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Small Business Administration Drops Retroactive Necessity Criteria for PPP Loans

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The Small Business Administration (SBA) and the Department of Treasury recently announced that they would no longer apply retroactive necessity criteria to applications for Paycheck Protection Program (PPP) loans above $2 million. SBA rolled out the necessity questionnaire late last year for loans of more than $2 million. This criteria was not part of the congressional intent of the CARES Act and NRMCA opposed applying this to companies that in good faith applied for and received PPP loans of any size.

Last year, NRMCA aggressively advocated for the creation of a program that would support small businesses’ need for liquidity and certainty through the pandemic, and applauded the passage and implementation of the PPP. NRMCA held webinars and provided its members with the education and tools to take advantage of PPP loans; and nearly one-third of NRMCA companies applied for and received these loans. Over the past year, NRMCA consistently advocated for fair treatment of companies that received Paycheck Protection Program loans of all sizes without the retroactive application of new standards for forgiveness. The announcement from the SBA and Treasury is a significant win for the industry and the many NRMCA member companies that applied for and received PPP loans.

For more information, contact Andrew Tyrrell at


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