SBA Loan Forms to Back Good-Faith Certification Awaiting Approval

Companies that received $2M or more in PPP loans will likely need to provide additional information through new proposed supplemental SBA questionnaire forms and supporting documents to back up the good-faith certification made when taking out the PPP loan. Last week the SBA requested approval from the Office of Management and Budget for the information collection.

Although the SBA has not officially released the two questionnaire forms, some banks have received Form 3509—Loan Necessity Questionnaire (For-Profit) and Form 3510—Loan Necessity Form (for Non-Profits).

The SBA move comes as no surprise as you likely recall the confusion companies faced in Q2 when attempting to decipher how “economic uncertainty” was to be defined, per FAQ #31. Borrowers were warned of the potential public relations disaster if they were to receive the spotlight based on receiving the loan, without much evidence for “need.” Before taking out the loan, loan borrowers agreed that “economic uncertainty makes this loan necessary to support the ongoing operations.”

At Windham Brannon, we are dedicated to keeping you up to date with the latest Covid-19 activity in our Covid-19 Resource Center. Our team is working around the clock to ensure we stay up to date on the latest guidance and information to assist you and your business during this unique time.


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