Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty

Forms and Documents

Document Name	Status
Form SBA Form 3508 pdf Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty Form and Instruction	Modified
3245-0407 Emergency Justification for 3508 revisions and 3509 +3510 Cancellation 7-19-2021 signed JK.pdf Supplementary Document	2021-07-19
3245-0407 PPP 3508 Revisions Supporting Statement 7-19-2021.docx Supporting Statement A	2021-07-19

IC Document Collections

IC ID	Document Title	Status
241035	Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty Form and Instruction	Modified

ICR Details

OMB Control No: 3245-0407	ICR Reference No: 202107-3245-002
Status: Received in OIRA	Previous ICR Reference No: 202106-3245-002
Agency/Subagency: SBA	Agency Tracking No:
Title: Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 07/26/2021
Date Submitted to OIRA: 07/19/2021

	Requested	Previously Approved
Expiration Date	6 Months From Approved	09/30/2021
Responses	44,384,854	37,002,166
Time Burden (Hours)	12,947,044	9,935,129
Cost Burden (Dollars)	565,596,195	355,220,794

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Abstract: Section 7(a) of the Small Business Act (15 U.S.C. 636) authorizes the Small Business Administration to guarantee loans made by banks or other financial institutions to qualified small businesses in the 7(a) Loan Program. The regulations covering this loan program at 13 CFR Part 120 require loan applicants and lenders to provide certain information that is used to determine program eligibility and compliance. CARES Act PL 116-136 will also cover this program.

Emergency Justfication: July 19, 2021 Susan Minson SBA Desk Officer Office of Management and Budget Dear Ms. Minson: Pursuant to the Office of Management and Budget (OMB) procedures in 5 CFR Part 1320, SBA requests emergency review of revisions to the collection of information for the Paycheck Protection Program Loan Program (PPP Loan Program). This information collection (OMB Control Number 3245-0407) is currently approved under emergency proceedings until September 30, 2021. This request for emergency processing, includes a request for waiver of the requirement to publish the 60-day and 30-day public comment notices in the Federal Register. SBA is requesting approval to implement changes to loan forgiveness forms SBA Form 3508, Paycheck Protection Program, Loan Forgiveness Application Form 3508, SBA Form 3508EZ, Paycheck Protection Program, PPP Loan Forgiveness Application Form 3508EZ, and SBA Form 3508S, Paycheck Protection Program, PPP Loan Forgiveness Application Form 3508S. Among other things, the three forms were revised as follows: • To reflect changes made to the calculation of payroll costs by Schedule C filers for PPP purposes under the interim final rule titled “Business Loan Program Temporary Changes; Paycheck Protection Program Revisions to Loan Amount Calculation and Eligibility” (Loan Amount Calculation Rule). • To incorporate payroll cost exclusions required by the American Rescue Plan Act. (P.L. 117-2). • To delete the question (and instructions) related to the SBA Form 3509, Loan Necessity Questionnaire (For-Profit Borrowers) and SBA Form 3510, Loan Necessity Questionnaire (Non-Profit Borrowers) that SBA is requesting approval to discontinue. SBA has also made revisions to the SBA Form 3508S and Instructions, the SBA Form 3508D, and [No Form Number] Lender Reporting Requirements Concerning Requests for Loan Forgiveness to reflect changes made under the interim final rule titled “Business Loan Program Temporary Changes; Paycheck Protection Program – COVID Revenue Reduction Score, Direct Borrower Forgiveness Process, and Appeals Deferment.” SBA has also made a revision to [No Form Number] Lender Reporting Requirements for Loan Review related to the discontinuance of the SBA Form 3509, Loan Necessity Questionnaire (For Profit Borrowers) and SBA Form 3510, Loan Necessity Questionnaire (Non-Profit Borrowers). Susan Minson Page 2 Finally, SBA is requesting approval to discontinue SBA Form 3509, Loan Necessity Questionnaire (For-Profit Borrowers) and SBA Form 3510, Loan Necessity Questionnaire (Non-Profit Borrowers). The authority for the program expired on June 30, 2021. There is an urgent need to make the revised forgiveness forms available as soon as possible because (a) borrowers are continuing to apply for forgiveness and it is important that borrowers are able to use forms with the most updated information, and (b) there is a short period of time before certain borrowers will be required to begin making principal and interest payments on their loans if they have not yet applied for forgiveness with their lenders, and the changes to the SBA Form 3508S will allow the borrowers to have another alternative to submit their forgiveness applications. Therefore, given the urgent need to make the revised information collection available to the affected small businesses and nonprofits, SBA cannot comply with the standard review and approval procedures. Accordingly, SBA is requesting that OMB review and approve the revised information collection under the emergency procedures set forth in 5 CFR 1320.13. 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
Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty	SBA Form 3508 pdf, SBA Form 3508EZ , SBA Form 3508 Word , SBA Form 3508S Word, SBA Form 3508D Word, SBA Form 3508EZ Application Instructions pdf, SBA Form 3508 D pdf	PPP Loan Forgiveness Calculation Form ,   PPP Forgiveness Application ,   PPP Forgiveness Application ,   PPP Forgiveness Application ,   Paycheck Protection Program Borrower’s Disclosure of Certain Controlling Interests, ,   PPP Application Instructions ,   Paycheck Protection Program Borrower’s Disclosure of Certain Controlling Interests,

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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	44,384,854	37,002,166	0	7,382,688	0	0
Annual Time Burden (Hours)	12,947,044	9,935,129	0	3,011,915	0	0
Annual Cost Burden (Dollars)	565,596,195	355,220,794	0	210,375,401	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: At the time this Information Collection was last approved in March 2021, the total number of loans was estimated at approximately 8 million. Total PPP loans approved, based on SBA website data, is 11.8 million. This increase of more than 3 million in the number of PPP loans approved, and hence the number of and cost burden associated with application forms and forgiveness forms, has increased burden hours.

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Annual Cost to Federal Government: $195,294,753

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]? No

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? Yes

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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: 07/19/2021

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