SBA Audits of Paycheck Protection Program Loans – Questionnaire for Loans over $2 million

For loans totaling $2 million or more, the SBA has created a questionnaire that borrowers are being asked to complete and provide additional information requested by the questionnaire.  The questionnaire is sent to lenders to provide to the borrowers once the lender submits the forgiveness application to the SBA.  The borrower has 10 days to return it to the lender with all required support, and the lender has 5 days to return the completed form and support to the SBA.

There are two versions of the questionnaire, one for for-profit borrowers and one for non-profit borrowers.  The purpose of the questionnaire in both cases is to obtain additional information from the borrower concerning the economic uncertainty that made the loan necessary.

On the for-profit questionnaire, here are some examples of what the SBA is requesting information about and for certain items is requesting you submit support along with the questionnaire (these are not all the questions, just some examples):

1. 1. Gross revenue in Q2 of 2020 and Q2 2019 (or Q1 2020 if not in existence during Q2 2019).
   2. Was the borrower required to shut down and which state or local authority issued the order?
   3. Was the borrower ordered to significantly alter its operations by a state or local authority?
   4. What were the approximate cash outlays for the mandatory alterations?
   5. As of the last day of the calendar quarter immediately before the date of Borrower’s PPP loan application, how much did Borrower own in cash and cash equivalents?
   6. Between March 13, 2020 and the end of the loan forgiveness covered period of the PPP loan, has Borrower paid any dividends or other capital distributions (other than for pass-through estimated tax payments) to its owners?
   7. During the loan forgiveness covered period of the PPP loan, were any of Borrower’s owners or employees compensated in an amount that exceeds $250,000 on an annualized basis?
   8. What was the book value (shareholders’ equity value) of Borrower as of the last day of the calendar quarter immediately before the date of Borrower’s PPP loan application?

The non-profit questionnaire takes a similar approach with its questions, asking about gross receipts (instead of revenue), endowments, etc.

After certain questions, there is space to provide additional information or commentary, up to 1,000 words.

You can find a copy of each of the forms below.

For-Profit form 3509 

Non-Profit form 3510 

Contact us if you have any questions.