Another task that lenders can tackle now is to register with SAM.gov, the System for Award Management (SAM). It is the federal government’s system for registering contractors and any business that intends to do business with it. Registering with SAM.gov is a new requirement during this round of the PPP and is part of the SBA’s efforts to combat fraud. Within the SBA’s interim final rule for new and increased PPP loans issued Jan. 6 was the following information:
Do lenders have to register in SAM.gov to make PPP loans?95
Yes. Given the exigent circumstances in which small businesses and lenders currently find themselves due to the COVID-19 pandemic, PPP lenders will have thirty (30) days from the date of the first PPP loan disbursement made by them after December 27, 2020, to complete SAM registration and provide SBA with the lender’s unique entity identifier.
95 This subsection adds a new requirement that all PPP lenders must register in SAM.gov. See 2 CFR 25.110(c)(2)(iii).
To register for SAM.gov, you first must have a login.gov account. (https://login.gov/help/creating-an-account/how-to-create-an-account/).
Then, you will need to create a user account in SAM, which will require providing detailed information about the financial institution, including the DUNS number, legal business name, and taxpayer ID number. The account must also be verified.
Lenders aren't required to affirm they have already registered with SAM.gov in order to process applications on the PPP platform. However, SBA staff have indicated the assumption is that if lenders are processing applications, the registration is underway -- if not completed.