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Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There are two questionnaire forms on the Treasury: Form 3509 for for-profit borrowers and Form 3510 for non-profit borrowers. On December 9, 2020, the SBA released FAQ 53, which provides some clarifications on the questionnaire (the “FAQ #53”).
Update: Starting in March 2021, we saw borrowers with loans of $2 million or greater starting to receive requests for additional materials (such as the maintained documents) or being informed by their lenders that they were under “SBA review.” Also, in March, April, and May 2021, we saw several lenders (and perhaps the SBA) stop processing forgiveness applications while they were working on new First Draw and Second Draw PPP Loans. In late May, the lenders and SBA appear to have resumed processing them. In addition, borrowers are reporting anecdotally that they are waiting months for the SBA to act on their applications for the forgiveness of loans of $2 million or greater, some up to eight months.