Finally, some welcome news regarding the Paycheck Protection Program (PPP) review of large loans! The PPP Form 3509 for business borrowers and Form 3510 for nonprofit organizations, called the PPP Loan Necessity Questionnaire, has been eliminated by the Small Business Administration (SBA). The Questionnaire was mandated by the SBA for any PPP loan equal to or in excess of $2 Million. These questions were designed to provide the SBA with additional information regarding large loans to determine if the loans were necessary under the terms of the pandemic-related criteria for struggling businesses.
The AICPA was among 80 organizations that urged Congress, Treasury, and the SBA to temporarily suspend use of the questionnaires because of concerns about the types and timeframes of information requested. The AICPA followed this up with a letter to SBA expressing concerns that Forms 3509 and 3510 were burdensome and not reflective of Congress’s intent when it established the PPP in March 2020.
On July 9, the SBA released a notice saying it would no longer be sending requests for completion of the form. In addition, Loan Necessity Questionnaires previously requested by the SBA are no longer required to be submitted. For PPP loans with an open request for additional information related to the Loan Necessity Questionnaire, the SBA has advised lenders to close the request in the PPP computer platform and submit the loan back to the SBA.
These changes are effective immediately. The SBA will release further details through an updated FAQ later this year.
Should you have any questions, please don’t hesitate to reach out to your tonneson + co representative.