Paycheck Protection Program

Paycheck Protection Program

Currently, new Paycheck Protection Program (PPP) loans from the U.S. Small Business Administration (SBA) are not available.

We've obtained PPP funding for more than 14,000 of our customers. Check out our PPP Highlights overview for additional information. Over 1,000 Comerica colleagues have been supporting PPP with the mission of serving our customers as you focus on keeping your workforce intact.

Preparing for PPP Loan Forgiveness

To our 14,000+ customers who received SBA Paycheck Protection Program funding, we encourage you to stay on track to be eligible for loan forgiveness. Up to 100% of your loan may be forgiven if you meet program requirements including using funds to pay for eligible business expenses.

 

What’s Next?

For explicit PPP information including details about forgiveness eligibility and program requirements, please visit the SBA’s PPP website and the U.S. Department of Treasury website. Review the SBA’s Frequently Asked Questions to learn additional insights on the forgiveness process. We recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you. We know that your PPP loan is a critical element to weathering these challenging times. As the SBA releases further guidance, we are committed to keeping you informed about how and when to apply for PPP forgiveness through Comerica with updates by email and on the website.

In mid-October, we sent an email to the Authorized Representative on file which laid out the timeline for invitations to apply for forgiveness. If you did not receive this email, please contact your assigned Relationship Manager, Banking Center Manager, or the Comerica Contact Center.

Loan Forgiveness Timeline Calculator 

Input your PPP loan information into the following fields to understand the forgiveness process timing including the covered period, last day to apply for forgiveness and first payment due date.

PPP Loan Forgiveness FAQ

Note that much of the information below is taken directly from the SBA and/or the SBA Paycheck Protection Program Loan Forgiveness Application. The information posted here is solely for your convenience and is not intended to be, and should not be considered, comprehensive or definitive. Consult the SBA PPP website and U.S. Department of the Treasury website for information related to loan forgiveness and the PPP program. Guidance and rules directly from the SBA and/or the U.S. Treasury will supersede any information below or in any FAQ posted here, to the extent of any conflict.

In addition to the FAQ information below, please feel free to use our Comerica Virtual Assistant in the lower right corner to quickly locate PPP forgiveness information. Please disable your ad blocker in order to access Comerica Virtual Assistant.

Learn more about:

Qualifying for loan forgiveness

 

1) Is PPP loan forgiveness automatic?

No. You must request and apply for forgiveness.

 

2) Can I request loan forgiveness from Comerica Bank for an SBA PPP loan?

Yes, if you have received a PPP loan through Comerica you must request forgiveness through Comerica. In mid-October, we sent an email to the Authorized Representative on file, which laid out the timelineo for invitations to apply for forgiveness. If you did not recieve this email, please contact your assigned Relationship Manager, Banking Center Manager, or the Comerica Contact Center at 800.979.0850, Monday through Friday 8 a.m. to 9 p.m. ET and Saturday 8 a.. to 5 p.m. ET. 

 

3) Will accrued interest on the forgiven amount on a PPP loan also be forgiven?

If some or all of the PPP loan is ultimately forgiven, the SBA will pay the interest that has accrued with respect to the forgiven amount. Accrued interest on any unforgiven balance remaining will be included in your payments that will become due at the end of the deferral period.

 

4) Who is authorized to apply for PPP loan forgiveness?

When it comes time to apply, the application for PPP loan forgiveness must be completed, certified and signed by an Authorized Representative of the borrower.

An Authorized Representative is a person who has the power and authority to apply for and sign the PPP loan forgiveness application and other document(s) required for PPP loan forgiveness on behalf of the borrower; and who is authorized to sign and to make certifications for and on behalf of the borrower and on behalf of each owner of 20% or more of the borrower’s equity.

 

5) When does the Covered Period begin for spending so that it may be eligible for loan forgiveness?

Please refer to the definitions of Covered Period and Alternative Payroll Covered Period on the instructions for the SBA's PPP loan forgiveness applications. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

6) When do I need to use the loan proceeds to be eligible for forgiveness?

Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on the instructions for the SBA's PPP loan forgiveness applications. Also refer to FAQ 8 above as to your Covered Period. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

7) If I spent my loan funds within the Covered Period, could I receive forgiveness on both the loan amount and the interest?

Yes, for the portion that meets all the SBA rules and if the SBA approves your request for loan forgiveness.

 

8) Can I apply for loan forgiveness if I did not use all of my loan funds during the Covered Period?

