Rundown of Updated PPP Forgiveness Application Forms for Both First and Second Draw Loans

Sep 19, 2026

Information memo dated January 21, 2021 outlining the Small Business Administration (SBA) updates to PPP Loan Forgiveness Applications reflecting recent legislation. It summarizes which updated forms to use for first-draw borrowers, including the simplified Form 3508EZ for qualifying loans under $2,000,000 and the streamlined Form 3508S for loans up to $150,000. It also covers the full Form 3508 requirements for loans over $150,000 and notes exceptions related to salary and headcount reductions, plus guidance to consult lenders.

LanguageEnglish

CategoryForms

FormatPDF

Pages1

AccessFree to download

Simplified Forgiveness Application (Form 3508EZ)

Loan size under $2,000,000 and eligibility qualifications

Loans Under $150,000

One-page submission and documentation handling

Loans in Excess of $150,000

Full Form 3508 requirements and safe-harbor recap

Attorney Support and Disclaimer

INFORMATION MEMO BUSINESS AND TRANSACTIONS JANUARY 21, 2021 Rundown of Updated PPP Forgiveness Application Forms for Both First and Second Draw Loans The Small Business Association (SBA) recently updated all versions of the PPP Loan Forgiveness Applications to reflect changes in the recent legislation. Borrowers who have yet to apply for forgiveness on their First Draw PPP should use these updated forms and consult with their lender. Some lenders are utilizing equivalent versions of the forms. Also, some lenders have delayed accepting the forgiveness applications while they address the second round of PPP funding. Simplified Forgiveness Application (Form 3508EZ) The updated EZ PPP Loan Forgiveness Application Form 3508EZ and corresponding instructions is available here. Borrowers who received a loan less than $2,000,000 (combined with affiliates) may use this form as long as they satisfy one of the two following qualifications: 1) there were no reductions in salaries by more than 25% during the covered period and no reductions in number of employee headcounts (with some exceptions); or 2) the borrower did not reduce salaries by more than 25% during the covered period and the borrower was unable to operate at the same level of business activity due to government shutdown orders. Loans Under $150,000 The updated simplified PPP Loan Forgiveness Application Form 3508S and corresponding instructions is available here. The recent legislation increased the threshold amount for this simplified application to $150,000 . If a borrower has a PPP loan equal to or less than this amount, the borrower may simply submit this one-page form to its lender; supporting documentation is not required to be submitted, but only maintained. Loans in Excess of $150,000 The updated full version of the PPP Loan Forgiveness Application Form 3508 and corresponding instructions is available here. As a recap, borrowers who received a loan of $2,000,000 or more (combined with affiliates) must use this form, as well as borrowers who reduced salaries and/or employee headcounts and do not qualify for a safe harbor noted above under the 3508EZ application. The attorneys at Bond, Schoeneck and King can help you apply for forgiveness on your First Draw PPP loan. Please contact Jeffrey B. Scheer or the attorney at the firm with whom you are regularly in contact. Bond has prepared this communication to present only general information. This is not intended as legal advice, nor should you consider it as such. You should not act, or decline to act, based upon the contents. While we try to make sure that the information is complete and accurate, laws can change quickly. You should always formally engage a lawyer of your choosing before taking actions which have legal consequences. For information about our firm, practice areas and attorneys, visit our website, [www.bsk.com](www.bsk.com). • Attorney Advertising • © 2020 Bond, Schoeneck & King PLLC CONNECT WITH US ON LINKEDIN: SEARCH FOR BOND, SCHOENECK & KING, PLLC FOLLOW US ON TWITTER: SEARCH FOR BONDLAWFIRM

FAQs

What prompted the SBA updates to PPP loan forgiveness applications?

The SBA updated all versions of the PPP Loan Forgiveness Applications to reflect changes in recent legislation.

When can borrowers use the simplified Form 3508EZ?

Borrowers with loans less than $2,000,000 (combined with affiliates) may use Form 3508EZ if they meet either the salary/headcount reduction conditions or the government shutdown-related inability to operate at the same activity level.

Which PPP forgiveness form should be used for loans over $150,000?

Borrowers must use the full Form 3508 for loans in excess of $150,000, including cases where the borrower reduced salaries and/or employee headcounts and does not qualify for the safe harbor described for the 3508EZ application.

Sep 19, 2026

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