Received: from mta4.cpro20.com ([216.24.226.4]:14896) by stodi.digitalkingdom.org with esmtps (TLSv1.2:ECDHE-RSA-AES256-GCM-SHA384:256) (Exim 4.92) (envelope-from ) id 1jfm7x-0000Bj-B1 for lojban@lojban.org; Mon, 01 Jun 2020 08:13:28 -0700 DKIM-Signature: v=1; a=rsa-sha256; c=relaxed/relaxed; s=key1; d=cpro20.com; h=List-Unsubscribe:Message-ID:Date:Subject:To:From:Reply-To:MIME-Version: Content-Type; bh=+TT1BCHUSCHxOmstJLL1c/UPHIKEvxRrlf6vzYaBXjU=; b=VbnSPG/oBbpj+htv1eLcn5cCj5Lr7O0SiOzqOBpMzRnrgYfhAILHH/c5C+orUiILqXc4OOdKbcet TpMnAr4ngkRecjnMiMQGdduFDhOPuXzIHpCmBYS0qOWV5fK+Vll26j8I+BYYbz/wbwo6noMPG88W kyeK2Sc3zb6B/+zPgVU= Received: by mta4.cpro20.com id hqkdha2l5s43 for ; Mon, 1 Jun 2020 11:12:42 -0400 (envelope-from ) List-Unsubscribe: X-Campaign-Shard: 1 Bounces-To: bounce_qoeegd_gmnhvtit_o@cpro20.com Message-ID: <1591024267784.43912745.123810195.29719122258@backend.cpro20.com> X-Campaign: 43912745/123810195/29719122258 Errors-To: bounce_qoeegd_gmnhvtit_o@cpro20.com Date: Mon, 1 Jun 2020 11:12:42 -0400 Subject: PPP Flexibility Act - Seven Things Nonprofits Need to Know - June 1, 2020 To: Nonprofit Execs & Board Members From: "Inside Charity" Reply-To: "Inside Charity" MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="----=_Part_1290516682.1591023612143" X-Spam-Score: -1.7 (-) X-Spam_score: -1.7 X-Spam_score_int: -16 X-Spam_bar: - ------=_Part_1290516682.1591023612143 Content-Type: text/plain;charset=UTF-8 PPP Flexibility Act - Seven Things Nonprofits Need to Know - June 1, 2020 (Because of your important work with Charitable Organizations) Dear Nonprofit Execs & Colleagues In Service, Charity PPP Loan Flexibility Act - Seven Things Nonprofits Need to Know is INSIDE CHARITY's review of the new Paycheck Protection Program Flexibility Act which "attempts" to ease restrictions on charities as they seek loan forgiveness under the Paycheck Protection Program authorized by the CARES Act. While there is optimism in Washington that this new bill will reach President Trump’s desk for signature, there is no guarantee of when or if this may happen. And, until that occurs, the new and harsher Treasury regulations issued on May 22 will dictate how the PPP loan forgiveness process works. The biggest problem with the new regulations is that your nonprofit will likely need a lawyer, accountant, and advanced degree in mathematics to figure out how to calculate the forgivable portion of the loan. The government once again did not realize the administrative burden these rules place on charities at a time when they’re trying to figure out how to survive the coronavirus shutdown and cautious reopening of our economy. 1. The SBA can review any loan at any time The May 13 Treasury FAQs provided a “safe harbor” for all loans under $2 million, deeming them made in “good faith” that the economic uncertainty faced by the borrower necessitated the loan. However, it did leave the door open to the possibility that the SBA could review all loans made to charities to determine eligibility and accurate calculations for the loan amount and forgiveness. The new regulation elaborates on this as follows: “For a PPP loan of any size, SBA may undertake a review at any time in SBA’s discretion. For example, SBA may review a loan if the loan documentation submitted to SBA by the lender or any other information indicates that the borrower may be ineligible for a PPP loan, or may be ineligible to receive the loan amount or loan forgiveness amount claimed by the borrower. 13 CFR 120.524(c).” Once again, eligibility refers to access to “credit elsewhere,” or the “liquidity” of the borrower. So, under these rules, the SBA could review your loan and determine you had credit elsewhere or other funds, and require you to pay back the loan in full or in part. Banks lose out on this one too, as the SBA can withhold the bank fee or “claw” it back if they make this determination. The SBA will still guarantee these loans, however. Many business groups, including the Independent Community Bankers Association (ICBA), are lobbying aggressively for a true “safe harbor,” for which loans under $1 million will be considered eligible, not reviewable, and forgiven. The overwhelming majority of PPP loans are under $1 million. Even without this, audits of this nature will likely be rare as the SBA lacks the capacity to conduct a large number of them. However, if your loan is over $2 million and you had sufficient liquidity or credit elsewhere, you may consider repaying the loan or be prepared for an audit. 2. The loan forgiveness process could take up to 5 months Once you file the forgiveness application with your bank, it will have 60 days to review it and let you know the amount of forgiveness. The bank will then notify the SBA of the amount of forgiveness and the SBA will have 90 days to approve the bank’s decision. The SBA can request more information from your lender or nonprofit directly and then will approve the amount in whole or in part. If the SBA determines a portion or all of the loan did not meet the guidelines for eligibility or forgiveness, it can request repayment of the loan or “pursue other available remedies.” The guidelines do not explain what these other remedies might be. Borrowers do have the right to appeal decisions rejecting forgiveness to the SBA. It is important to note the SBA now requires borrowers to keep all files and paperwork on PPP loans for six years. Inside Charity is pleased to report that over 200,000 executives, staff, board members, ministry leaders and volunteers rely on Inside Charity for their nonprofit news. over the past ten days. We're grateful to everyone who has participated and want to encourage as many as people as possible to continue to share their experiences. Your written comments and contributions have helped your colleagues navigate this process. We are all in the throes of the global pandemic. Charities everywhere are feeling the effects of isolation measures, business shutdowns, travel bans, and markets crashing. InsideCharity is here to make sure receive the information you require to navigate these unprecedented times. We're in direct contact with the financial experts at the SBA to provide you real-time updates you need to navigate CARE Act funding. We look forward to hearing from you. Simply reply to this email or subscribe above to ensure you receive CARES Act Updates every time the Federal Government makes them available. Warmly, James P. LaRose, CNE, CDE, CNC Senior Editor You are subscribed to this email as lojban@lojban.org. Click here to modify your preferences http://trk.cpro20.com/form?21pok3--11cug-dnhzxhu7&sl=y&t=1&ac=g62g or unsubscribe http://trk.cpro20.com/form?21pok3--11cug-dnhzxhu7&sl=y&t=5&ac=g62g. ------=_Part_1290516682.1591023612143 Content-Type: text/html;charset=UTF-8
(Because of your important work with Charitable Organizations)                                                 

