September 16, 2021

Volume XI, Number 259


September 15, 2021

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September 14, 2021

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September 13, 2021

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SBA Will No Longer Require PPP Loan Necessity Questionnaire

In a notice sent to lenders in early July, the Small Business Administration (“SBA”) informed lenders that it is eliminating the Loan Necessity Questionnaires (the “Questionnaires”) for Paycheck Protection Program (“PPP”) loans of $2 million or greater.

The SBA’s notice stated that it would no longer request either Form 3509 (for for-profit borrowers) or SBA Form 3510 (for not-for-profit borrowers). Moreover, Questionnaires previously requested by the SBA are no longer required to be submitted and lenders have been advised to close any open requests for additional information related to Questionnaires.

The changes are effective immediately, but the SBA said it would release an FAQ shortly with more details.

© Polsinelli PC, Polsinelli LLP in CaliforniaNational Law Review, Volume XI, Number 195

About this Author

Phil Feigen of the Polsinelli Law Firm Corporate Transaction Attorney, in Washington DC
Office Managing Partner

Phil Feigen brings a unique perspective to providing general corporate advice, as well as complex business counsel to clients in ever-changing regulatory environments.  For more than 20 years, Phil has been providing guidance with respect to Small Business Investment Companies and other Small Business Administrative regulations, federal and state banking laws and federal securities laws. 

Phil focuses on helping clients through the SBIC licensing process so that they may realize the benefits of the program and increase the amount of investment...


David Allred believes that excellent client service begins with strong relationships. David is a member of the Banking and Financial Institutions practice and represents both publicly traded and privately held banks at all stages of the business cycle, from formations to a mature business. As an accountant and an attorney, David brings a unique perspective to providing corporate advice to clients in ever-changing regulatory environments. He has served banks on a broad range of complex legal issues including: 

  • Mergers and acquisitions
  • ...
Kimberly N. Simmons Corporate Finance Attorney Polsinelli Washington, D.C.

Kim Simmons diligently seeks to find practical solutions to complex corporate financial transactions. She works with seasoned Polsinelli attorneys to analyze each transaction matter to develop a strategic approach to representation based on the client’s immediate and long-term business and operational goals. Kim helps deliver a range of legal services during the life cycle of the client’s business—from selecting the appropriate choice of entity through an exit strategy.

Kim previously served as a Polsinelli summer associate in the Washington, D.C. office.