SBA Issues PPP Loan Necessity Questionnaire to $2M+ Borrowers; What You Should Know

The Small Business Administration (SBA) has begun issuing loan necessity questionnaires to Paycheck Protection Program (PPP) borrowers with PPP loans with an original principal amount of $2 million or greater.

The loan necessity questionnaire will be used by the SBA in its review of the PPP borrower’s good-faith certifications of the borrower’s economic need. While we await further clarification, we advise PPP borrowers who received loans amounts at or greater than $2 million to create a solid plan for their documentation and understand the timeline set forth by the SBA.

This new requirement is backwards-looking from the end of your covered period in an attempt to evaluate loan necessity. This questionnaire includes questions related to:

  • Compensation in excess of $250,000
  • Cash reserves prior to taking a PPP loan
  • Distributions paid during the covered period
  • Capital expenditures during the covered period

There are other questions to related to whether a company was shutdown, had restrictions on service (such as a restaurant) and many more questions.

Here are the details at the time of this post. Please check back often to our SBA Resource Hub, or contact your Lurie advisor for questions.

The SBA Released Two Versions of the Loan Necessity Questionnaire:

  • Form 3509 Loan Necessity Questionnaire (For-Profit Borrowers) 

  • Form 3510 Loan Necessity Form (Non-Profit Borrowers) 

Why You May Have Received This Notice

  • The SBA is “reviewing these loans to maximize program integrity and protect taxpayer resources. The information collected will be used to inform SBA’s review of your good-faith certification that economic uncertainty made your loan request necessary to support your ongoing operations,” (source: SBA). 
  • Receipt of one of these forms does not mean that SBA is challenging your certification.

From the SBA: “Within five business days after you provide a complete form with all required responses, supporting documents, and signatures and certifications, the Lender servicing your loan is required to upload the form and documents to the SBA PPP Forgiveness Platform ( and separately input your responses to each question into the web form available in the platform.”

Requirements for Borrowers

Failure to complete the form and provide the required supporting documents may result in SBA’s determination that you were ineligible for either the PPP loan, the PPP loan amount, or any forgiveness amount claimed, and SBA may seek repayment of the loan or pursue other available remedies.

What to Do Next

Contact your Lurie advisor to discuss strategies specific to your PPP loan. Also, if you have already applied for forgiveness, respond with answers for forms 3509 or 3510 within the deadline. As mentioned above, Lurie advisors are monitoring the latest developments closely and will update with additional guidance. As mentioned above, Lurie advisors are monitoring the latest developments closely and will update with additional guidance. Please visit our SBA Resource Hub for the latest information.

Need a second set of eyes?

Our CPAs can help you navigate complex PPP loan forgiveness rules including calculation and documentation requirements.
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