SBA to Require PPP Loan Necessity Form from Large Borrowers

On November 6, 2020, the SBA announced that PPP loan borrowers who received, together with affiliates, $2 million or more in Paycheck Protection Program loans, will now be required to complete one of two necessity questionnaires. These forms will collect supplemental information that SBA loan reviewers will use in evaluating the good-faith certification borrowers made on their PPP applications that economic uncertainty made their loan request necessary to support ongoing operations.

  • Form 3509, Paycheck Protection Program Loan Necessity Questionnaire (For-Profit Borrowers)
  • Form 3510, Paycheck Protection Program Loan Necessity Questionnaire (Non-Profit Borrowers)
  • Borrowers are given 10 business days after receipt to return the completed questionnaire and supporting documents to their lender

If we can assist you with understanding the programs’ forgiveness provisions, analyzing your loan forgiveness opportunity and application or assist you with gathering loan forgiveness information needed, please call any Sponsel CPA Group Team member or our colleagues listed below.

             Jason Thompson-Direct at 317-608-6694 or

             Eric Woodruff-Direct at 317-613-7850 or

             Lisa Blankman-Direct at 317-613-7856 or

This communication is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although our firm has made every reasonable effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this communication. Some of those modifications may be significant. As such, be aware that this is not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to you or your business with respect to the matters addressed.

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