View Information Collection Request (ICR) Package
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Please note that the OMB number and expiration date may not have been determined when this Information Collection Request and associated Information Collection forms were submitted to OMB. The approved OMB number and expiration date may be found by clicking on the Notice of Action link below.
View ICR - OIRA Conclusion
OMB Control No:
3245-0407
ICR Reference No:
202106-3245-002
Status:
Historical Inactive
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
OIRA Conclusion Action:
Withdrawn and continue
Conclusion Date:
06/28/2021
Retrieve Notice of Action (NOA)
Date Received in OIRA:
06/21/2021
Terms of Clearance:
Inventory as of this Action
Requested
Previously Approved
Expiration Date
09/30/2021
6 Months From Approved
09/30/2021
Responses
37,002,166
0
37,002,166
Time Burden (Hours)
9,935,129
0
9,935,129
Cost Burden (Dollars)
355,220,794
0
355,220,794
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
Authorizing Statute(s):
None
Citations for New Statutory Requirements:
None
Associated Rulemaking Information
RIN:
Stage of Rulemaking:
Federal Register Citation:
Date:
Not associated with rulemaking
Federal Register Notices & Comments
Did the Agency receive public comments on this ICR?
No
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 3506, SBA Form 3508 Instructions , SBA Form 3508EZ, SBA Form 3508D, SBA 3508S Instructions , 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
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.
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
Agency Contact:
Mary Frias 202 401-8234 mary.frias@sba.gov
Common Form ICR:
No
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