SBA Creates Questionnaire for Large PPP Borrowers Related to Loan Eligibility

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November 12, 2020

Mike Batts, CPA

The Small Business Administration (SBA) has published two new forms – one for nonprofit organizations and one for other borrowers – that the SBA apparently intends to use in connection with evaluating borrowers’ eligibility for obtaining Paycheck Protection Program (PPP) loans of $2 million or more.  Form 3510, the form for nonprofits, is entitled “Paycheck Protection Program Loan Necessity Questionnaire (Non-Profit Borrowers).”

The stated purpose of the form is “to facilitate the collection of supplemental information that will be used by SBA loan reviewers to evaluate the good-faith certification that you made on your PPP Borrower Application (SBA Form 2483 or Lender’s equivalent form) that economic uncertainty made the loan request necessary.”

According to the narrative accompanying the form, each nonprofit PPP borrower that, together with its affiliates1, received PPP loans with an original principal amount of $2 million or greater is required to…

1 Special rules apply in determining and aggregating affiliate organizations, and special exemptions apply for religious organizations.

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