[OMS_MANAGERS] Update from NAO on the Payroll Protection Program (PPP)

Mon Apr 6 13:28:37 PDT 2020

This message is being forwarded over the OMS listserv. All responses will be over the listserv.
NAO will be offering an Ask the Experts session tomorrow on Emergency SBA Loans and How Nonprofits Can Access Them. Register here<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9g7aE2igRt_wAA_jeljEB3Ih_CnKBozxk2wfNunUuwlsa2dh1jk9ix-k0hHiN_IzxfNmQzgTyTSjbvksp5tg31LX3x_Ew9NAV91jInAYQO36IBRjM300k2A7A5ELQi9Hs7Xs9NJI9pKZxokVIEUeWB4WykyVYTOZGq&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==>.

Late in the evening on April 2nd, the Small Business Administration announced that it had released final details and guidance for the Payroll Protection Program<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9g3CBwarvo1Yz0yrp4Qh9XAiq-rLXzhTKM7t6Ojlal_VBJ0Lqq-q1BCUccY9cqUkRs_UqICRZcvFT5VlwbCDzzezEQuheGDyLukXxq9rRtIQdVzadL2puKsLcBz2TofPwGHsLP--_ueQdH1FMoKzTqPy6b04iqgHj6b7YyzoX4BeXxbrLa_0Pjr5Jbik1F92aKw0oapswnOX-JuH_gGju1nw==&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==> (PPP) and signaled the program would "go live" on Friday. The PPP is designed to help businesses keep their workforce employed during the COVID-19 crisis. The attraction of these loans is that they are highly forgivable and it is expected that much of the over $350 billion in the PPP will be forgiven, effectively making them grants.

What happened on Friday during the "launch" of the PPP can be described as nothing short of pandemonium. Some banks were reporting they had received access through the portal and were uploading applications, while others were holding off to get clarifications from the SBA. The SBA has also been criticized for issuing conflicting or belated guidance on numerous issues in the loan programs, including how borrowers are supposed to count the total number of employees for determining whether an employer has 500 or fewer employees. For charitable nonprofits, the CARES Act expressly applies strict SBA affiliation rules that require all employees of separate affiliates to be counted as a group if the parent organization can exercise control over the whole. On Friday, SBA issued additional guidance largely exempting faith-based organizations from the affiliation rules<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9g09D3A8yoakOOdDdzyBe_-kw3rRd0w3SEsFDS-eORD0hsXtvVcWt9soPwAwVT88HSxObXlsZwCeTn5FmZrSgF27kp67sX2HR4FCRbQWoCuv3fq7nV7OKLGWvw19giSthgk9O1sOrjIra5fw6yVQwO5X1RDm3AZPmRb5B2IByQFbXb6-u18V1e383eEFRGwt6EoMT-LKSL3keHY5iZiK3dMq7tcDNfdFiu61d2gyu_T5ddxa7Ul_-sD-K9sX8ZkgaGxteZBPFncOrHjEND5R8lzlAANa3XeG1fpxMVWgfos-82kapitAUqlEWsrkHhARHI1V6etbIK9PavYnNJgGZgwxS4T8OdIey7VWOEWigUg_sKxdWneSKNFcadEwxj0L_IFNpOpiS77TcKqviSE86PqzPZU1RIDCZ5_JI-1iCgzty5-mka_D_ek76Y0DILMMWnMArXP3jrDVXbCh4kToHaNRsakAOUQ-xjkXSGx0teQCe4B0qgC9zVZNGRM52SsmSkjdo4ksAtnG-KUw4-6pzWs0AoGSNABQlehleomT97SkLJHj8BEvbXuTTkP5bkhy1yqLslS6_2DtAaJu46tFEMiqMJJU8JPFejY1LuLLHc-Jis6id4HuRmsTAeiA1vhrFgMT7ExbUwXNAubvHzIR1THSm0-5gPPJuz8uDTbZ4KolC9Q5uNU4CiwaSAY4LHPSSjNuiTuccSjBOEKx5rjUDmLq4EosK3UG5I_rLrDIaqjgllLce4nyPHRzRt9AOPim3js4QHfCImUGqFoE7X6fTb10NnbWxz1QNMqw5zD9VnvZXm4DXMH-qkFmYRKKPKYf3edwoiTYtgG0Jgb_DmUG0Qnd8uQfgOS_su5yVWlde2vpbzUdJNxUEs1w==&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==>, citing religious freedom and constitutional protections.

