SBA to Review PPP Loans Over $2 Million Through Loan Necessity Questionnaire

The Small Business Administration (SBA) has begun issuing loan necessity questionnaires to Paycheck Protection Program (PPP) borrowers with PPP loans above the $2 million threshold; the questionnaires are due to the lender within 10 days of receipt by the PPP borrower.

The loan necessity questionnaires will be utilized by SBA in conducting its review of the PPP borrower’s good-faith certifications pertaining to the borrower’s economic need as part of the loan forgiveness process.

The SBA has developed two versions of these loan necessity questionnaires:

1. For-profit borrowers (Form 3509)
2. For non-profit borrowers (For 3510)

Lenders who have submitted decisions on loan forgiveness for PPP applicants are expected to receive notifications through the SBA Forgiveness Platform requesting the completion of the questionnaire. The expectations will be for borrowers to complete these questionnaires in supplement to the loan forgiveness applications.

Although these forms are not yet available on the Treasury or SBA websites, we understand they have already been distributed to certain borrowers. Once the forms become available to the public, we will gain more clarity on the process by which the SBA will review and assess PPP loans over $2 million from a "loan necessity" perspective.

We are keeping up-to-date as new legislation and provisions are passed and are committed to keeping you well-informed. If you have any questions, or need assistance, please don't hesitate to reach out.