CBA Letter for House Small Business Hearing re SBA and PPP

September 23, 2020



The Honorable Nydia M. Velázquez


Committee on Small Business

U.S. House of Representatives

2302 Rayburn House Office Building

Washington, D.C. 20515


The Honorable Steve Chabot

Ranking Member                                                            

Committee on Small Business

U.S. House of Representatives

2371 Rayburn House Office Building

Washington, D.C. 20515




Dear Chairwoman Velázquez and Ranking Member Chabot:


On behalf of the Consumer Bankers Association (CBA), I would like to thank you for convening the Committee on Small Business hearing on “Paycheck Protection Program: An Examination of Loan Forgiveness, SBA Legacy Systems, and Inaccurate Data.” We appreciate the Committee’s continued oversight of the programs established under the CARES Act, specifically the Paycheck Protection Program (PPP). CBA is the voice of the retail banking industry, whose products and services provide access to credit for consumers and small businesses.


The PPP has been welcomed by small businesses across the country and considered a lifeline for the millions of men and women who work at them. Banks of all sizes have worked tirelessly to implement and execute the program, doing everything humanly possible to support U.S. small businesses and provide them assistance through the PPP. The efforts by lenders, Congress, the Small Business Administration (SBA), and the Department of the Treasury have helped over 5 million small businesses receive the support they need to endure through the COVID-19 pandemic.


With the opening of the Paycheck Protection Forgiveness Platform on August 10th, these millions of small businesses have begun to tackle the forgiveness process which is proving to be a burdensome and complex undertaking. In response, CBA joined a coalition of over a hundred various business, financial service, and non-profit trades submitted a letter to Congressional leadership expressing the need for a streamlined forgiveness process for the smallest of small businesses participating in the PPP. [1] CBA and our coalition partners call for immediate passage of H.R. 7777, The Paycheck Protection Small Business Forgiveness Act, bipartisan legislation sponsored by Reps. Chrissy Houlahan and Fred Upton, that would simplify the forgiveness process and ensure small businesses can focus their time, energy, and resources back into their business and communities instead of allocating significant time and resources in completing complex forgiveness forms.


In lieu of Congressional action, the Treasury and the SBA should commit additional resources to provide an expedited forgiveness process for small business borrowers with loan amounts of not more than $150,000 under the agencies’ de minimis exemption authority. This is an appropriate threshold that mirrors existing legislation with broad bipartisan and bicameral support as well as input from industry and small business PPP participants. PPP loans of $150,000 and under account for less than 28 percent of PPP loan dollars distributed. Creating a streamlined simple one-page attestation process for loan forgiveness will relieve small businesses from the burden of compiling documentation and unnecessarily complex forms while simultaneously struggling to reopen and support economic recovery.


Additionally, CBA supports strengthening the “Hold Harmless” provisions originally in the CARES Act.[2] Banks across the country readily answered the call to participate in PPP to ensure small businesses and their employees would receive needed support in these unprecedented times, largely without essential guidance and regulations required by any loan program in place. Congress should ensure that lenders who met this challenge and participated in PPP are protected by extending the appropriate liability protections provided in the Hold Harmless provisions to the entire PPP loan process, not just the forgiveness aspect.


Congress and the administration should work together during these unpredictable and unprecedented economic times to bring quick and decisive action for the smallest of businesses so they may get back to serving their customers and employees. Our members remain eager to help small businesses and look forward to Congress and the Administration making the necessary changes to the Paycheck Protection Program so it can be become more efficient and better utilized by borrowers and lenders.




Richard Hunt

President and CEO







September 17, 2020



The Honorable Mitch McConnell                                The Honorable Nancy Pelosi                       

Majority Leader                                                            Speaker        

U.S. Senate                                                                   U.S. House of Representatives                    

428A Russell Senate Office Building                          H-232 U.S. Capitol

Washington, D.C. 2-0510                                             Washington, D.C. 20510


The Honorable Charles Schumer                                The Honorable Kevin McCarthy                  

Democratic Leader                                                      Minority Leader 

U.S. Senate                                                                  U.S. House of Representatives

428A Russell Senate Office Building                         H-204 U.S. Capitol

Washington, D.C. 20510                                            Washington, D.C. 20515



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


The undersigned associations representing thousands of banks, credit unions, financial institutions, nonprofits and businesses of all sizes that serve America’s consumers write to express our strong support for 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. We ask that Congress immediately pass these much-needed bipartisan pieces of legislation, supported by a third of the Senate and 77 members of the House of Representatives, that would streamline the forgiveness process for mom-and-pop businesses who received Paycheck Protection Program loans during these unprecedented times.


