PPP Loan Necessity Questionnaire requirement: Lenders have been advised by the Small Business Administration (SBA) that it is eliminating the loan requirement review of the $2 million loans for the Paycheck Protection Program (PPP).

In a July 9 notice, SBA stated that either version of the loan necessity questionnaire would no longer be requested, namely SBA Form 3509 for-profit borrowers and SBA Form 3510, for non-profit borrowers. Moreover, the previously sought questions regarding loan necessity are no longer to be tabled by the SBA.

PP Loan Necessity Questionnaire requirement
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The SBA has urged lenders to complete their application on the PPP platform for PPP loans with an Open Application for further information relating to the Loan Necessity Questionnaire.

The SBA advises lenders to complete the request on the PPP computer platform for PPP loans and to reinstate the loan to the SBA on open request for more information regarding the Loan Necessity Questionnaire.

The modifications are instantly effective, but the SBA has stated it would soon publish a FAQ with further details.

The AGC stated last month that SBA is in the process of removing the need for the Loan Requirement Questionnaire.

In December 2020 the organization of general contractors filed a lawsuit challenging the constitutionality of the questionnaire and the procedure for developing, approving, and publishing the questionnaire employed by the SBA and the Office of Management and Budget (OMB). Stephen E. Sandherr, the CEO of AGC, said in a June 23 statement that he discovered that the SBA had initiated the process of withdrawing the questionnaire completely.

In November, the SBA launched the revised forms. Later this month, the AICPA was among the eighty organizations which, due to concerns over the type and timespan of information requested, signed the letter urging Congress, Treasury, and SBA temporarily to suspend questionnaires use.

The AICPA has addressed another letter to the OMB and to the SBA the following week, citing concerns regarding the burden of Forms 3509 and 3510 and not the intention of Congress in setting up the PPP for March 2020.

On 31 May, the SBA discontinued accepting PPP loans applications. For 14 months, the program, which enabled roughly 12 million companies, granted approximately $800 billion in forgiven loans. In the application and the forgiveness processes CPAs played a crucial role in supporting borrowers.

The surveys on the need for loans were discussed at the webcast by the Town Hall of AICPA, among numerous PPP forgiveness subjects. A webcast replay is provided on AICPA TV free of charge.

In the virtual city hall held every other week, AICPA professionals discuss the latest PPP and other SME support schemes. AICPA members and $39 for non-member are free of charge for the webcast that provides credit for CPE. To obtain more information and to register, visit the AICPA Town Hall Series website. City Hall recordings can be viewed on AICPA TV free of charge.

The Pay Check Resources page for AICPA contains AICPA resources and tools for addressing the economic effect of coronavirus.

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