The SBA is officially dropping the PPP loan questionnaire requirement


The US Small Business Administration (SBA) has notified lenders that it is removing the creditworthiness test for Paycheck Protection Program (PPP) loans of $2 million or more.

In a July 9 statement, the SBA said it would no longer be requesting either version of the credit necessity questionnaire: SBA Form 3509 for for-profit borrowers and SBA Form 3510 for nonprofit borrowers. Additionally, previously requested SBA credit necessity questionnaires are no longer required to be submitted.

For PPP loans with an open request for additional information related to the Loan Needs Questionnaire, the SBA advised lenders to close the request on the PPP computer platform and return the loan to the SBA.

The changes are effective immediately, but the SBA said it would release an FAQ with more details shortly.

The Associated General Contractors of America (AGC) said last month that the SBA was in the process of dropping the requirement of the Credit Needs Questionnaire.

The general contractor group submitted legal action December 2020, challenging the legality of the questionnaire and the process used by the SBA and the Office of Management and Budget (OMB) to develop, approve and publish it. in one Explanation On June 23, AGC CEO Stephen E. Sandherr said he had learned that the SBA had initiated the process of fully withdrawing the questionnaire.

The SBA introduced the new forms in November. Later that month, AICPA was among 80 organizations to do so signed a letter urging Congress, the Treasury Department and the SBA to temporarily suspend use of the questionnaires due to concerns about the nature and timing of the information being requested. The AICPA sent another letter the following week to the OMB and SBA, raising concerns that Forms 3509 and 3510 were onerous and did not reflect Congress’ intent when it established the PPP in March 2020.

The SBA stopped accepting applications for PPP loans as of May 31. Over a 14-month period, the program provided approximately $800 billion in forgivable loans to nearly 12 million businesses. have CPAs played a key role in assisting borrowers through the application and forgiveness processes.

The credit need questionnaires were among the many PPP forgiveness topics discussed during the AICPA webcast on July 8 at City Hall. A replay of the webcast is available free of charge at AICPA TV.

AICPA experts discuss the latest on the PPP and other small business assistance programs during a virtual town hall held every two weeks. The webcasts, which offer CPE credits, are free for AICPA members and $39 for non-members. Go to AICPA Town Hall series Website for more information and to register. Recordings of town hall events are available for viewing free of charge AICPA TV.

the AICPA Paycheck Protection Program resource page houses resources and tools developed by the AICPA to manage the economic impact of the coronavirus.

For more news and reports on the coronavirus and how CPAs can address challenges related to the outbreak, visit JofA‘S Coronavirus Resource Page or Subscribe to our email alerts for current PPP news.

jeff drew ( is a JofA editor-in-chief.


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