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. 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 response@grassiadvisors.com.


Lou Pizzileo Louis Pizzileo is an assurance and advisory Partner at Grassi and leads the firm’s SEC and Capital Markets Practice. He has over 25 years of experience serving growth-minded middle market and Fortune 500 companies. As the leader of SEC & Capital Markets team, Lou has guided many micro, mid, and small-cap companies through successful initial public offerings. He has also assisted existing public companies... Read full bio