Updated on Friday, October 30, 2020.

The Small Business Administration (SBA) will be requesting borrowers complete loan necessity questionnaires for those with PPP loans totaling $2 million or more. This questionnaire is part of a review process to assess the SBA’s evaluation of borrowers’ good-faith certification of their economic need.

In the memo the SBA has indicated that they have developed these “loan necessity questionnaires” (for-profit borrowers – Form 3509; non-profit borrowers – Form 3510) to inform SBA’s review of those borrowers’ good-faith certification, as required by the CARES Act, that “[c]urrent economic uncertainty makes this loan request necessary to support the ongoing operations” of the borrower.”

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 loan necessity questionnaires are attached hereto this e-mail.

The expectations will be for borrowers to complete these questionnaires in supplement to the loan forgiveness applications.The questionnaires are due to the lender within 10 days of receipt by the PPP borrower.

Criteria and content included within these questionnaires have not been made publicly available (as of the date of this correspondence), but once publicly available we look forward to finally getting more clarity in the process by which the SBA will review and assess PPP loans over $2 Million from a “loan necessity” perspective.

In continued efforts by your Blue & Co. LLC team, we are continuing to monitor and disseminate information potentially impacting our clients in connection with their Paycheck Protection Program (PPP) loans advanced through the SBA in connection with the CARES Act. For more information, please visit our COVID-19 Resource Center.

If you have any questions about this, please contact your local Blue & Co., LLC advisor.