What happens if my PPP loan is not forgiven? Repayment terms and next steps

In this 6-minute read:

  • Requirements to receive full PPP loan forgiveness
  • Applying for PPP loan forgiveness
  • Under what circumstances will businesses have to repay their full or partial PPP loan?
  • What should your next steps be if your PPP loan isn’t fully forgiven?
  • What are the repayment terms of the PPP loan?
  • Additional PPP loan resources

URGENT PPP FORGIVENESS UPDATE: On July 28, 2021, the SBA announced big news (for most PPP borrowers). The SBA has established an online PPP forgiveness platform called the SBA PPP Direct Forgiveness Portal. If your PPP loan was for $150,000 or less, AND if your lender has opted-in to the use of the platform, you will be able to submit your PPP loan forgiveness application online directly to the SBA, using the electronic equivalent of SBA Form 3508S. For full details, read our post about the new SBA PPP Direct Forgiveness Portal and other recent rule changes. Check the SBA’s list of PPP lenders who have opted-in to the SBA PPP Direct Forgiveness Portal.

As businesses are finished spending their PPP loans, they can begin the forgiveness application process in order to receive full loan forgiveness and not have to worry about paying this loan back. 

Not all businesses will receive full loan forgiveness, though. So what happens if your PPP loan is not fully forgiven? What should your next steps be?

Womply has made email marketing truly automatic for busy small business owners and all types of independent contractors. Learn more, plus get free reputation monitoring and customer insights when you sign up for Womply Free!

Requirements to receive full PPP loan forgiveness

First, it helps to understand what the PPP loan requirements are in order to receive full loan forgiveness. This will help you spend your funds appropriately (if you haven’t spent them all yet) and prepare your business for the best outcome. 

The three basic requirements for spending your PPP loan if you wish to receive full loan forgiveness are as follows:

  1. You must maintain your employee counts and their compensation levels (there are certain exceptions here, which we’ll get to later)
  2. You must spend at least 60% of your loan proceeds on payroll costs
  3. You must spent any funds outside of payroll costs on other eligible PPP expenses

These are the basic requirements of forgiveness for both first and second draw PPP loans. 

Applying for PPP loan forgiveness

To apply for loan forgiveness, you should first check if your lender has opted-in to the new SBA PPP Direct Forgiveness Portal. If your PPP loan was for $150,000 or less, AND if your lender has opted-in to the use of the platform, you will be able to submit your PPP loan forgiveness application online directly to the SBA, using the electronic equivalent of SBA Form 3508S. For full details, read our post about the new SBA PPP Direct Forgiveness Portal and other recent rule changes.

If the above doesn’t apply to you, contact your PPP lender and complete the correct application form.

Applying for PPP loan forgiveness is a crucial step in the process, because PPP loan forgiveness is not automatic. You must fill out a PPP forgiveness application, gather any necessary documentation to verify your expenditures, and turn that all in to your lender to process with the SBA. 

If you’re not sure what you need here, communicate with your PPP lender. They can help make sure you get the correct application and give you direction on what kind of documentation you’ll need to verify your spending. 

There are multiple PPP forgiveness applications, which you’ll fill out based on how much your loan was and some other specific requirements. 

If your PPP loan was $150,000 or less, you’ll need to fill out Form 3508S for your PPP forgiveness. Check out our instruction guide for PPP loan forgiveness Form 3508S (loans under $150K).

If your PPP loan was over $150,000, there are two different forms that may apply to you. Form 3508EZ is a simplified application form for larger loans and it has some specific requirements that you must meet if you wish to fill it out. If you don’t meet the requirements for Form 3508EZ then you’ll need to fill out Form 3508, which just has some additional calculating to determine the maximum loan forgiveness you can receive. Check out our instruction guide: PPP forgiveness application instructions for loans over $150,000 (forms 3508 and 3508EZ)

After you’ve turned in your PPP forgiveness application and your lender sends it to the SBA, the SBA will have up to 90 days to make a final decision. If your PPP loan is not fully forgiven, then you will need to repay back any portion that wasn’t forgiven. 

Under what circumstances will businesses have to repay their full or partial PPP loan?

Businesses will only have to pay back their PPP loans if they didn’t fulfill all of the requirements for loan forgiveness. The biggest reason businesses may need to pay back their loan (or at least a portion of it) is that they haven’t maintained their employee counts and compensation levels (and their loan terms and date of origination require these conditions). Though there are those other circumstances where the business owner didn’t spend their funds as directed by the SBA. 

Part of the forgiveness application will ask you how many employees you had at the time of your PPP loan application and how many employees you had at the time of your forgiveness application. If there are disparities here, that’s one instance that may require you to pay at least part of your PPP loan back (depending on when you received your loan and how much your loan amount was). To make sure that you’ve met this requirement, you’ll need to know the number of FTE (full-time equivalent) employees you had during each of these times. If you managed to keep your employees on staff, then you’ve maintained your “employee count.”

