SBA Releases Long-Awaited Guidance on Form 1502 for PPP Processing Fees
May 21, 2020
The Small Business Administration has just issued guidance to Paycheck Protection Program lenders on filing Form 1502, which will trigger the payment of PPP loan processing fees to lenders. SBA will begin accepting Form 1502 filings tomorrow; lenders must submit Form 1502 data for all PPP loans by May 29 or 10 calendar days after the loan is disbursed or canceled, whichever is later.
To file Form 1502, lenders—or their service providers—must have an existing account or create a new account with SBA’s fiscal transfer agent, Colson Services. The guidance provides details on how to access Colson’s lender portal and submit Form 1502 data. Lenders must submit separate 1502 reports for PPP and other 7(a) program loans. For PPP loans that have been sold, the originating lender is responsible for the initial Form 1502 submission.
While lenders must file Form 1502 data for all PPP loans disbursed or canceled, 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.
SBA said that it will not pay processing fees for PPP loans canceled, terminated or repaid due to an SBA loan review finding the borrower ineligible. The agency added that lender processing fees may be clawed back within a year after disbursement if SBA later determines the borrower to be ineligible, although this determination will not affect the SBA guaranty for the loan, provided the lender “has complied with its obligations under section III.3.b of the initial PPP Interim Final Rule.” Read the guidance.