You may apply for partial forgiveness if you did not use all of your loan proceeds for eligible expenses during the Covered Period, if you meet all SBA rules and if the SBA approves your request for loan forgiveness for that amount. Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on instructions for the SBA's Paycheck Protection Program loan forgiveness application. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

9) What spending might qualify for forgiveness?

Please refer to the definitions of Eligible Payroll Costs and Eligible Nonpayroll Costs on the instructions for the SBA's PPP loan forgiveness applications. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

10) Do mortgage principal and prepayments qualify for forgiveness?

Please refer to the definition of Eligible Nonpayroll Costs on the instructions for the SBA's PPP loan forgiveness application. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

11) For loans approved prior to June 5, 2020, is the Covered Period 8 to 24 weeks or 8 or 24 weeks?

The Paycheck Protection Program Flexibility Act of 2020 made changes to the PPP rules, increasing the initial 8-week Covered Period to 24 weeks (though borrowers with loans approved prior to June 5, 2020, may still elect to use the initial 8-week Covered Period). According to rules issued by the SBA, a borrower may submit a loan forgiveness application any time - including before the end of the Covered Period - if the borrower has used all of the loan proceeds for which the borrower is requesting forgiveness. However, if the borrower applies for forgiveness before the end of the applicable Covered Period and has reduced any employee's salaries or wages in excess of 25 percent, the borrower must account for the excess salary reduction for the full 8-week or 24-week Covered Period, as applicable, in accordance with SBA rules.

 

Applying for loan forgiveness

 

12) How will I apply for loan forgiveness?

Comerica is utilizing an online portal for accepting forgiveness applications. The requirements of the portal mirror those of the SBA's paper applications; however, the electronic format will facilitate automating the calculations and streamlining the process of submitting the application to Comerica and, in turn, to the SBA, as well as the required review process by both parties. Working with the SBA's form of application is a good preparation for the forgiveness process; however, we are not accepting forgiveness applications outside of our online portal.

 

13) When can I request loan forgiveness for a PPP loan?

In mid-October, we sent an email to the Authorized Representative on file which laid out the timeline for invitations to apply for forgiveness. If you did not receive this email, please contact your assigned Relationship Manager, Banking Center Manager, or the Comerica Contact Center at 800.979.0850, Monday through Friday 8 a.m. to 9 p.m. ET and Saturday 8 a.m. to 5 p.m. ET.

According to SBA rules, a borrower may submit a loan forgiveness application any time - including before the end of the Covered Period - if the borrower has used all of the loan proceeds for which the borrower is requesting forgiveness. However, if the borrower applies for forgiveness before the end of the applicable Covered Period and has reduced any employee's salaries or wages in excess of 25 percent, the borrower must account for the excess salary reduction for the full 8-week or 24-week Covered Period, as applicable, in accordance with SBA rules. 

If a forgiveness application has not been submitted to the lender, the principal and interest deferral period will last until 10 months after the end of the borrower's 24-week covered period. This represents an approximate 15-and-a-half-month period before loan payments must begin. Even after this deferral period has concluded, a forgiveness application can still be submitted at any time prior to loan maturity.

 

14) What should I do to prepare for my loan forgiveness request?

Review the appropriate SBA's PPP loan forgiveness application as a guide. Allow yourself ample time and effort to prepare; we encourage you to download the appropriate application and use it to organize your information in advance so you may complete your online application efficiently and accurately.

Reference the appropriate SBA’s instructions and guidance about calculating your requested forgiveness amount, documenting your eligible business costs, determining impact of FTE reduction and more. If applicable, complete the PPP Schedule A Worksheet (pages 4-5 in the full application form) and ensure the accuracy of the data which you will provide in your online application.

Please do not submit the SBA's PPP loan forgiveness application to us, it is meant to only serve as a guide; we will only accept information entered on our online loan forgiveness application site. The PPP Loan Forgiveness Applications are for reference and informational purposes only.

Review the PPP Loan Forgiveness: Required Documentation guide we have created to familiarize yourself with the types of documents you will need to provide during the loan forgiveness process.

We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you. Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting the SBA’s PPP website or the U.S. Department of the Treasury website.

 

15) What documents do I need to include when I apply for forgiveness?

Review the PPP Loan Forgiveness: Required Documentation guide we have created to familiarize yourself with the types of documents you will need to provide during the loan forgiveness process.We recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you. You should also review the SBA's PPP loan forgiveness applications.

