The SBA in consultation with the Department of Treasury has now issued Q & A #39, referencing Q & A #31 with the following:

Question:      Will SBA review individual PPP loan files?
Answer:         Yes. In #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 will be forthcoming.

In the April 29th email, (HERE) it was recommended that the dealership incorporate documentation and a discussion into the dealership’s corporate minutes, of the dealership’s sales and service area and economic uncertainty as well the dealership’s conditions and concerns that support the need for the PPP loan request.

Please consider making periodic updates, at least weekly, to your SBA loan file documenting the dealership’s and area’s downturn in sales—both new and used, service, parts, and F & I. Compare each department with the previous year, showing the dealership’s need for the PPP loan. In addition, document the personnel who are continuing to work at the dealership.

If audited, maintaining this information today will assist in showing the dealership’s need for the SBA loan, if necessary, at a later date.