For loans over $150,000, the SBA requires that borrowers submit their first draw loan forgiveness applications to SBA before they can submit their second draw loan forgiveness application.
"For Second Draw PPP Loans in excess of $150,000, the borrower must submit its loan forgiveness application for the First Draw PPP Loan before or simultaneously with the loan forgiveness application for the Second Draw PPP Loan, even if the calculated amount of forgiveness on the First Draw PPP Loan is zero."