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SBA Requiring Borrowers of PPP loan in Excess of $2M to Submit Questionnaire

SBA Requiring Borrowers of PPP loan in Excess of $2M to Submit Questionnaire

November 11, 2020
By Tonneson
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The Small Business Administration (SBA) has recently compiled a Questionnaire comprised of 21 questions for large borrowers:

Large borrowers are taxpayers who borrowed more than $2M in PPP loans. Form 3509/3510 is a first step designed to gather information on the borrower’s 2020 results to-date of its financial business activity and cash flow.

The questionnaire began making its way to lenders this week, and lenders have begun to distribute the questionnaire to applicable loan recipients. This form has a 10-day time limit to return the form with applicable data to the lender. Although there is no guidance regarding not meeting this deadline, we would suggest if you do not feel you can meet the deadline, that you call your lender to discuss an extension. The lender is required to submit your information to the SBA within five business days of receiving your completed form with documents, signatures and certifications. Lenders are not required to verify your form or documentation, only to remit it to SBA loan reviewers.

Form 3509/3510 is part of the SBA’s response to their FAQ #46 where they announced earlier this year that they would audit any borrower of more than $2M in loan proceeds. If your loan proceeds fit this definition, we would suggest you start to gather the documentation now to help you complete the form in a timely manner when received from your lender. Lenders should receive some additional instructions from the SBA on how to fill out the form, so hopefully there will be additional information coming to assist in the completion of the forms in the near future.

Form 3509/3510 is only a fact-finding tool that will hopefully give the SBA loan reviewers valuable information on the necessity of the loan to your business activity and liquidity in these difficult times. This form is not a challenge to the validity of your need, only a first step by the SBA to review your loan.

We will update you with any new information as we receive it from the SBA, but it is expected that there will be additional components to this review and that borrowers will have the opportunity to provide further information once the initial questions are answered and reviewed. Should you have any questions, please don’t hesitate to reach out to your tonneson + co representative.