Necessity Questionnaire No Longer Required for Forgiveness of Large PPP Loans

On June 28, the Office of Management and Budget repealed the requirement that Paycheck Protection Program borrowers with loans of $2 million or more complete a loan necessity questionnaire as part of their forgiveness application.

While the submission of a Form 3509 is no longer required as part of the forgiveness process, our friends at that National Automobile Dealers Association note that most dealers with loans that large have already completed the request for loan conversion, particularly given the requirement that requests for forgiveness be submitted within 10 months of receiving the loan.

If you have any questions about the PPP loan forgiveness process, please review this information from the Small Business Administration. You can also visit NADA’s Coronavirus Hub, or contact NADA’s Regulatory Affairs department at

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