The Paycheck Protection Program (PPP), established by Congress, provided millions of small businesses the economic relief they needed to meet the challenges posed by the COVID-19 crisis. Now that the program has ended, small business owners and nonprofits are facing the challenges of reopening local economies in a time of uncertainty, retooling their businesses, working to protect the health of both customers and employees, and serving the needs of the community. Small businesses across the country are facing the time-consuming and costly process of applying for PPP loan forgiveness. S. 4117 and H.R. 7777 ensure those businesses can focus their time, energy, and resources back into their business and communities instead of allocating significant time and resources 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 these pieces of 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.[3] 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 business we serve, we urge you to improve the PPP forgiveness process and support S. 4117 and H.R. 7777. 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.





Aeronautical Repair Station Association

Air Conditioning Contractors of America 

American Bankers Association

American Coatings Association

American Farm Bureau Federation

American Financial Services Association

American Foundry Society

American Hotel & Lodging Association

American Land Title Association

American Road & Transportation Builders Association

American Staffing Association

America's Small Business Development Center Network

Asian American Hotel Owners Association

Associated Equipment Distributors

Associated Industries of Massachusetts

Associated Wire Rope Fabricators

Association of Credit and Collection Professionals

Association of Marina Industries

Association of Woodworking & Furnishing Suppliers

Bank Policy Institute

Brick Industry Association  

CAMEO- California Association for Micro Enterprise Opportunity

CCIM Institute

Commercial Food Equipment Service Association

Consumer Bankers Association

Credit Union National Association

Decorative Hardwoods Association 

Electronic Transactions Association

Farm Credit Council

Financial Services Forum

Foodservice Equipment Distributors Association

Global Cold Chain Alliance

Golf Course Superintendents Association of America


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 and Brokers of America

Innovative Lending Platform Association

Institute of Real Estate Management

International Franchise Association

International Sign Association


Manufactured Housing Institute

Manufacturer & Business Association

Mid-Size Bank Coalition of America

Modular Building Institute

Motor and Equipment Manufacturers Association

National Association for Surface Finishing

National Association for the Self-Employed

National Association of Chain Drug Stores

National Association of Chemical Distributors

National Association of Federally-Insured Credit Unions

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 Women Business Owners

National Bankers Association

National Career Development Association

National Community Pharmacists Association

National Cotton Council

National Council of Chain Restaurants

National Council of Nonprofits

National Demolition Association

National Electrical Contractors Association

National Electrical Manufacturers Representative Association

National Independent Automobile Dealers Association

National Investor Relations Institute

National Limousine Association

National Lumber & Building Material Dealers Association

National Restaurant Association

National Retail Federation

National RV Dealers Association.

National Association of Home Builders

New York State Land Title Association


North American Association of Food Equipment Manufacturers

Painting Contractors Association

Pennsylvania Food Merchants Association 

Pet Industry Distributors Association

Petroleum Marketers Association of America

Private Practice Section of the American Physical Therapy Association

Secondary Materials and Recycled Textiles Association

Security Industry Association

Small Business & Entrepreneurship Council

Small Business Council of America

Small Business Legislative Council (SBLC)

Small Business Majority

Society of Collision Repair Specialists

South Carolina Restaurant and Lodging Association

Southwest Cable Communications Association

Specialty Equipment Market Association

Texas Bankers Association

The Mineral, Metals, and Materials Society

The National Association of Trailer Manufacturers

Tire Industry Association

U.S. Chamber of Commerce

U.S. Hispanic Chamber of Commerce

United Veterinary Services Association

Vacation Rental Management Association

Washington Retail Association

Water Quality Association

Wine & Spirits Wholesalers of America

Women Impacting Public Policy (WIPP)

World Floor Covering Association

Young Audiences Arts for Learning































[1]  See “Addendum A” - Trade Association letter signed by approximately 110 business, financial service, and non-profit groups dated September 17, 2020.  

[2] The Coronavirus Aid, Relief, and Economic Security (CARES) Act, Section 1106, Subsection (h), “Hold Harmless”

[3]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,