ICBA has raised questions about an SBA "loan necessity" questionnaire for Paycheck Protection Program loans of $2 million or more that appears to go against the language of the CARES Act.

In a recent ICBA letter to congressional leaders and separate joint letters to lawmakers and agency heads, ICBA said the questionnaire has led many borrowers to justifiably fear that the SBA is altering PPP loan eligibility criteria after disbursement.

PPP applicants have already certified that they applied due to economic uncertainty. However, the letters note, the SBA last month began distributing the questionnaire with questions about business conditions in the months after the loans were disbursed.

The letters call on the SBA to temporarily suspend use of these questionnaires while they address these issues and work toward a better solution in line with the CARES Act and the PPP application.