SBA Outlines Procedures for PPP ‘Loan Necessity’ Questionnaires

The Small Business Administration on Wednesday outlined procedures for lenders in handling the loan necessity questionnaires that SBA is requesting for PPP loans totaling $2 million or more. The procedures were detailed in a user guide and introductory letter sent using SBA’s PPP forgiveness platform.

According to the documents, lenders will receive notice of requests from SBA for questionnaires via the SBA forgiveness platform at forgiveness.sba.gov. The questionnaires — SBA Form 3509 for for-profit borrowers and Form 3510 for nonprofit borrowers — are available there, and the platform now accepts online submission of the completed questionnaires. Lenders must notify the borrower of the request within five business days and should advise the borrower to complete the form within 10 business days, SBA said. Lenders must upload the completed questionnaire, manually enter borrower responses and upload supporting documentation within five business days of receiving it.

While reiterating that lenders are not required to verify or validate the borrower’s responses or supporting
documentation submitted with the questionnaires, SBA emphasized in its letter that “[f]ailure to timely respond to any SBA request may result in a delay in SBA’s remittance of the loan forgiveness amount, if any, or in a determination that the borrower was ineligible for the loan or ineligible to receive the loan amount or loan forgiveness amount claimed by the borrower (or the loan forgiveness amount in the lender’s forgiveness decision).” Lenders may contact PPPForgivenessRequests@sba.gov with any questions. 

ABA has joined other trade groups in raising concerns about the loan necessity questionnaires, noting that the forms ask for information unrelated to what borrowers were asked to consider when they applied for their PPP loan and warning that they may introduce confusion and excess burden for borrowers and lenders.

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