1. PPP Loan Forgiveness Help Center
  2. Forgiveness Process Questions

Why did I receive a Loan Necessity Questionnaire (also called SBA Form 3509 or 3510)?

You may have received a Loan Necessity Questionnaire (also called SBA Form 3509 or 3510) if you, together with your affiliates, received loans of $2 million or more. 

SBA is reviewing all loans of $2 million or more, and other loans as appropriate, for eligibility, fraud or abuse, and compliance with loan forgiveness requirements. As part of this process, SBA is providing a Loan Necessity Questionnaire to lenders for them to provide to PPP borrowers that, together with their affiliates, received loans of $2 million or more. 

If you’ve received this questionnaire from Scratch, the SBA asks you to return the completed questionnaire to us within 10 business days of receipt.  Failure to respond to this inquiry in a timely basis may result in a delay of forgiveness. 

The information you provide on the questionnaire will help SBA assess your certification in your loan application that “current economic uncertainty makes this loan request necessary to support the ongoing operations of the Applicant,” as required by the CARES Act.

SBA advises that a request to complete the Loan Necessity Questionnaire does not mean that SBA is challenging a borrower’s certification that is required by the CARES Act. SBA’s assessment of a borrower’s certification will be based on the totality of the borrower’s circumstances through a multi-factor analysis. SBA will assess whether the borrower had adequate basis for making the required good-faith certification, based on its individual circumstances in light of the language of the certification and SBA guidance. This certification is required to have been made in good faith at the time of the loan application, even if subsequent developments resulted in the loan no longer being necessary. In its review, SBA may take into account the borrower’s circumstances and actions both before and after the borrower’s certification to the extent that doing so will assist SBA in determining whether the borrower made the statutorily required certification in good faith at the time of its loan application.

SBA advises that after a borrower submits their completed questionnaire, SBA may request additional information, if necessary, to complete its review. When additional information is requested, borrowers will have an opportunity to provide a narrative response to SBA explaining the circumstances that provided the basis for their good-faith loan necessity certification. SBA will make a final determination that a borrower lacked an adequate basis for its loan necessity certification after reviewing any additional information that a borrower chooses to submit. This targeted, multi-step approach will ensure the integrity of the evaluation process and expeditious processing, as well as properly allocate SBA’s finite resources to those loans that require additional review.