PPP Borrowers Are No Longer Required to Submit Forms 3509 & 3510 for Forgiveness of Large Loans

PPP Borrowers Are No Longer Required to Submit Forms 3509 & 3510 for Forgiveness of Large Loans

Paycheck Protection Program (PPP) loan borrowers will no longer required to submit Form 3509, PPP Loan Necessity Questionnaire (For-Profit Borrowers) and Form 3510, PPP Loan Necessity Questionnaire (Non-Profit Borrowers), for forgiveness of large loans. 

The SBA implemented the questionnaires late last year as part of their review of the program, which included a review of good-faith certifications and economic need of loan recipients with loans, together with their affiliates, totaling $2 million or more. 

Until now, borrowers meeting the $2 million threshold were required to file Form 3509 or 3510 with their loan forgiveness applications. However, on June 21, 2021, the SBA requested that the Office of Management and Budget (OMB) withdraw its approval for Forms 3509 and 3510.

The withdrawal of this requirement will be of particular benefit to large businesses that have not yet filed forgiveness applications.

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If you have questions, contact me today. Visit our COVID-19 Financial Resource and Tax Center for information on related matters. 

by Holly Ferguson, CPA

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Holly Ferguson joined ARB in 1996 and has been a principal for the firm since 2012. Throughout her career, Holly has provided financial reporting consulting services, assisted with transactional accounting and consulting related to business acquisitions/sales, and analyzed implications and strategic implementation of new accounting standards. As the Practice Leader of ARB’s Accounting & Attest Services Team, she focuses primarily on related services for businesses, manufacturers, credit unions, and nonprofit organizations.