On December 9, 2020, the U.S. Small Business Administration (SBA) released finalized Loan Necessity Questionnaires as part of the review of all Paycheck Protection Program (PPP) loans of $2 million or more. There are two forms– 3509 for for-profit businesses and 3510 for non-profit businesses.
The form will be sent directly to the borrower through the lender. Once received, the borrower has 10 business days to complete the questionnaire. Questions are specific to business activity and liquidity assessment. There is limited space and opportunity to provide a narrative response. The requested form does not mean the SBA is challenging the forgiveness of the PPP funds, but simply conducting a multi-factor analysis.
PYA recommends that any borrower who obtained $2 million or more in PPP funding complete the Loan Necessity Questionnaire at the same time the forgiveness application is completed. This will allow your organization to gather the requested data and provide for an internal review of all questions and supporting narratives without the rush of the limited completion time of 10 business days. The borrower can maintain this information until completion of the form is requested by the lender.
PYA remains committed to keeping you up-to-date on the latest PPP and COVID-19-related news. If you need assistance with PPP forgiveness or year-end planning, or would like additional COVID-19 guidance, visit our COVID-19 hub, or contact one of our PYA executives below at (800) 270-9629.
Disclaimer: To the best of our knowledge, this information was correct at the time of publication. Given the fluid situation, and with rapidly changing new guidance issued daily, be aware that some or all of this information may no longer apply. Please visit our COVID-19 hub frequently for the latest updates, as we are working diligently to put forth the most relevant, helpful guidance as it becomes available.