Can I use the 3508EZ form to apply for PPP loan forgiveness?

3508EZ PPP Loan
Can you use the EZ form to apply for PPP forgiveness?

The Treasury Department updated the PPP loan application to account for the new reals established by the Flexibility Act. They also introduced a new form the EZ form which is significantly simpler then the full form.

You can use the EZ form if you meet two criteria. First, you have not have reduced compensation for any employee by more than 25%. Second you either restored all FTE’s OR could not restore FTE’s due to COVID-19 restrictions.

Most of the complexity in the standard form comes from calculating forgiveness adjustments due to FTE and salary reductions. Also, the Flexibility Act loosened the restrictions on FTE’s and payroll reduction – so this new form addresses that.

Download the 3508EZ form here.
Download the 3508EZ form Instructions here.

More Detail on who can use the PPP Loan Forgiveness Application 3508EZ

You can use the form if

You are a self-employed individual, an independent contractor, or a sole proprietor who had no employees when you applied for the PPP loan and did not include any employee salaries in calculating average monthly payroll.

Or you are a corporation, you did not reduce salary by more than 25% for any employee earning less than $100,000 and you either:

  • Returned to full employment by December 31, 2020.
  • Tried to return to full employment by December 31, 2020, but could not find qualified people who would accept your offer.
  • Could not return to full employment because your business could not operate at full capacity due to COVID-19 restrictions.

That final point is extremely broad and important. I know a few businesses that have not been impacted by the COVID restrictions. However, they also haven’t had to reduce employees. The businesses that I know of who have reduced headcount have done so due to the COVID restrictions. The restrictions seem to be an acceptable reason not to rehire as well.

The exact wording from the PPP 3508EZ application is:

“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 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.”

3508EZ Application

If you did reduce employee headcount despite not being impacted or if you did reduce salaries by more than 25% use the full forgiveness application.

Download the 3508EZ form here.

If you are looking for more information on the terms of the PPP loan check outy our other poses. You can read more about the PPP loan here and we have more information on how the Flexibility Act Changed the PPP terms here.

Jeff Coyle, CPA

Jeff Coyle, CPA, Partner of Rosenberg Chesnov, has been with the firm since 2015. He joined the firm after 20 years of business and accounting experience where he learned the value of accurate reporting, using financial information as a basis for good business decisions and the importance of accounting for management.

He is a diligent financial professional, able to manage the details and turn them into relevant business leading information. He has a strong financial background in construction, technology, consulting services and risk management. He also knows what it takes to create organizations having built teams, grown companies and designed processes for financial analysis and reporting.

His business experience includes:

Creating and preparing financial reporting, budgeting and forecasting.
Planning and preparation of GAAP and other basis financial statements.
Providing insight on financial results and providing advice based on those results.

Jeff also has a long history of helping individuals manage their taxes and plan their finances including:

Income tax planning and strategy.
Filing quarterly and annual taxes.
Audit support.
General financial and planning advice.
Prior to joining the firm in 2015, Jeff was in the private sector where he held senior financial and management positions including Controller and Chief Financial Officer. He has experience across industries, including construction, technology and professional services which gives him a deep understanding of business.

Jeff graduated from Montclair State University, he is a CPA and member of the American Institute of Certified Public Accountants, New York State Society of Certified Public Accountants and New Jersey State Society of Public Accountants.

Jody H. Chesnov, CPA

Jody H. Chesnov, CPA, Managing Partner of Rosenberg Chesnov, has been with the firm since 2004.  After a career of public accounting and general management, Jody knows the value of good financials.  Clarity, decision making, and strategy all start with the facts – Jody has been revealing the facts and turning them into good business results for more than three decades.

He takes a pragmatic approach to accounting, finance and business. His work has supported many companies on their path to growth, including helping them find investors, manage scaling and overcome hurdles.  His experience and passion for business reach beyond accounting and he helps businesses focus on what the numbers mean organizationally, operationally and financially.

He has a particular expertise in early-stage growth companies.  His strengths lie in cutting through the noise to come up with useful, out of the box, solutions that support clients in building their businesses and realizing their larger visions.

Prior to joining the firm in 2004, Jody was in the private sector where he held senior financial and management positions including General Manager, Chief Financial Officer and Controller.  He has experience across industries, which gives him a deep understanding of business.

Jody graduated with a BBA in Accounting from Baruch College, he is a CPA and member of the American Institute of Certified Public Accountants and New York State Society of Certified Public Accountants.

In addition to delivering above and beyond accounting results, Jody is a member of the NYSCPA’s Emerging Tech Entrepreneurial Committee (ETEC), Private Equity and Venture Capital Committee and Family Office Committee.  

He is an angel investor through the Westchester Angels, and has served as an advisor for many startup companies and as a mentor through the Founders Institute.

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