Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty

Forms and Documents

Document Name	Status
Form SBA Form 3508 Inst Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty Form and Instruction	Modified
3245-0407 Emergency Justification for 3509 +3510 Cancellation FINAL 6-21-2021.pdf Supplementary Document	2021-06-21
3245-0407 Supporting Statement Cancel 3509 and 3510 6-21-2021.docx Supporting Statement A	2021-06-21
3245-0407 PPP Extension Act 4-06-2021.pdf Supplementary Document	2021-04-06
3245-0407 American Rescue Plan Authority_ 3-18-2021.docx Supplementary Document	2021-03-18
3245-0407 Emergency Request _1st Draw_ 3-18-2021.pdf Supplementary Document	2021-03-18
3245-0407 Summary Statutory Authority _PPP ICR Economic Aid Amendments(Forgiveness IFR) 1-19-2021.docx Supplementary Document	2021-01-19
3245-0407 Appendix C _PPP ICR Statutory Authority.Flexibility Act_ CARES Act Amendment_ 10-26-2020.docx Supplementary Document	2020-10-26

IC Document Collections

IC ID	Document Title	Status
241035	Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty Form and Instruction	Modified

ICR Details

OMB Control No: 3245-0407	ICR Reference No: 202106-3245-002
Status: Received in OIRA	Previous ICR Reference No: 202104-3245-002
Agency/Subagency: SBA	Agency Tracking No:
Title: Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty
Type of Information Collection: Revision of a currently approved collection	Common Form ICR:  No
Type of Review Request: Emergency	Approval Requested By: 06/23/2021
Date Submitted to OIRA: 06/21/2021

	Requested	Previously Approved
Expiration Date	6 Months From Approved	09/30/2021
Responses	36,960,166	37,002,166
Time Burden (Hours)	9,858,139	9,935,129
Cost Burden (Dollars)	352,599,984	355,220,794

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Abstract: Section 7(a) of the Small Business Act (15 U.S.C. 636) authorizes the Small Business Administration to guarantee loans made by banks or other financial institutions to qualified small businesses in the 7(a) Loan Program. The regulations covering this loan program at 13 CFR Part 120 require loan applicants and lenders to provide certain information that is used to determine program eligibility and compliance. CARES Act PL 116-136 will also cover this program.

Emergency Justfication: June 21, 2021 Susan Minson SBA Desk Officer Office of Management and Budget Dear Ms. Minson: Pursuant to the Office of Management and Budget (OMB) procedures established at 5 CFR 1320, SBA is requesting that approval to discontinue SBA Form 3509, Loan Necessity Questionnaire (For-Profit Borrowers) and SBA Form 3510, Loan Necessity Questionnaire (Non-Profit Borrowers), OMB Control No. 3245-0407 be processed in accordance with section 1320.13, Emergency Processing by June 23, 2021. SBA’s authority to accept new loan guaranty applications for the PPP program expired on May 31, 2021. See, PPP Extension Act of 2021, P.L. 117-6. The Loan Necessity Questionnaires had a deterrent effect and prevented program abuse by applicants that could not make the loan necessity certification in good faith. Now that SBA’s program authority has expired, such deterrence is no longer necessary. Furthermore, SBA has been conducting loan necessity reviews, using the Loan Necessity Questionnaires, on loans of $2 million or greater where borrowers have submitted forgiveness applications. A significant number of these reviews have shown that the borrowers met the good faith certification requirement. SBA’s decision was also influenced by the 61 comments received from members of the public regarding the questionnaires. The majority of the commenters raised objections to the questionnaires as being unnecessary and burdensome, among other things. The loan necessity reviews, including review of the Loan Necessity Questionnaire, are lengthy and have caused delays beyond the 90-day statutory timeline for forgiveness, thus negatively impacting borrowers that made their loan necessity certification in good faith. Discontinuance of these two forms will reduce the burden on PPP borrowers with loans of $2 million or greater, as they will no longer be required to complete the Loan Necessity Questionnaires to obtain forgiveness of their loans. SBA will also be able to conserve its finite audit and review resources and be better positioned to process forgiveness decisions within the statutory deadlines. Sincerely, Jihoon Kim Director, Office of Financial Program Operations

