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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.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....