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	Modified
3245-0415 Lender Certification for Reinstatement emergency letter 6-15-2021.pdf Supplementary Document	2021-06-15
3245-0415 Corr Certification for Error Correction-Reinstatement Supporting Statement 6-15-2021.docx Supporting Statement A	2021-06-15

IC Document Collections

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

ICR Details

OMB Control No: 3245-0415	ICR Reference No: 202106-3245-001
Status: Received in OIRA	Previous ICR Reference No: 202012-3245-002
Agency/Subagency: SBA	Agency Tracking No:
Title: Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 06/30/2021
Date Submitted to OIRA: 06/16/2021

	Requested	Previously Approved
Expiration Date	6 Months From Approved	06/30/2021
Responses	4,000	4,000
Time Burden (Hours)	2,000	2,000
Cost Burden (Dollars)	67,520	72,000

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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: June 15, 2021 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 OMB review of the non-substantive revisions to the collection of information titled, Lender Certification for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan, OMB Control No. 3245-0415, be processed in accordance with section 1320.13, Emergency Processing. These revisions include clarifying that a lender’s ability to reinstate or correct a loan is subject to the availability of funds. This change will help to manage lenders’ expectations, especially as funds become depleted. Additional changes include clarifying that an Individual Taxpayer Identification Number (ITIN) is an acceptable Taxpayer Identification Number for the Borrower and removing an outdated reference to the expiration of authority for the PPP. Also, the form has been revised in light of the new 2021 origination process for PPP loans, where loans are processed through SBA’s Paycheck Protection Platform, rather than directly through SBA’s ETRAN system. SBA has determined that the revisions are necessary prior to the expiration of time periods established under Part 1320 to complete the OMB review process. The 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 made when entering the SBA Loan Approval Amount of PPP loans in ETRAN or the Paycheck Protection Platform, subject to availability of funds. SBA has been accepting forgiveness decisions from lenders and making forgiveness payments on PPP loans and recognized that there is a need for the revisions to help ensure, among other things, that Lenders submit the appropriate information that SBA needs to review the correction or reinstatement requests. In light of the ongoing need to review such requests, approval of this revised information collection without having to go through the standard Paperwork Reduction Act review procedures will have an immediate benefit for lenders, enhance the integrity of the program, and improve SBA’s oversight and monitoring responsibilities. SBA requests approval of these non-substantive revisions by June 30, 2021. According to OMB guidance,1 the agency is not required to solicit public comment for non-substantive revisions to Flexibilities Under the Paperwork Reduction Act for Compliance with Information Collection Requirements.

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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 FORNSTATEMENT OR CORRECTION OF PAYCHECK PROTECTION PROGRAM (PPP) LOA

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ICR Summary of Burden

	Total Request	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	4,000	0	0	0	0
Annual Time Burden (Hours)	2,000	2,000	0	0	0	0
Annual Cost Burden (Dollars)	67,520	72,000	0	-4,480	0	0

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

Burden Increase Due to:

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

Burden Reduction Due to:

Short Statement:

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Annual Cost to Federal Government: $276,000

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: 06/16/2021

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