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Authorizing Statute(s): None

Citations for New Statutory Requirements: None

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Associated Rulemaking Information
RIN:	Stage of Rulemaking:	Federal Register Citation:	Date:
	Not associated with rulemaking

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Federal Register Notices & Comments

Did the Agency receive public comments on this ICR? No

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Number of Information Collection (IC) in this ICR: 1

IC Title	Form No.	Form Name
Paycheck Protection Loan Program Borrower Information Form and Lender's Application for Loan Guaranty	SBA Form 3508D, SBA 3508S Instructions , SBA Form 3506, SBA Form 3508 Instructions , SBA Form 3508EZ, SBA Form 3508EZ Instructions , SBA Form 3507 , SBA Form 2484 , SBA Form 3508 , SBA Form 3508S, SBA Form 2483 C , SBA Form 2483	Form 3508 Instructions ,   Form 3508 EZ Instructions ,   Instructions PPP Loan Forgiveness Application ,   Forgiveness Application and Instructions ,   Forgiveness Applications and Instructions ,   Forgiveness Application and Intructions ,   Paycheck Protection Program Borrower’s Disclosure of Certain Controlling Interests ,   PPP Lender Application ,   PPP Borrower Application ,   PPP Borrower Application ,   PPP Agreement for New Lenders Banks Credit Unions ,   PPP Agreement for New Lenders Non Bank Non Insured Depository Institution Lenders

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ICR Summary of Burden

	Total Request	Previously Approved	Change Due to New Statute	Change Due to Agency Discretion	Change Due to Adjustment in Estimate	Change Due to Potential Violation of the PRA
Annual Number of Responses	36,960,166	37,002,166	0	-42,000	0	0
Annual Time Burden (Hours)	9,858,139	9,935,129	0	-76,990	0	0
Annual Cost Burden (Dollars)	352,599,984	355,220,794	0	-2,620,810	0	0

Burden increases because of Program Change due to Agency Discretion: No

Burden Increase Due to:

Burden decreases because of Program Change due to Agency Discretion: Yes

Burden Reduction Due to: Changing Forms

Short Statement: The total burden hours have decreased. This decrease is due to the discontinuation of SBA Forms 3509 and 3510.

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Annual Cost to Federal Government: $154,005,869

Does this IC contain surveys, censuses, or employ statistical methods? No

Does this ICR request any personally identifiable information (see OMB Circular No. A-130 for an explanation of this term)? Please consult with your agency's privacy program when making this determination.     No

Does this ICR include a form that requires a Privacy Act Statement (see 5 U.S.C. §552a(e)(3))? Please consult with your agency's privacy program when making this determination.     No

Is this ICR related to the Affordable Care Act [Pub. L. 111-148 & 111-152]? No

Is this ICR related to the Dodd-Frank Wall Street Reform and Consumer Protection Act, [Pub. L. 111-203]? No

Is this ICR related to the American Recovery and Reinvestment Act of 2009 (ARRA)? No

Is this ICR related to the Pandemic Response? Yes

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Common Form ICR:  No

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On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:

(a) It is necessary for the proper performance of agency functions;

(b) It avoids unnecessary duplication;

(c) It reduces burden on small entities;

(d) It uses plain, coherent, and unambiguous language that is understandable to respondents;

(e) Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

(f) It indicates the retention periods for recordkeeping requirements;

(g) It informs respondents of the information called for under 5 CFR 1320.8 (b)(3) about:

(i) Why the information is being collected;

(ii) Use of information;

(iii) Burden estimate;

(iv) Nature of response (voluntary, required for a benefit, or mandatory);

(v) Nature and extent of confidentiality; and

(vi) Need to display currently valid OMB control number;

(h) It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to be collected.

(i) It uses effective and efficient statistical survey methodology (if applicable); and

(j) It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.

Certification Date: 06/21/2021

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