PPP Loan Necessity Forms from SBA

If your business or nonprofit received $2 million or more in Paycheck Protection Program (PPP) loans, you will be required to complete one of two Small Business Administration (SBA) forms: Form 3509 – Paycheck Protection Program Loan Necessity Questionnaire (for-profit), or Form 3510 – Paycheck Protection Program Loan Necessity Questionnaire (nonprofit).

These forms (which are still in draft) were created to collect additional information that will be used by SBA loan reviewers in evaluating the good-faith certification of loan necessity due to economic uncertainty made by borrowers on applications. The loan necessity forms will be provided by the lender to the loan recipient after the lender submits the loan forgiveness application to the SBA. Once the lender has notified the loan recipient of an SBA request for these forms, they will be due within 10 days.

The questionnaires are extensive and we’re finding that clients which are required to complete them benefit from guidance by our tax professionals. For example, the questions do not provide opportunity for context within the answers, which pertain to the operational necessity for the loan. While there are many outstanding questions regarding these forms and their final format, all impacted loan recipients should begin preparing for this process.

If you’re a current client with a $2 million or more PPP loan, please contact your Smith and Howard tax advisor or use the contact form below.

If you are not currently a client and would like to speak with us about engaging our tax team for guidance on completing the form, please complete our contact form and someone on our team will respond quickly.