SBA Requiring PPP Large Borrowers to Complete Loan Necessity Form

  |   November 9, 2020

Attention large borrowers of Paycheck Protection Program (PPP) loans: If your business or non-profit received at least $2 million in PPP funding, you will have to complete one of two new loan necessity questionnaires. The U.S. Small Business Administration (SBA) is sending lenders both forms to distribute to borrowers.

The new forms are SBA Form 3509, Paycheck Protection Program Loan Necessity Questionnaire (For-Profit Borrowers) and SBA Form 3510, Paycheck Protection Program Loan Necessity Questionnaire (Non-Profit Borrowers). Both are designed to collect supplemental information for SBA loan reviewers to use in evaluating the good-faith certification borrowers made on their PPP applications which inferred economic uncertainty had compelled their loan request to maintain operations. According to the SBA, about 30,000 of the 5.2 million PPP loans were for $2 million or more.

The SBA has notified lenders that they will be receiving notification letters asking that borrowers complete the appropriate questionnaire.

Upon receiving the forms, borrowers will have 10 business days to complete and return it, along with required supporting documents.

Each of the forms comprises nine pages, and includes 21 questions, many of which have multiple sections. Six of the questions require supporting documents.

More guidance is expected from the SBA regarding the forms. However, instructions warn borrowers that “failure to complete the form and provide the required supporting documents may result in the 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.”

How REDW Can Help

REDW is here to help you navigate the PPP. Please contact REDW Principals James Ortiz or Christina Roderick to discuss any concerns about PPP-related issues.


REDW is committed to keeping you informed at all times, and especially through the impacts of the COVID-19 pandemic. Stay connected with us on LinkedIn and @REDWLLC on Twitter. Access some of our other updates on our COVID-19 Resource Hub.

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