PPP Update: SBA Officially Removes Requirement
for Loan Necessity Questionnaire

July 30, 2021

The Small Business Administration has made an update to their FAQs for Paycheck Protection Program loans which removes the requirement for PPP borrowers of $2 million or more to complete a Loan Necessity Questionnaire (SBA Form 3509 or 3510) to further substantiate their economic need for the loan. This change was anticipated, but now it’s official. Here’s a link to the SBA’s updated PPP Program FAQ. The change is covered in the answer to Question 69, found at the end of the document. It’s important to note that the SBA retains the right to audit PPP loans for up to six years.
If you have any questions about how this update affects your unique business, please contact your Grassi advisor or our Crisis Response & Recovery hotline at 212.223.6216 or response@grassicpas.com.