PPP Loan Questionnaires Released for Borrowers of Over $2 Million

The Small Business Administration (SBA) published in late October that it will begin issuing loan necessity questionnaires to Paycheck Protection Program (PPP) borrowers with PPP loans of over $2 million. The loan necessity questionnaires will be utilized by the SBA to review the PPP borrower’s good-faith certifications of economic need. There are two versions of the questionnaire: Form 3509 that will be used by for-profit borrowers, and Form 3510 that will be used by non-profit borrowers.

If your PPP lender has submitted a decision on your PPP loan forgiveness, you will receive a notification through the SBA Forgiveness Platform requesting the completion of the questionnaire. SBA has noted that lenders are not required to verify or validate borrowers’ responses or any required supporting documents.

The loan necessity questionnaires ask for information to support business activity and liquidity assessments which includes (but is not limited to) the following:

• PPP loan holder’s gross revenue in Q2 of both 2020 and 2019
• PPP loan holder’s expenses in Q2 of both 2020 and 2019
• PPP loan holder status of being ordered to shut down by a state or local authority
  due to COVID-19
• PPP loan holder status of being ordered to significantly alter its operations by a state or local authority due to COVID-19
• PPP loan holder being asked to voluntarily cease or reduce its operations due to COVID-19
• PPP loan holder status of beginning any new capital improvement projects not due to COVID-19
• PPP loan holder’s cash and cash equivalents as of the end of the last calendar quarter prior to the PPP loan application
• PPP loan holder’s support of payments of any dividend or other capital distributions (in excess of distributions to pay taxes) prior to the end of the Covered Period
• PPP loan holder support of any prepaid any outstanding debt prior to the end of its
  Covered Period
• PPP loan holder status of any employees receiving compensation in excess of $250,000 on an annualized basis during its Covered Period
• PPP loan holder support of any owners receiving compensation in excess of $250,000 on an annualized basis during its Covered Period
• PPP loan holder status of receiving funds from any other CARES Act program
  

Please feel free to reach out to Brixey & Meyer to help navigate the loan forgiveness process. We are committed to keeping our clients, friends and families posted on the latest developments in these unprecedented times. You can simply comment below, visit our website or call us at 866.760.0940.