Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan

Forms and Documents

Document Name	Status
Form SBA Form 3512 Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan Form and Instruction	New
3245-PPP Corr Emergency Justification for PPP Lender Certification for Errors 12-09-2020.pdf Supplementary Document	2020-12-09
3245-PPP Corr Lender Certification for Error Correction-Reinstatement Supporting Statement 12-09-2020.docx Supporting Statement A	2020-12-09

IC Document Collections

IC ID	Document Title	Status
244824	Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan Form and Instruction	New

ICR Details

OMB Control No: 3245-0415	ICR Reference No: 202012-3245-002
Status: Active	Previous ICR Reference No:
Agency/Subagency: SBA	Agency Tracking No:
Title: Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan
Type of Information Collection: New collection (Request for a new OMB Control Number)	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 12/10/2020
OIRA Conclusion Action: Approved without change	Conclusion Date: 12/09/2020
	Date Received in OIRA: 12/09/2020
Terms of Clearance:

	Inventory as of this Action	Requested	Previously Approved
Expiration Date	06/30/2021	6 Months From Approved
Responses	4,000	0	0
Time Burden (Hours)	2,000	0	0
Cost Burden (Dollars)	72,000	0	0

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Abstract: Lenders that cancelled a PPP loan in SBA’s ETRAN system due to the lender’s data input error or made a data input error in the SBA Loan Approval Amount of a PPP loan on ETRAN will use this form to request that the SBA Loan Approval Amount be corrected or that an erroneously cancelled loan be reinstated. SBA will use the information provided to evaluate the nature of the lender’s error and to determine whether the SBA Loan Approval Amount should be corrected or whether the loan should be reinstated.

Emergency Justfication: December 9, 2020 Susan Minson SBA Desk Officer Office of Management and Budget Dear Ms. Minson: Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR 1320, SBA requests that the collection of information titled, Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan, be processed in accordance with section 1320.13, Emergency Processing. SBA has determined that this information must be collected prior to the expiration of time periods established under Part 1320, and that this information is essential to the SBA’s ability to evaluate lenders’ requests for reinstatement of PPP loans that were cancelled in SBA’s ETRAN system due to lenders’ data input errors and/or correction of lenders’ data input errors in the SBA Loan Approval Amount of PPP loans on ETRAN. SBA has been accepting forgiveness decisions from lenders and making forgiveness payments on PPP loans, therefore the ability to collect this information without having to go through the standard Paperwork Reduction Act review procedures will enable SBA to review and correct lenders’ data input errors, if appropriate. This will enhance the integrity of the program and improve SBA’s oversight and monitoring responsibilities. Lenders that cancelled a PPP loan in SBA’s ETRAN system due to the lender’s data input error or made a data input error in the SBA Loan Approval Amount of a PPP loan on ETRAN will use this form to request that the SBA Loan Approval Amount be corrected or that an erroneously cancelled loan be reinstated. SBA will use the information provided in the Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan to evaluate the nature of the lender’s error and to determine whether the loan should be reinstated or whether the SBA Loan Approval Amount should be corrected. Lenders will submit this information directly to one of SBA’s Loan Servicing Centers. SBA requests approval of the submission by December 10, 2020. Given the inability to seek public comment during such a short timeframe, SBA also requests a waiver from the requirement to publish 60-day and 30-day notices in the Federal Register seeking public comment during the period of OMB review. Although SBA is unable to consult with the public prior to issuing the forms, the Agency has experience designing similar forms in a way that is clear and minimizes burden on respondents. Sincerely, Jihoon Kim Director, Office of Financial Program Operations

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan	SBA Form 3512	Lender Certification for Error Corrections and Reinstatements

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ICR Summary of Burden

	Total Approved	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	4,000	0	0	4,000	0	0
Annual Time Burden (Hours)	2,000	0	0	2,000	0	0
Annual Cost Burden (Dollars)	72,000	0	0	72,000	0	0

Burden increases because of Program Change due to Agency Discretion: Yes

Burden Increase Due to: Miscellaneous Actions

Burden decreases because of Program Change due to Agency Discretion: No

Burden Reduction Due to:

Short Statement: New Collection

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Annual Cost to Federal Government: $72,000

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? Yes

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? No

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 12/09/2020

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