NAO has been working with National Council of Nonprofits and Independent Sector on getting clarity, guidance and support for Oregon's nonprofit sector. In an open letter issued this afternoon addressed to the American Bankers Association and Bank Policy Institute, Independent Sector asked that financial institutions prioritize nonprofits to ensure equitable access to SBA 7(a) loans for those that qualify as part of the CARES Act. Independent Sector has asked that financial institutions prioritize nonprofits to ensure equitable access to SBA 7(a) loans for those that qualify as part of the CARES Act; that they particularly pay attention to small nonprofits, nonprofits run by people of color, and nonprofits serving communities of color and tribal communities; and called on them to see the charitable community as a partner in finding solutions. See Independent Sector's open letter here<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9gTzRyHOedTkZk0L6SAzL5SSAsGZB7_uD7Hepr4fHqaQYMw1jbtV3ylqBXMN06mQIzJnO6deDTec3UDXonnZYHxTsB0PqwBMTcuep0w8bMUulbIsQvnEcHSYxuyzPutFb8t9J7NT0dEZ_DqRCl5Kvzp1HGuQ6UD9h0VIzLXorRZJ452-o0c9hI2pFZoLLTkTow&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==>.

There are many Oregon banks that are qualified to handle the PPP loans<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9g7om-nLCMVz-ZYEUGJCG9YAwOgBfUf7e4Lt4paAluy1gUY20S27E6TMalvtxnVIS7luSo3lcDs2YlBzSyoMtqhCblwdG5hEIytWUVn9kVXC-O8mt-RENzeQtNA9RE47HUj2X7TJh5CBf-ATeckJGLQhTzBVw5D_Pmwzap7JspU9c=&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==> and we have been checking in with several of them. None of the banks that we reached out to were able to confirm that they were uploading client applications to the portal, although we did hear from some of you that there were banks with successful uploads on Friday. (Rumors of uploads on Thursday were just that - rumors - as NO banks had access at that time.) Most banks are telling us that they are prioritizing their current clients for the applications and they expect to have access and the processes clarified to begin uploads today and tomorrow.

It is important to remember that each bank will have its own modified processes and applications for this program, so please pay attention to the instructions your bankers are giving you on the details they need to process your applications.

Don't lose heart if your organization doesn't get a PPP loan the first time out! While the $350 billion will go quickly, it is expected that there will be successive tranches of funds through additional federal stimulus packages that will expand the funding for this program.

NAO will be offering an Ask the Experts session tomorrow on Emergency SBA Loans and How Nonprofits Can Access Them. Register here<http://r20.rs6.net/tn.jsp?f=0011EABCuXc-jKxU8SojkJSsBHa-WuegAEMxxBExrKBLHHrT58LejhkVsLYsObP8E9g7aE2igRt_wAA_jeljEB3Ih_CnKBozxk2wfNunUuwlsa2dh1jk9ix-k0hHiN_IzxfNmQzgTyTSjbvksp5tg31LX3x_Ew9NAV91jInAYQO36IBRjM300k2A7A5ELQi9Hs7Xs9NJI9pKZxokVIEUeWB4WykyVYTOZGq&c=o8z_UJk4kWqrdby4a1ta1OO5bpOFJGDcdi1dXGWlqCldAcppHDm9AQ==&ch=N76htN6pkeqHj6yQgo7DfM1OoAk2mbVwhTJ2ZQZKV3n18337xDg9sA==>.

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