Beginning in October 2020, the SBA required businesses receiving more than $2 million in loans to submit a questionnaire providing revenue, employee compensation, financing projects and other financial information. After ample backlash and a lawsuit filed by The Associated General Contractors of America in December 2020 the SBA started the process to completely withdraw the questionnaire.
In a recent notice, the Small Business Administration (SBA) announced that it will no longer require either version of the loan necessity questionnaire (Form 3509 for for-profit borrowers or Form 3510 for not-for-profit borrowers). The changes are effective immediately with an FAQ expected to be issued in the near future with more details.
The SBA has advised lenders with an open request for additional information related to the questionnaire to close the PPP computer platform and resubmit the loan to the SBA.
We recommend that applicants continue to retain any documentation and any relevant information needed to substantiate the need for a PPP loan and the forgiveness. While the process of applying for a loan has become less burdensome with the removal of the questionnaire, the remainder of review process has remained the same.