SBA Drops PPP Necessity Questionnaire on $2 Million Loans

By Jennifer Mailhes, CPA – Shareholder, Business Advisory Group

On July 9, the Small Business Administration (SBA) announced it has rescinded its requirement for Paycheck Protection Program (PPP) borrowers with loans greater than $2 million to complete a loan necessity questionnaire. This change was made effective immediately, but the SBA said there are FAQs to come to offer more clarity.

Since November 2020, the SBA has required Form 3509, Loan Necessity Questionnaire (For-profit borrowers) and Form 3510, Loan Necessity Questionnaire (Non-profit borrowers) for borrowers requesting PPP loan forgiveness of $2 million or more. The questionnaires, designed to help certify the need for the loan, had previously overwhelmed PPP borrowers with a significant amount of documentation required. Now, neither document is required to be submitted to the SBA for loan forgiveness.

For PPP loans with open requests for additional information to the Loan Necessity Questionnaire, the SBA suggests lenders close the request in their PPP computer platform and resubmit the loan to the SBA.

If you have questions about PPP loan forgiveness for your unique situation, contact our team of PPP advisors today.