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PPP Loan Necessity Questionnaire – Information Requirements

In our continued effort to bring the most current information regarding the Paycheck Protection Program (PPP) Loan Forgiveness information, below includes additional insight regarding the Loan Necessity Questionnaire to be issued by the SBA to borrowers.

We have experienced the SBA making a request to the Lender to receive additional information from borrowers with loans in excess of $2 million.

Specifically, we are providing more specific information regarding the documentation being requested for the Loan Forgiveness Application process.

Per SBA request, the lender is required to notify the borrower (within 5 days of receipt) that the SBA has undertaken a review of borrower’s loan, and due to the fact that the loan amount exceeds the $2 million threshold, the borrower is required to provide an executed copy of the Loan Necessity Questionnaire to the lender (within 10 days of receipt). Upon receipt of the completed Loan Necessity Questionnaire, the lender is then subsequently required to upload the questionnaire along with all supporting documents and certifications.

More importantly, within 5 days of receipt of the request from SBA, the lender is required to provide the following documentation to the SBA via the SBA’s Forgiveness Platform:

1. The Borrower Application Form (SBA Form 2483 or Lender’s equivalent form) and all supporting documentation provided by the borrower.

2. All supporting documentation that the borrower was required to submit to the lender with its Loan Forgiveness Application, including payroll documentation, nonpayroll documentation, and full-time equivalent employee documentation, if applicable (documentation listed under “Documents that Each Borrower Must Submit with its PPP Loan Forgiveness Application” in the instructions to the borrower’s Loan Forgiveness Application.  See link for instructions). Lender must also request in writing that the borrower provide lender with the applicable documentation listed under “Documents that Each Borrower Must Maintain but is Not Required to Submit” in the instructions to the borrower’s Loan Forgiveness Application (See link for instructions). Lender then must submit electronic copies of these documents via the Forgiveness Platform within 5 business days of receipt from the borrower.

3. A signed and certified transcript of account.

4. A copy of the executed note evidencing the PPP loan.

5. Any memorandum or other analysis that the lender prepared in making its decision on borrower’s Loan Forgiveness Application.

Additionally, borrowers should be aware the SBA reserves the right and may, in the future, request additional information, directly from the borrower. Such additional requests provide the borrower to respond to within 10 business days of receipt; any failure to respond to these inquiries or any other SBA inquiry on a timely basis may result in a delay in SBA’s remittance of the loan forgiveness amount, or in a determination that the borrower was ineligible to receive the loan amount or loan forgiveness amount claimed.

We will continue to monitor the evolving situation regarding PPP Loan Forgiveness. If you have any questions in the interim, please contact your local Blue & Co. LLC professional.

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