SBA Issues PPP Loan Necessity Questionnaires to Borrowers of $2M or More

SBA Issues PPP Loan Necessity Questionnaires to Borrowers of $2M or More

The Small Business Administration (SBA) has developed two questionnaires, one for nonprofit borrowers and one for for-profit business borrowers, that will go to Paycheck Protection Program (PPP) borrowers with loans, together with their affiliates, totaling $2 million or more. These questionnaires are part of the SBA’s review of the program, including review of good-faith certifications and economic need of loan recipients meeting the $2 million threshold. These will be issued by your lender. Copies of these questionnaires may be found below:

SBA Form 3510 – Nonprofit Questionnaire

SBA Form 3509 – For-Profit Questionnaire

The Forms 3509 and 3510 are just a starting point for providing explanations regarding the necessity of your loan.  There will be opportunities throughout the audit process to provide more narrative surrounding the necessity of the PPP loan, rather than the character limits in the forms 3509 and 3510.  Remember that you only have 10 days to return the completed form to the bank.

Lenders who have submitted loan forgiveness decisions on behalf of these borrowers will receive instructions through the SBA Forgiveness Platform. Questionnaires will still need to be completed by these borrowers; however, the SBA is not making lenders responsible for validating responses or related documentation. Lender questions may be directed to

Additional Resources

For contractors and construction companies, Associated General Contractors of America (AGC) has produced a PPP Packet to help contractors document market conditions when loans were requested. This is a good resource to use in documenting the need for your PPP funds. 

Detailed program information may also be found in the Treasury’s FAQ documents:

Frequently Asked Questions

Frequently Asked Questions on Loan Forgiveness

Also, download ARB’s 13-Week Cash Flow Analysis tool and access our PPP Loan Forgiveness Workbook

Contact ARB

Contact us for your PPP loan questions and forgiveness application needs today. Visit ARB’s COVID-19 Financial Resource and Tax Center for additional information on related tax and financial matters.


by Holly Ferguson, CPA & David Jean, CPA, CCIFP, CExP