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SBA announces loan necessity questionnaire for PPP loans $2 million and up

Nov 02, 2020

In a recent SBA Notice, two new questionnaires related to Paycheck Protection Program (PPP) economic uncertainty were announced: Form 3509 for for-profit borrowers and Form 3510 for nonprofit borrowers. These forms collect information on PPP loans of $2 million or greater (by borrower or together with affiliates) to ascertain whether economic uncertainty made the loan request necessary.

Official copies of the questionnaires and lender instructions have not yet been posted on the Forgiveness Portal or SBA’s website. However, you can click the following links to view the unreleased for-profit Form 3509 and nonprofit Form 3510.

Once the official forms are released, lenders are to provide the appropriate form to borrowers, who then have 10 business days from receipt to complete the questionnaire, collect required supporting documents and return them to the lender. Note that the Form 3509 is not submitted with the loan forgiveness application (Form 3508).

The lender is required to upload the form and documents to the SBA PPP Forgiveness Platform within five business days after receipt from the borrower.

How these forms relate to the PPP economic uncertainty certification

The SBA Notice says that the information provided will be used to review the borrower’s good-faith certification that economic uncertainty made the PPP loan request necessary to support ongoing operations — and that receipt of the form does not mean that the SBA is challenging the certification. After this form is submitted, the SBA may request additional information, if necessary, to complete the review.

The SBA’s Notice included an estimate that 52,000 loan necessity requests will be sent out — 42,000 to for-profit borrowers and 10,000 to nonprofit borrowers.

Stay tuned for further details once the official Forms 3509 and 3510 are released on the SBA website.

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Gregory G. Butler, CPA
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