FOR IMMEDIATE RELEASE: January 4, 2021
The Consolidated Appropriations Act of 2021 has been approved by Congress and signed by the President. It includes $284 billion dollars for a second round of Paycheck Protection Program (PPP) Loans that churches and nonprofits are eligible to apply for.
The Small Business Administration has 10 days to issue regulations related to the new application process. When the SBA issues these regulations, they will begin publishing a series of clarifications and new guidance. As we enter the second round of PPP Loans, the SBA is still actively sharing new guidance on the first round of loans with banks. This is the primary reason most churches and nonprofits have yet to receive forgiveness on their current loans. Joe Park with Horizons shared these key provisions as they are generally understood today. He cautions us that the devil is in the details and those have yet to be published.
Limited Eligibility: Eligibility is limited to churches and nonprofits that have less than 300 employees and whose gross receipts were at least 25 percent less in one or more quarters of 2020, as compared to the same quarter in 2019.
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.
Maximum Loan Amount: Borrowers have an option to calculate the maximum loan amount by multiplying the borrower's average total monthly payroll in (a) the one-year period prior to the date on which the loan is made, or (b) calendar year 2019, by 2.5x. The maximum loan amount is $2 million. Similar to the first round, seasonal employers calculate their maximum loan amount differently.
Choose Your Own Covered Period: Borrowers are able to choose the length of their covered period so long as it is at least eight weeks and is not longer than 24 weeks.
Use of PPP Funds: Congress expanded the types of expenses for which PPP loans can be used for new and existing loans. In addition to payroll, rent, covered mortgage interest and utilities, the PPP loan now allows proceeds to be used for:
Forgiveness for Loans under $150,000: Forgiveness application for loans under $150,000 will be simplified to a one-page certification that includes a description of the number of employees the eligible recipient was able to retain because of the loan, the estimated total amount of the loan spent on payroll costs and the total loan amount. Borrowers should be aware that while the forgiveness application is simplified, all of the rules still apply. All borrowers must retain all employment records relevant to the forgiveness application for a period of four years and all other records relating to PPP and the forgiveness application for a period of three years.
In response, Horizons will again partner with CapinCrouse, a leading CPA firm whose practice is solely churches and nonprofit organizations, as well as with other respected sources to bring you the best information as it becomes available.
You can find more detailed information about the Consolidated Appropriations Act of 2021 at Horizons.net or on Giving365. Joe remined us in his article to log into Giving365 recently. Their free online library of ministry resources for pastors, staff, lay leaders, finance committees and generosity teams has hundreds of resources designed to help you make disciples and fund ministry.
As we get more information and as Horizons schedules webinars, I will keep you posted. I would encourage you to look at your income comparison by quarters in 2020 and 2019. This will be the piece that might prohibit you from applying as I do not know of any churches in the Mississippi Conference with more than 300 employees. By doing so, you will be ready to determine if you can apply for additional PPP loan proceeds your income. Stay tuned for more information.