The other part of that is that you must maintain your employees’ compensation levels. In order to achieve this, you must be paying your employees no less than 75% of what their wages were prior to receiving the PPP loan. If you fall below that, then you may have to pay back at least part of your PPP loan.  

Important exceptions to the “maintaining employee count and compensation” rule

It’s understandable that employees may leave of their own accord or need to be let go for other reasons beyond budget cuts. Here are the exceptions:

  • If you received a PPP loan of $50,000 or less you are exempt from having to maintain your employee count and their compensation levels
  • If an employee quit, retired, or was fired (with just cause), or refused to be rehired when you offered, then you can still qualify for full loan forgiveness. You may be required to show verification of this should the circumstance arise
  • Businesses and eligible organizations and individuals that receive PPP loans after December 27th, 2020 are not required to “rehire” any employees in order to receive forgiveness. You will, however, need to maintain current payroll levels, according to the SBA directives mentioned above, during the forgiveness period. 

What should your next steps be if your PPP loan isn’t fully forgiven?

Some PPP loans will not be forgiven. If you receive the SBA’s final decision on your forgiveness application and it wasn’t fully forgiven, there are a couple of steps you can take. 

First, you may be able to appeal the SBA’s decision. You can only file for an appeal if the SBA has issued a loan review. If your lender determines that your loan can’t be fully forgiven, then you can request a review by the SBA (though this isn’t guaranteed to happen). Any loans of $2 million or more are automatically reviewed by the SBA, and even loans less than that may still be reviewed if the SBA determines the need to do so. 

If you are unable to appeal the SBA’s decision, then you’ll have to repay any portion of your loan that wasn’t forgiven.

PLEASE NOTE: As of August 2021, if you file an appeal with the SBA, your repayment of any unforgiven portion of your loan is deferred until the SBA issues a final decision on your appeal. Read more details in our post on the new SBA PPP Direct Forgiveness Portal and other recent rule changes.

What are the repayment terms of the PPP loan?

If you do end up having to pay back any portion of your PPP loan, then it will be good to understand the repayment terms. Those are as follows:

  • 1% interest rate
  • Maturity of 5 years, meaning that the full amount of the non-forgiven portion of the loan (including interest) is due in 5 years (or 2 years if you received your PPP loan early on in the program… see the terms of your loan for specifics)
  • You don’t need to start paying back your loan until you receive a decision on your forgiveness application (unless you file an appeal within 30 days of the decision; see above) or 10 months after the end of your covered loan period

Any portion of the loan that you need to pay back will be paid back through your lender. If you have further questions about repaying your loan, talk to your lender. 

Additional PPP loan resources

Win new customers, build loyalty with your existing customers, and strengthen your online presence with Womply!

Womply has made Email Marketing truly automatic for busy small business owners, independent contractors, and sole proprietors. Womply helps you turn customers into regulars and get more repeat business with targeted emails that send automatically when customers transact with you. Build customer loyalty and revenue, and get more repeat business with just a few clicks! 

Womply Reputation Management makes it easy to keep up to speed with your online reviews on multiple sites at once. Our dashboard allows you to read and respond to all your reviews on all the popular platforms, all in one place with one login. Plus, you can set up automatic replies if you so choose, to help build customer engagement and loyalty, and improve your local SEO.

And don’t forget about Womply’s exclusive Customer Directory that gives you a preloaded list of all of your customers — including spend history, name, and contact information — that automatically updates with every transaction. This allows you to get smarter about your customers and their impact on your business to target the right ones, every time.

Learn more, plus get free reputation monitoring and customer insights when you sign up for Womply Free!

Recent Articles

9 Atlanta area events that can be great for your small business in 2022

In this 5-minute read: 9 events in Atlanta, GA in 2022 that your business should know about Start your year …

Read More

25 free business listing websites every small or local business should be on (Updated for 2022!)

Be sure to claim your company’s free listings on these sites so more customers can find your business. 

Read More

9 events that every Houston, TX area small business should know about in 2022

In this 5-minute read: 9 local events that Houston small businesses should take advantage of this year Attending events, business …

Read More

Small business events in Chicago: 8 ways to grow and market your business in 2022

In this 5-minute read: 8 Chicago events to add to your 2022 business calendar Wherever your business is located, you …

Read More

10 2022 Washington DC area events that can be great for your small business

In this 5-minute read: 10 events that Washington DC area businesses need to know about this year Which DC events …

Read More

5 Orlando area events in 2022 your small business should take advantage of

In this 5-minute read: 5 2022 events in Orlando, FL that your business needs to know about Which events may …

Read More

See why Womply is the #1 marketing and CRM solution used by 500,000+ businesses.