Treasury, SBA Update PPP FAQs on Loan Necessity Questionnaires


Jessica L. Jeane, J.D.
Director of Public Policy & Strategic Communications
December 9, 2020

Treasury and the Small Business Administration (SBA) late in the evening of December 9 updated the Paycheck Protection Program (PPP) Loans FAQs regarding the recently imposed and controversial loan necessity questionnaires. Specifically, number 53 of the updated FAQs addresses why some PPP borrowers are receiving a For-Profit and Non-Profit Loan Necessity Questionnaire (SBA Forms 3509 and 3510).

Generally, the forms serve to assist the SBA in its assessment and audit of PPP loans of $2 million or more. Recently, the “information collection” questionnaires have come under significant criticism from business groups and stakeholders alike contending that a retroactive necessity certification is unduly burdensome and confusing.

Borrowers are encouraged to frequently check the PPP FAQs, which continue to be periodically updated. The SBA’s website housing the updated FAQs, Loan Necessity Forms, and additional PPP resources can be located here.

Additionally, NSA Alerts on PPP-related developments can be located on the Main Street Practitioner Blog

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