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Audits of PPP Loans in Excess of $2 Million

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Rödl & Partner Tax Matters Vol 2020 – 15, published November 20, 2020 and updated January28, 2021

 

Audits of PPP Loans in Excess of $2 Million

In addition to completing the PPP forgiveness application, businesses that together with their affiliates received $2 million or more in PPP loans will need to complete one of two new necessity questionnaires. The forms are SBA Form 3509 (For-Profit Borrowers) and SBA Form 3510 (Non-Profit Borrowers). Lenders will distribute the forms with an expected 10-day return due date. The SBA is not publishing the forms directly to the public although drafts are circulating online. The purpose of the forms is to gather data for use in auditing the good-faith certification borrowers made on their PPP applications that the loan was necessary to support operations. It is expected that the SBA will also consider additional narrative explanations separately from these forms as part of the audit.

 

 

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