If you have received a PPP loan over $2M, the accurate completion of your forgiveness application is critical. Before you begin the application process it’s important to understand the SBA’s form requirements.
In the world of PPP we have come to expect change and evolving rules and regulations. Fortunately, as time has passed, most of the changes and evolution have been pro-business and amicable. The latest development has been the release of the SBA’s Forms 3509 and 3510 to lenders. The Form 3509 will need to be completed by for-profit borrowers, while the 3510 will need to be completed by nonprofit borrowers who received PPP proceeds in excess of $2 million.
Timely and accurate completion of this form is a critical part of your forgiveness process and deserves your attention. The SBA will use the form’s information to review your good-faith certification that economic uncertainty made the loan request necessary to support your ongoing operations at the time of your initial PPP loan application.
Once you’ve submitted your forgiveness application, your lender will provide the Form 3509/3510 and you’ll have 10 days to complete and submit the form, along with supporting documents, to the lender.
You’ll definitely want to wait on submitting your forgiveness application until you’ve had a chance to thoughtfully know and articulate your answers to the various questions in the Form 3509/3510. Our recommendation is to have all your documentation ready prior to submission. This form is a work in process from the SBA and the final version will likely be different but completing this form is a great start to being prepared in this critical process.
Reading through the form you can get a real understanding for what the SBA wants to know. For example, what was revenue in the second quarter 2020 vs the second quarter 2019? Was the business required to shut down based on government order or were there other things that impacted the business due to COVID-19? There are several questions dealing with liquidity assessment including how much cash or cash equivalents did the business have immediately before the loan application? There are many more questions and the form provides for a couple of spots to provide additional information on 1) business activity assessment and 2) on liquidity assessment.
The stakes are very high on this and we hope an advance look at the form and questions will help you prepare and ultimately lead to a positive assessment by the SBA on loan necessity.
The SBA has promised to audit every loan over $2 million and no one knows exactly what that will entail but being prepared for this for Form 3059 or Form 3510 is a big step towards your loan forgiveness being achieved.
The PPP Loan Forgiveness will be the biggest financial decision an organization makes this year if done correctly. We offer services to help with the PPP Loan Forgiveness application. For assistance please contact:
Randy Feld, CPA, ABV at firstname.lastname@example.org
Chris Wittich, CPA, MBT at email@example.com