PPP Forgiveness: New Questionnaire Requirement for Large Borrowers

Just as many Paycheck Protection Program (PPP) lenders are beginning to accept forgiveness applications and submit them to the Small Business Administration (SBA) for consideration of partial or full forgiveness, the SBA has announced it will begin requiring a new Loan Necessity Questionnaire for large borrowers.

The SBA and Department of Treasury have each indicated that borrowers whose PPP loans were $2M or more should expect additional scrutiny and be prepared for a potential audit or review by the SBA. Much of these announcements' focus was intended to deter large borrowers from accepting PPP funds when not needed. As a result, many expect the SBA to focus its review process on these borrowers' justification of need for their loans.

As of this week, the SBA announced that $2M+ loan borrowers will be required to complete a Loan Necessity Questionnaire to assist the SBA in evaluating each applicant's "good faith certification" that they had an economic need for the PPP loan. There will be a version for non-profit borrowers and one designed for for-profit borrowers.

Similar to the loan and forgiveness application processes, borrowers can expect to receive further information from their PPP lenders, who will collect and submit the new forms to the SBA.

HORNE is working with borrowers and lenders to assist with the forgiveness application and submission process.

If you have questions about the PPP loan forgiveness process, HORNE is here to help. Click the button below to sign up for HORNE’s Forgiveness Assistance Program or contact us at PPPForgiveness@hornellp.com. 

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