Justification

U.S. SMALL BUSINESS ADMINISTRATION
WASHINGTON, DC 20416

December 9, 2020
Susan Minson
SBA Desk Officer
Office of Management and Budget
Dear Ms. Minson:
Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR
1320, SBA requests that the collection of information titled, Lender Certification for
Reinstatement or Correction of Paycheck Protection Program (PPP) Loan, be processed in
accordance with section 1320.13, Emergency Processing. SBA has determined that this
information must be collected prior to the expiration of time periods established under Part 1320,
and that this information is essential to the SBA’s ability to evaluate lenders’ requests for
reinstatement of PPP loans that were cancelled in SBA’s ETRAN system due to lenders’ data
input errors and/or correction of lenders’ data input errors in the SBA Loan Approval Amount of
PPP loans on ETRAN. SBA has been accepting forgiveness decisions from lenders and making
forgiveness payments on PPP loans, therefore the ability to collect this information without
having to go through the standard Paperwork Reduction Act review procedures will enable SBA
to review and correct lenders’ data input errors, if appropriate. This will enhance the integrity of
the program and improve SBA’s oversight and monitoring responsibilities.
Lenders that cancelled a PPP loan in SBA’s ETRAN system due to the lender’s data input error
or made a data input error in the SBA Loan Approval Amount of a PPP loan on ETRAN will use
this form to request that the SBA Loan Approval Amount be corrected or that an erroneously
cancelled loan be reinstated. SBA will use the information provided in the Lender Certification
for Reinstatement or Correction of Paycheck Protection Program (PPP) Loan to evaluate the
nature of the lender’s error and to determine whether the loan should be reinstated or whether the
SBA Loan Approval Amount should be corrected. Lenders will submit this information directly
to one of SBA’s Loan Servicing Centers.
SBA requests approval of the submission by December 10, 2020. Given the inability to seek
public comment during such a short timeframe, SBA also requests a waiver from the
requirement to publish 60-day and 30-day notices in the Federal Register seeking public
comment during the period of OMB review. Although SBA is unable to consult with the public
prior to issuing the forms, the Agency has experience designing similar forms in a way that is
clear and minimizes burden on respondents.
Sincerely,

JI KIM

Digitally signed by JI KIM
Date: 2020.12.09 10:16:43
-05'00'

Jihoon Kim
Director, Office of Financial Program Operations