Please do not submit the SBA's PPP loan forgiveness application to us, it is meant to only serve as a guide; we will only accept information entered on our online forgiveness application site. The PPP Loan Forgiveness Applications are for reference and informational purposes only.

Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

16) How do I calculate FTEs in the context of PPP loan forgiveness?

No- per SBA guidance, providing an accurate calculation of the loan forgiveness amount is the responsibility of the borrower. Lenders are expected to perform a good-faith review, in a reasonable time, of the borrower's calculations and supporting documents. If the lender identifies errors in the borrower's calculation or material lack of substantiation in the borrower's supporting documents, the lender should work with the borrower to remedy the issue.

Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting the SBA’s PPP website or the U.S. Department of the Treasury website. We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you.

 

17) Can Comerica Bank calculate my loan forgiveness amount for me?

No- per SBA guidance, providing an accurate calculation of the loan forgiveness amount is the responsibility of the borrower. Lenders are expected to perform a good-faith review, in a reasonable time, of the borrower's calculations and supporting documents. If the lender identifies errors in the borrower's calculation or material lack of substantiation in the borrower's supporting documents, the lender should work with the borrower to remedy the issue.

Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting the SBA’s PPP website or the U.S. Department of the Treasury website. We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you.

 

18) Which SBA PPP Loan Forgiveness Application should I use?

On June 16, the SBA revised the forgiveness application to incorporate changes enacted by the PPP Flexibility Act of 2020. The SBA also issued a second PPP loan forgiveness application. The new EZ Forgiveness Application requires fewer calculations and less documentation for eligible borrowers. Eligible borrowers under the EZ Forgiveness Application are defined as:

- Those who are self-employed

- OR those did not reduce the salaries or wages of their employees by more than 25%, and did not reduce the number of their employees

- OR those who experienced reductions in business activity as a result of health directives related to COVID-19 and did not reduce the salaries or wages of their employees by more than 25%

On October 8, the SBA released a third forgivness application that is applicable to PPP loans of $50,000 and less.

If your loan does not fall within one of the above definitions, you should refer to the standard loan forgiveness application.

Please do not submit any of the SBA's PPP loan forgiveness applications to us, they are meant to only serve as a guide; we will only accept information entered on our online forgiveness portal. The PPP loan forgiveness applications are for reference and informational purposes only.

We also recommend you consult with an accounting professional for specific questions about documenting your eligible expenses, as well as review your PPP loan documents with any legal or financial advisors who may support you.

Since legislative developments may cause SBA program guidelines to evolve, be sure to stay informed by visiting the SBA’s PPP website or the U.S. Department of the Treasury website.

 

19) Can Comerica make a change or update to my forgiveness application if I request it?

We are not able to make changes to your application for you. Once you submit your application, we cannot guarantee that you will have the ability to make changes, so we encourage you to confirm your application is complete and accurate prior to submitting. If you would like to make changes to your application after submitting it, you may initiate a request to reopen your application, but we cannot provide assurances that we will be able to do so in all cases. If your application is able to be reopened, you will need to make the desired changes, upload any additional documents that are required as a result of the change, and re-certify your updated application in a timely manner so that your application can be processed within our 60-day review period.

 

20) If I am applying for forgiveness using a period prior to the end of the Covered Period, how do I reconcile this with the Covered Period definition throughout the application?

The most recent PPP Loan Forgiveness Applications and instructions were published by the SBA on June 16 and the rule clarifying that a borrower may submit a loan forgiveness application any time (including before the end of the Covered Period - if the borrower has used all of the loan proceeds for which the borrower is requesting forgiveness) was issued on June 22. We have requested clarification of this issue from the SBA through our industry trade organizations as to whether there will be an updated application issued that reconciles this, but we have not received a response at this time. Unless or until such further guidance is provided, we would encourage you to consult with your advisors on how to appropriately complete the current form of application.

 

21) How do I determine my Lender PPP Loan Number as required on the forgiveness application?

The Lender PPP Loan Number will be auto-populated in our portal.

 

22) Can I withdraw my PPP Loan Forgiveness application after I have already submitted the request?

Yes, please access the Message Center on your PPP Dashboard to submit the request to withdraw your PPP loan forgiveness application. The request should include a reason you are requesting the application to be withdrawn.

 

23) If Comerica has questions related to my forgiveness application or its attachments, does that reset the 60-day review window?

The SBA requires that we complete our review process within 60 days of the date you originally submitted your application to us. Failure to resolve open issues with your application in a timely manner so that we may complete our review during this 60-day window could result in your application being Approved in Partial or Declined, as questions do not extend the review window.

