The Associated General Contractors of America (AGC) have said that the U.S. Small Business Administration (SBA) is in the process of removing the requirement that Paycheck Protection Program (PPP) borrowers submit a Loan Necessity Questionnaire when applying for forgiveness on loans of $2 million or more. SBA leadership has not made any comment regarding the assertions of AGC. Additionally, PPP lenders continue to get requests from the SBA during the forgiveness process for borrowers to complete forms 3509 and 3510. It is unclear if the SBA will withdraw the necessity questionnaire and, if withdrawn, what legal claims will be raised by either those that were required to complete one and were denied forgiveness or were not given the opportunity to complete one and were denied forgiveness.
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