CHURCH EXECUTIVE JAN / FEB 2021 | Page 18

LOOKING AHEAD TO

What the second round of PPP loans means for churches — and how to secure funding

After much political drama , the Consolidated Appropriations Act of 2021 ( CAA ) [ https :// bit . ly / 3hIWqaR ] has been approved by Congress and signed by the President .
It includes $ 284 billion dollars for a second round of Paycheck
Joe Park
Protection Program ( PPP ) Loans for which churches and nonprofits are eligible to apply through participating banks .
Your banker might be slow to begin taking applications . Here ’ s why . The Small Business Administration ( SBA ) is charged with developing regulations related to the new application process . This sounds like a simple and straightforward process ; but as we learned with the first round of PPP loans , the reality is neither simple nor straightforward . Upon issuance of these regulations , the SBA gets flooded with questions from banks , attorneys and accounting firms and with political pressure from the Congress and the Administration . They then begin publishing a series of clarifications and new guidance that in the first round resulted in bankers repeatedly going back to their customers with new applications and / or asking for additional documentation . The same is true with the PPP forgiveness applications . Seven months have elapsed since the first PPP loan forgiveness applications were submitted , and the vast majority of these applications have yet to be processed by banks , primarily because the SBA is still actively sharing new guidance on the first round of loans with banks . In fact , the new Consolidated Appropriations Act significantly changes the loan forgiveness process for the first round of PPP Loans approved in the CARES ACT , which will further
delay the forgiveness previously approved loans . Thus , I want to caution you that the devil is in the details — and those details are subject to change .
Limited eligibility for qualifying for a new PPP loan Eligibility is limited to organizations , including churches , that meet the following criteria :
1 ) Less than 300 employees
2 ) Gross receipts were at least 25 % less in one or more quarters of 2020 , as compared to the same quarter in 2019 . This can get complicated for churches with complex streams of income . For the purposes of calculating gross receipts , churches are referred to the meaning of section 6033 of the IRS code of 1986 . [ www . law . cornell . edu / uscode / text / 26 / 6033 ] I recommend asking your external accountant to calculate this for you .
3 ) Necessity requirement : All borrowers must be able to certify that the “ current economic uncertainty makes this loan request necessary to support the ongoing operations ,” as of the date on which the PPP loan application is submitted . This is where is gets sticky for many churches . I believe Congress left this language “ current economic uncertainty ” intentionally vague to allow as many organizations as possible to apply . Most churches would agree that “ can ” is not synonymous with “ should ,” given the many biblical admonitions to rise above the ways of the world to what is honoring and pleasing to God . As churches wrestle with whether or not they should apply , I would encourage them to remember that they may return the funds at any point if they determine the loan was not necessary .
Other key provisions Based on the current common understanding , the following are other key provisions to consider when determining if a new loan is right for your church .
18 CHURCH EXECUTIVE | JAN / FEB 2021