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SBA Seeks Additional Public Comments on PPP Information Collection Forms


Jessica L. Jeane, J.D.
Director of Public Policy & Strategic Communications
December 31, 2020

The U.S. Small Administration (SBA) is seeking additional public comments on certain Paycheck Protection Program (PPP) information collection forms. The SBA's unpublished notice announcing the next public comment period is scheduled to be published in the Federal Register on January 4, 2021.

In particular, the SBA solicits public comments for its Loan Necessity Questionnaires, SBA Form 3509 (For-Profit Borrowers) and SBA Form 3510 (Non-Profit Borrowers). These two information collection forms have garnered a great deal of controversy since being issued to certain borrowers.

“The SBA invites the public to submit comments, including specific and detailed suggestions on ways to improve the collection and reduce the burden on respondents,” the notice states. “Commenters should also address (i) whether the information collection is necessary for the proper performance of SBA’s functions, including whether it has any practical utility; (ii) the accuracy of the estimated burdens; (iii) ways to enhance the quality, utility, and clarity of the information to be collected; and (iv) the use of automated collection techniques or other forms of information technology to minimize the information collection burden on those who are required to respond.”

Previous commenters expressed concern that the affected public had not been given adequate notice to submit comments, according to the SBA. Thus, the agency is providing another 60 days for the public to review the forms as listed in the notice.

    The core mission of the National Society of Accountants is to help tax and accounting professionals become more successful.

NSA presents this information in the interest of its members for information purposes only and is not intended to provide, nor should it be relied upon, as legal, tax, or accounting advice.

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