applications for loans made in 2020. Borrowers cannot apply for forgiveness until the end of their Covered Period, which can be any period between 8 and 24 weeks after receiving loan funding.

We expect to begin accepting forgiveness applications for loans made in 2021 by the end of the second quarter. As a reminder, if a forgiveness application has not been submitted to the lender, the principal and interest deferral period will last until 10 months after the end of the borrower’s 24-week covered period, or approximately 15½ months before loan payments must begin. We will continue to update the site as we finalize exact timing.

 

20) Which SBA PPP Loan Forgiveness Application should I use?

For borrowers with loans of $150,000 and less, use the 3508S form.

For borrowers with loans greater than $150,000, use the 3508EZ form, if you are eligible. It requires fewer calculations and less documentation for eligible borrowers, which are defined as:

- Those who are self-employed

- OR those who did not reduce the salaries or wages of their employees by more than 25%, and did not reduce their number of employees

- OR those who experienced reductions in business activity as a result of health directives related to COVID-19, and did not reduce the salaries or wages of their employees by more than 25%

For all other borrowers, use the 3508 form.

For more information and updates, visit SBA.gov or U.S. Department of Treasury website

 

21) What should I do to prepare for my loan forgiveness request?

Review the appropriate SBA PPP loan forgiveness application as a guide. Allow yourself ample time and effort to prepare; we encourage you to download the appropriate application and use it to organize your information in advance so you may complete your online application efficiently and accurately.

Reference the appropriate SBA instructions and guidance about calculating your requested forgiveness amount, documenting your eligible business costs, determining impact of FTE reduction and more. If applicable, complete the PPP Schedule A Worksheet (pages 4-5 in the full application form) and ensure the accuracy of the data which you will provide in your online application.

Please do not submit the SBA PPP loan forgiveness application to us, it is meant to only serve as a guide; we will only accept information entered on our online loan forgiveness application site. The PPP Loan Forgiveness Applications are for reference and informational purposes only.

Review the PPP Loan Forgiveness: Required Documentation guide we have created to familiarize yourself with the types of documents you will need to provide during the loan forgiveness process.

We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you. Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting SBA.gov or the U.S. Department of the Treasury website.

 

22) What documents do I need to include when I apply for forgiveness? (This is not applicable for 3508S applications, which do not require supporting documents.)

Review the PPP Loan Forgiveness: Required Documentation guide we created to familiarize yourself with the types of documents you will need to provide during the loan forgiveness process.We recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you. You should also review the SBA PPP loan forgiveness applications.

Please do not submit the SBA PPP loan forgiveness application to us; it is meant to only serve as a guide. We will only accept information entered on our online forgiveness application site. The PPP loan forgiveness applications are for reference and informational purposes only.

Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

23) How do I calculate FTEs in the context of PPP loan forgiveness?

Please refer to the definitions of FTE and Average FTE on the instructions for the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

24) Can Comerica Bank calculate my loan forgiveness amount for me?

No. Per SBA guidance, providing an accurate calculation of the loan forgiveness amount is the responsibility of the borrower. Lenders are expected to perform a good-faith review, in a reasonable time, of the borrower’s calculations and supporting documents. If the lender identifies errors in the borrower’s calculation or material lack of substantiation in the borrower’s supporting documents, the lender should work with the borrower to remedy the issue.

Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting SBA.gov or the U.S. Department of the Treasury website. We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you.

 

25) Can Comerica make a change or update to my forgiveness application if I request it?

We are not able to make changes to your application for you. Once you submit your application, we cannot guarantee that you will have the ability to make changes, so we encourage you to confirm your application is complete and accurate prior to submitting. If you would like to make changes to your application after submitting it, you may initiate a request to reopen your application, but we cannot provide assurances that we will be able to do so in all cases. If your application is able to be reopened, you will need to make the desired changes, upload any additional documents that are required as a result of the change, and re-certify your updated application in a timely manner so that your application can be processed within our 60-day review period.

 

26) How do I determine my Lender PPP Loan Number as required on the forgiveness application?

The Lender PPP Loan Number will be auto-populated in our portal. The number will not be displayed in the portal until the final DocuSign application is generated, after Comerica’s review of the application is complete.

 

27) Can I withdraw my PPP Loan Forgiveness application after I have already submitted the request?

Yes. Please access the Message Center on your PPP Dashboard to submit the request to withdraw your PPP loan forgiveness application. The request should include a reason you are requesting the application to be withdrawn.

 

28) If Comerica has questions related to my forgiveness application or its attachments, does that reset the 60-day review window?

The SBA requires that we complete our review process within 60 days of the date you originally submitted your application to us. Failure to resolve open issues with your application in a timely manner so that we may complete our review during this 60-day window could result in your application being Approved in Partial or Declined, as questions do not extend the review window.

 

29) If Comerica has submitted my forgiveness application to the SBA, can I consider it approved?

No. Although Comerica may submit your forgiveness application to the SBA, Comerica makes no determination as to whether you will be entitled to forgiveness; that decision rests solely with the SBA

 

30) How long will it take to process my application?

Once you have submitted a complete application, SBA guidelines provide lenders with 60 days to review and process the application prior to sending it to the SBA for approval. Once an application is submitted to the SBA, the SBA has an additional 90 days to review the application before making a decision. For loans of $2 million and greater, the SBA’s review is taking longer than 90 days from the date of original submission.

To gain a better understanding of timing for the forgiveness process, leverage our loan forgiveness timeline calculator to input your information. The information provided by the calculator relies on the dates and responses provided by you and is for illustration purposes for your convenience only. Comerica makes no representations or warranties as to the accuracy of the dates shown, and we encourage you to refer to your loan documents and the SBA PPP website for the authoritative terms, provisions and rules governing your PPP loan.

 

31) Why can’t I upload or even see the documents before I complete the PPP Loan Forgiveness Application Dashboard?

The application must be complete before documents can be uploaded because document placeholders render conditionally based on the submitted forgiveness application.

 

Potential reductions in loan forgiveness

 

32) Will my forgiveness amount be reduced for cases where a borrower laid-off or reduced hours of an employee, then offered to rehire the same employee for the same salary and same number of hours or restore reduction in hours, and the employee rejected the offer?

Please refer to the definition of FTE Reduction Exceptions on the instructions for the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

33) Will my loan forgiveness amount be reduced for employees who were fired for cause, voluntarily resigned or voluntarily requested a schedule reduction?

Please refer to the definition of FTE Reduction Exceptions on the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

34) What if I wasn't able to rehire my employees until partway through my loan forgiveness period?

Please refer to the definition of FTE Reduction Exceptions on the instructions for the SBA PPP loan forgiveness applications. Please continue to check SBA.gov and Treasury.gov sites for the latest information.

 

Utilizing PPP funds

 

35) Can I use PPP funds to reimburse expenses paid through my personal account?

Yes, if the expense is an eligible use of PPP proceeds under SBA and Treasury guidance.

 

36) Can I pay back part or all of my loan sooner than the note maturity?

Yes. Please refer to SBA.gov and Treasury.gov sites for the latest information.