Q: Will SBA review individual PPP loan files?
A: Yes. In FAQ #31, SBA reminded all borrowers of an important certification required to obtain a PPP loan. To further ensure PPP loans are limited to eligible borrowers in need, the SBA has decided, in consultation with the Department of the Treasury, that it will review all loans in excess of $2 million, in addition to other loans as appropriate, following the lender’s submission of the borrower’s loan forgiveness application. Additional guidance implementing this procedure has been provided in subsequent FAQs and the consolidated interim final rule on loan forgiveness and loan review procedures.
The outcome of SBA’s review of loan files will not affect SBA’s guarantee of any loan for which the lender complied with the lender obligations set forth in paragraphs III.3.b(i)-(iii) of the first PPP Interim Final Rule, subsection C.3. of the consolidated interim final rule implementing updates to the PPP, or subsection (h)(2)(i) of the interim final rule for Second Draw PPP Loans, as applicable, and further explained in FAQ #1.