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SBA Questioning “Loan Necessity” for PPP Loans Over $2 Million

The SBA has announced two new PPP forms:

  • Form 3509, Paycheck Protection Program Loan Necessity Questionnaire (For-Profit Borrowers); and
  • Form 3510, Paycheck Protection Program Loan Necessity Questionnaire (Non-Profit Borrowers).

The forms will be sent to borrowers with loans totaling more than $2 million, and ask a number of questions to establish the borrower’s need for the PPP funds. The questions address the following information:

  • Gross revenue amounts from 2019 and 2020;
  • Whether the business was subject to a government shutdown;
  • Whether any owners were paid compensation in excess of $250,000 on an annualized basis during the covered forgiveness period; and
  • What the borrower’s liquidity was immediately prior to receiving the PPP funds, and during the covered forgiveness period.

The questionnaires are due to the lender within 10 days of receipt by the PPP borrower.

To view the memo issued by the SBA, go to:

The forms have not yet been posted to the SBA or Treasury websites. We have posted copies of the forms on our website at the following links:

Form 3509:

Form 3510:

Windes can help with calculating your loan forgiveness or compiling a loan forgiveness package for your lender. For more information, please contact our tax professionals at or toll free at 844.4WINDES (844.494.6337).

This article is reproduced with permission from Spidell Publishing, Inc.
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