 

24) If Comerica has submitted my forgiveness application to the SBA, can I consider it approved?

No. Although Comerica may submit your forgiveness application to the SBA, Comerica makes no determination as to whether you will be entitled to forgiveness; that decision rests solely with the SBA

 

25) How long will it take to process my application?

Once you have submitted a complete application, SBA guidelines provide lenders with 60 days to review and process the application prior to sending it to the SBA for approval. Once an application is submitted to the SBA, the SBA has an additional 90 days to review the application before making a decision.

To gain a better understanding of timing for the forgiveness process, leverage our loan forgiveness timeline calculator to input your information. The information provided by the calculator relies on the dates and responses provided by you, and is for illustration purposes for your convenience only. Comerica makes no representations or warranties as to the accuracy of the dates shown, and we encourage you to refer to your loan documents and the SBA PPP website for the authoritative terms, provisions and rules governing your PPP loan.

 

26) If I received an SBA Economic Injury Disaster Loan (EIDL) Advance, does that change my PPP forgiveness amount/process?

If a borrower received an EIDL advance, the SBA is required to reduce the borrower's loan forgiveness amount by the amount of the EIDL advance. The SBA will automatically deduct the amount of the EIDL advance from the forgiveness amount remitted by the SBA to the lender. For further information, please review the EIDL section of the SBA FAQ document.

 

27) Why can’t I upload or even see the documents before I complete the PPP Loan Forgiveness Application Dashboard?

The application must be complete before documents can be uploaded because document placeholders render conditionally based on the submitted forgiveness application.

 

Potential reductions in loan forgiveness

 

28) Will my forgiveness amount be reduced for cases where a borrower laid-off or reduced hours of an employee, then offered to rehire the same employee for the same salary and same number of hours or restore reduction in hours, and the employee rejected the offer?

Please refer to the definition of FTE Reduction Exceptions on the instructions for the SBA's PPP Loan Forgiveness Applications. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

29) Will my loan forgiveness amount be reduced for employees that were fired for cause, voluntary resigned, or voluntarily requested a schedule reduction?

Please refer to the definition of FTE Reduction Exceptions on the SBA's PPP loan forgiveness applications. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

30) What if I wasn't able to rehire my employees until partway through my loan forgiveness period?

Please refer to the definition of FTE Reduction Exceptions on the instructions for the SBA's PPP loan forgiveness applications. Please continue to check the SBA.gov and Treasury.gov sites for the latest information.

 

31)  What is the time period that my FTE reduction will be based upon if I apply prior to the end of my Covered Period?

The way the current application is drafted notes that it should be the earlier of December 31, 2020 and the date of application. However, the most recent PPP Loan Forgiveness Applications and instructions were published by the SBA on June 16th and the rule clarifying that a borrower may submit a loan forgiveness application any time (including before the end of the Covered Period - if the borrower has used all of the loan proceeds for which the borrower is requesting forgiveness) was issued on June 22, 2020. We have requested clarification of this issue from the SBA through our industry trade organizations as to whether there will be an updated application issued that reconciles this, but we have not received a response at this time. Unless or until such further guidance is provided, we would encourage you to consult with your advisors on how to appropriately complete the current form of application.

 

Utilizing PPP funds

 

32) Can I use PPP funds to reimburse expenses paid through my personal account?

Yes, if the expense is an eligible use of PPP proceeds under SBA and Treasury guidance.

 

33) Can I pay back part or all of my loan sooner than the note maturity?

Yes. Please refer to the SBA.gov and Treasury.gov sites for the latest information.

 

General

 

34) Do I need to have a separate bank account for my PPP funds?

The SBA does not require a separate account.

 

35) Can the SBA still audit my loan after they’ve approved my loan’s forgiveness?

According to the “Documents that Each Borrower Must Maintain but is Not Required to Submit” section of the SBA’s PPP Forgiveness Application Instructions, “The Borrower must retain all such documentation in its files for six years after the date the loan is forgiven or repaid in full, and permit authorized representatives of SBA, including representatives of its Office of Inspector General, to access such files upon request.”

 

36) How do I change the Authorized Representative email address on file for my PPP loan?

Please contact your assigned Relationship Manager, Banking Center Manager, or the Comerica Contact Center at 800.979.0850, Monday through Friday from 8 a.m. to 9 p.m. ET and Saturday 8 a.m. to 5 p.m. ET.