SBA Removes Requirement for Loan Necessity Questionnaire

The Small Business Administration has made an update to their FAQs for Paycheck Protection Program loans which removes the requirement for PPP borrowers of $2 million or more to complete a Loan Necessity Questionnaire (SBA Form 3509 or 3510) to further substantiate their economic need for the loan. This change was anticipated, but now it’s official. Here’s a link to the SBA’s updated PPP Program FAQ. The change is covered in the answer to Question 69, found at the end of the document. It’s important to note that the SBA retains the right to audit PPP loans for up to six years.

If you have any questions about how this update affects your unique business, please contact your Grassi advisor or our Crisis Response & Recovery hotline at 212.223.6216 or

Lou Pizzileo An accounting and advisory Partner at Grassi, Lou Pizzileo plays a key role serving the firm’s clients in the manufacturing and distribution, technology and specialty finance practices. Entrepreneurial minded, Lou recently led the firm’s efforts in assisting companies with capturing available stimulus provided by the CARES Act, including the Paycheck Protection Program. He also recently created and leads the firm’s IT accounting practice. Lou... Read full bio