The U.S. Small Business Administration (SBA) announced on July 9, 2021, that it would no longer require the Paycheck Protection Program (PPP) Loan Necessity Questionnaire, or SBA Forms 3509 (for-profit) and 3510 (non-profit), for PPP loans in excess of $2 million. Previously, applicants seeking PPP loan forgiveness for loans of $2 million or more had to complete the form, which essentially attested to the necessity of the funds and required detailed financial information. The SBA announcement also indicated that loans with outstanding Loan Necessity Questionnaire requests would no longer need to be submitted. Additionally, any existing PPP loans that had open requests from the SBA concerning information on a previously submitted Loan Necessity Questionnaire should be resubmitted by the lender without the form. All changes indicated by the SBA are already active and in effect.

It appears that legal action brought forward by the Associated General Contractors of America (AGC) in December of 2020 prompted questions over the legality of the required questionnaire.  AGC reported in June 2021 that the SBA was beginning procedures to eliminate the Loan Necessity Questionnaire, perhaps in light of the pending litigation.

When the SBA released the Loan Necessity Questionnaire in November 2020, 80 organizations signed a letter pressing Congress, the Department of the Treasury, and the SBA to stop using the form due to concerns over the type of information requested. Generally, the questionnaires are thought to go against the spirit of Congress’ intent with the PPP and are viewed as overly burdensome to companies applying for assistance.

If you have additional questions about PPP forgiveness or need assistance completing your PPP loan forgiveness application, our PPP loan consultants are here to help. Contact us for more information.

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Bert Mills, CPA, is the Managing Partner at Moore Colson. In his role, Bert sets the vision and mission of the Firm and works closely with the Firm’s leadership to drive and implement strategies. 


Andy Starnes, CPA, is a Partner and Tax Services Practice Leader Moore Colson. Andy’s specialties include corporate tax compliance and planning, business consulting and multi-generational planning with a focus on the construction, professional services and staffing industries.


Moore Colson CPAs and Advisors Chris Arnone Audit Practice Leader

Chris Arnone, CPA, is a Partner and Business Assurance Practice Leader at Moore Colson. Chris has over 20 years of experience providing audit, accounting and consulting services for companies in the transportation, manufacturing, distribution, staffing, private equity and venture capital industries.


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