PPP Update: End of Deferral Period and Loan Necessity Forms

July 27, 2021

The deadline is quickly approaching for borrowers of first-round Paycheck Protection Program (PPP) loans to either apply for forgiveness or begin making loan payments.

While borrowers can apply for forgiveness at any time before the loan’s maturity date, they are required to begin making payments if the forgiveness application is not received within 10 months after the last day of the covered period.

For deferral purposes, the covered period ends 24 weeks after receipt of PPP funds. With most first-round funds distributed in spring of 2020, many borrowers are facing the end of the deferral period this summer.

For assistance with determining the end of your deferral period and applying for loan forgiveness, please contact your Grassi advisor or our Crisis Response & Recovery hotline at 212.223.6216 or response@grassicpas.com.

SBA May Eliminate PPP Questionnaire Requirement 

Trade associations and lenders participating in the PPP are reporting that the SBA intends to discontinue use of the PPP Loan Necessity Questionnaire for for-profit borrowers (Form 3509) and nonprofit borrowers (Form 3510).
Not yet publicly announced by the SBA, this change would eliminate the requirement for PPP borrowers of $2 million or more to submit the questionnaire and documentation to further substantiate their economic need for the loan. However, the SBA will retain the right to audit PPP loans for up to six years.

Grassi’s Emergency Loan Consulting professionals will advise when the SBA issues guidance on this matter. In the meantime, if you are in the process of completing the questionnaire, please contact your Grassi advisor or lender for direction.