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SBA issues guidance on filing Form 1502
The Small Business Administration has issued a Procedural Notice on "Paycheck Protection Program Lender Processing Fee Payment and 1502 Reporting Process." Lenders must submit a Form 1502 report by the later of May 29 or 10 calendar days after final loan disbursement or cancellation.
- Lenders will not be paid if the PPP loan is canceled before disbursement or if the loan was canceled or voluntarily terminated after funds were disbursed and repaid by May 18
- The SBA will not pay processing fees for PPP loans canceled, terminated or repaid due to an SBA loan review finding the borrower ineligible
- Lender processing fees may be clawed back within a year after disbursement if SBA later determines the borrower to be ineligible
- Such a clawback for ineligibility will not affect the SBA guaranty for the loan, if the lender has complied with its obligations under section III.3.b of the initial PPP Interim Final Rule (What Do Lenders Have to Do in Terms of Loan Underwriting?)