BPI and Joint Coalition Urge House and Senate Leadership to Address PPP Forgiveness Process

Dear Majority Leader McConnell, Speaker Pelosi, Democratic Leader Schumer and Minority Leader McCarthy:

We, the undersigned associations representing thousands of banks, credit unions, financial institutions, nonprofits and businesses of all sizes that serve America’s consumers, write to urge you to immediately address the overburdensome Paycheck Protection Program (PPP) forgiveness process before the end of the year. Congress can solve this problem and inject the equivalent of $7 billion into our economy by passing bipartisan, common-sense legislation to streamline PPP forgiveness for small businesses on Main Street in communities across the country.

We encourage Congress to quickly consider legislation that will help countless businesses navigate the overly complex forgiveness process. S. 4117, The Paycheck Protection Program Small Business Forgiveness Act, sponsored by Senators Kevin Cramer, Bob Menendez, Thom Tillis and Kyrsten Sinema and H.R. 7777, The Paycheck Protection Small Business Forgiveness Act, sponsored by Reps. Chrissy Houlahan and Fred Upton are bipartisan and bicameral legislation introduced earlier this Congress and would reduce compliance costs by streamlining the forgiveness process for mom-and-pop businesses who received PPP loans during these unprecedented times. Additionally, passing such legislation that would expand the hold harmless protections for lenders will provide financial institutions that originated and currently service PPP loans the opportunity to focus their time and energy on providing much-needed credit and financial services to individuals and businesses by creating regulatory certainty for PPP loans in the future.

The PPP forgiveness process has already begun for banks and will continue for them and for millions of American businesses in the coming months. Businesses have been patiently awaiting for Congress to act, hoping that an improved and streamlined forgiveness process will ensure they can focus their time, energy, and resources back into their business and communities instead of allocating significant time and expense into completing complex forgiveness forms.

America’s small businesses, and the millions of men and women who work at them, are the foundations of communities across the country and the economy and in order to assist them, we urge Congress to quickly pass legislation that would forgive PPP loans of less than $150,000 upon the borrower’s completion of a simple, one-page forgiveness document. PPP loans of

$150,000 and under account for 87 percent of total PPP recipients, but less than 28 percent of PPP loan dollars. Expediting the loan forgiveness process for many of these hard-hit businesses would save more than $7 billion and hours of paperwork.

Data provided in an independent analysis by AQN Strategies (AQN) has shown an estimated benefit of issuing auto-forgiveness for various loan size thresholds.[1] AQN anticipates the combined resource requirements of operators’ time and/or third-party expenses to represent an effective cost of $2,000-$4,000 for each business that applies for forgiveness, requiring 20-100 hours of focused time from key leaders of these businesses. With an average loan size of less than $19,000 for the smallest 60% of loans, this estimate would represent 10-20% of the loan amount itself, which is otherwise intended to support payroll, rent, and other obligations necessary to keep businesses alive and ready to restart. In addition, AQN’s analysis suggests that the cost to businesses and lenders would be lower than the cost for the government to auto- forgive loans.

On behalf of our members and the millions of small businesses we serve, we urge you to improve the PPP forgiveness process and support streamlined forgiveness efforts. Financial institutions across the country stand ready to service a second round of PPP loans for our small business and nonprofit customers, but Congress must act now in order to ensure a second round of funds reach those most severely impacted expeditiously. Time is of the essence and we look forward to working with you to pass these critical bills. Thank you for your strong, common- sense leadership on such a critical issue.

Sincerely,

Aeronautical Repair Station Association

AICC, The Independent Packaging Association

Air Conditioning Contractors of America (ACCA)

American Bankers Association

American Case Management Association

American Dental Association

American Farm Bureau Federation

American Financial Services Association

American Foundry Society

American Hotel & Lodging Association

American Jail Association

American Land Title Association

American Road & Transportation Builders Association (ARTBA)

American Staffing Association

America’s SBDC

Asian American Hotel Owners Association

Associated General Contractors of America

Associated Industries of Massachusetts

Associated Wire Rope Fabricators

Association for Comprehensive Energy Psychology

Association for Enterprise Opportunity

Association of Credit and Collection Professionals

Association of Marina Industries

Association of Women’s Business Centers

Association of Woodworking & Furnishing Suppliers

Bank Policy Institute

Brick Industry Association

CAMEO- California Association for Micro Enterprise Opportunity

Commercial Food Equipment Service Association – CFESA

Consumer Bankers Association

Credit Union National Association

Decorative Hardwoods Association

DHI – Door Security + Safety Professionals

Electronic Transactions Association

Electronics Representatives Association

Financial Services Forum

Foodservice Consultants Society International – The Americas Division

Golf Course Superintendents Association of America

GovEvolve

Habitat for Humanity International

Home Furnishings Association

HUBZone Contractors National Council

Independent Beauty Association

Independent Community Bankers of America

Independent Electrical Contractors

Independent Insurance Agents & Brokers of America

Innovative Lending Platform Association

International Franchise Association

International Sign Association

Leading Builders of America

Manufacturer & Business Association

Marine Retailers Association of the Americas

Mid-Size Bank Coalition of America

Modular Building Institute

Modular Home Builders Association

National Association for Surface Finishing

National Association for the Self-Employed

National Association of Chain Drug Stores

National Association of Federally-Insured Credit Unions

National Association of Home Builders

National Association of Professional Employer Organizations

National Association of Professional Insurance Agents

National Association of Realtors

National Association of Surety Bond Producers

National Association of Tax Professionals

National Association of the Remodeling Industry

National Career Development Association

National Community Pharmacists Association

National Cotton Council

National Electrical Contractors Association

National Electrical Manufacturers Representatives Association (NEMRA)

National Limousine Association

National Marine Manufacturers Association

National Restaurant Association

National Retail Federation

National RV Dealers Association (RVDA)

National Stone, Stand & Gravel Association

National Wooden Pallet & Container Association

New York State Land Title Association

North American Association of Food Equipment Manufacturers (NAFEM)

Page 30 Coalition

Painting Contractors Association

Pet Industry Distributors Association.

Professional Beauty Association (PBA)

Secondary Materials and Recycled Textiles Association

Small Business Roundtable

Society of American Florists

Society of Collision Repair Specialists (SCRS)

South Carolina Restaurant & Lodging Association

Specialty Equipment Market Association (SEMA)

Specialty Tools & Fasteners Distributors Association

The Brick Industry Association

The Energy Marketers of America (EMA)

The Global Cold Chain Alliance

The Mineral, Metals, and Materials Society

The National Association of Trailer Manufacturers

The National Bankers Association

The National Council of Investigation & Security Services

The Promotional Products Association International (PPAI)

The Small Business Council of America

The Small Business Legislative Council

The Texas Bankers Association

Tire Industry Association

U.S. Black Chambers

U.S. Chamber of Commerce

United States Hispanic Chamber of Commerce

United Veterinary Services Association

Vacation Rental Management Association

Washington Retail Association

Women Impacting Public Policy (WIPP)

World Floor Covering Association

Young Audiences Arts for Learning


[1] Ben Sabloff, Jason Ford, Gaby Garcia, “Is It Easier to Ask for Forgiveness Than Permission? Not for PPP Loans Under $150K” AQN Strategies, June 1, 2020, https://www.aqnstrategies.com/aqncentral/forgive-small-ppp