SBA To No Longer Rely on Economic Necessity Questionnaires in Processing PPP Forgiveness Applications
Client Alert | 1 min read | 08.02.21
On July 29, 2021, the Small Business Administration announced in an FAQ that it is discontinuing any reliance on the Loan Necessity Questionnaires, which the SBA had required of each borrower, that together with its affiliates, received Paycheck Protection Program loans with a principal amount of $2 million or greater. As we’ve previously discussed, in October 2020, the SBA had unexpectedly released SBA Forms 3509 an 3510 to collect information that would purportedly allow SBA loan reviewers to assess PPP borrowers’ certification that economic uncertainty made the PPP loan necessary to support ongoing operations. The SBA explains in the new FAQ that use of the forms have caused delays and do not provide for efficient use of SBA audit resources and as such use of these forms is discontinued. The FAQ also notes that the majority of public comments SBA received on the forms raised objections to their use.
Contacts
Insights
Client Alert | 4 min read | 01.07.26
On December 17, 2025, the U.S. Food and Drug Administration (FDA) issued a request for information (RFI) on a proposal designed to help the FDA engage more directly with innovative, venture-backed companies focused on biotechnology, medical devices, AI, and regulatory technology.[i]The RFI includes 19 questions, with responses due by 2:00 p.m. ET on January 18, 2026.
Client Alert | 3 min read | 01.07.26
CMMC for AI? Defense Policy Law Imposes AI Security Framework and Requirements on Contractors
Client Alert | 3 min read | 01.07.26
New Year, Same CIPA Uncertainty – When Will the Appellate Courts Enter the Chat?
Client Alert | 11 min read | 01.07.26
