SBA Issues PPP Loan Necessity Questionnaire for Borrowers With Loans of $2 Million or Greater

The Small Business Administration (SBA) may shortly be releasing two new questionnaires to be completed by borrower’s that received PPP loans with an original principal amount of $2 million or greater. These new “Loan Necessity Questionnaires” consist of SBA Form 3509 (for-profit entities) and SBA Form 3510 (non-profit entities). The Loan Necessity Questionnaires do not appear on either the Treasury or SBA websites, but have been disseminated by the SBA to certain lenders and borrowers. Links to the forms are here:

SBA Form 3509 For-Profit Entities

SBA Form 3510 Non-Profit Entities

The SBA is requesting these forms to help facilitate the collection of supplemental information to be used by loan reviewers to evaluate the good-faith certifications made on the PPP Borrower Application that economic uncertainty made the loan request necessary.

The forms are designed to provide the SBA more information on two key assessments. The first relates to the borrower’s business activity and the second relates to the borrower’s liquidity. The questions on the forms indicate that the SBA is evaluating borrowers both on the date of the loan application and for some period after the loan application.

With the fluidity of the program it is likely that changes will be made to the forms linked above. We again stress the importance of properly documenting and supporting your “need” determination. While borrowers of loans over $2 million should review the information required by these forms, it is also prudent for borrowers under that amount to also review and be prepared to respond.

The PPP loan eligibility and forgiveness has been an evolving process. As always, don’t hesitate to contact your MSL advisor if you would like to discuss or if you would like assistance applying for loan forgiveness.