The U.S. Small Business Administration (SBA) will require Paycheck Protection Program (PPP) lenders to issue “loan necessity” questionnaires to all borrowers of PPP loans of $2 million of more. On October 26, 2020, the SBA published a notice seeking comment in the Federal Register for the two forms of “loan necessity” questionnaires – one for for-profit borrowers (Form 3509) and one for non-profit borrowers (Form 3510). As of November 9, 2020, it appears that the SBA has not officially released either questionnaire. However, we have located forms that may be current through online and other resources, which appear consistent with publicly-available information. Copies of the current forms are available here: SBA Form 3509 and SBA Form 3510.
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