Paycheck Protection Program (PPP) loans of $2 million and higher are subject to additional requirements to certify in good faith that the loan was needed. On October 30th, the SBA released a loan necessity questionnaire that will be required for all applicants seeking forgiveness of loans above this threshold. The questionnaire includes questions to assess the pandemic impact on the activity of the business as well as the business liquidity at the time of the application. Applicants who are unable to sufficiently convince the SBA of the loan necessity may have their forgiveness application denied.
Borrowers who are already in the forgiveness application process should expect to receive a necessity questionnaire from their lender. Links to the questionnaires are included below, as it may be beneficial for borrowers with large PPP loans to begin reviewing these documents in advance.