PPP Flexibility Act - Seven Things Nonprofits Need to Know - June 1, 2020
(Because of your important work with Charitable Organizations)

(Press Picture Below For Complete Article)

PPP Loan Flexibility Act - Seven Things Charit.jpg

Dear Nonprofit Execs & Colleagues In Service,

Charity PPP Loan Flexibility Act - Seven Things Nonprofits Need to Know is INSIDE CHARITY's review of the new Paycheck Protection Program Flexibility Act which "attempts" to ease restrictions on charities as they seek loan forgiveness under the Paycheck Protection Program authorized by the CARES Act. While there is optimism in Washington that this new bill will reach President Trump’s desk for signature, there is no guarantee of when or if this may happen. And, until that occurs, the new and harsher Treasury regulations issued on May 22 will dictate how the PPP loan forgiveness process works.

The biggest problem with the new regulations is that your nonprofit will likely need a lawyer, accountant, and advanced degree in mathematics to figure out how to calculate the forgivable portion of the loan. The government once again did not realize the administrative burden these rules place on charities at a time when they’re trying to figure out how to survive the coronavirus shutdown and cautious reopening of our economy.

1. The SBA can review any loan at any time

The May 13 Treasury FAQs provided a “safe harbor” for all loans under $2 million, deeming them made in “good faith” that the economic uncertainty faced by the borrower necessitated the loan. However, it did leave the door open to the possibility that the SBA could review all loans made to charities to determine eligibility and accurate calculations for the loan amount and forgiveness.

The new regulation elaborates on this as follows:

“For a PPP loan of any size, SBA may undertake a review at any time in SBA’s discretion. For example, SBA may review a loan if the loan documentation submitted to SBA by the lender or any other information indicates that the borrower may be ineligible for a PPP loan, or may be ineligible to receive the loan amount or loan forgiveness amount claimed by the borrower. 13 CFR 120.524(c).”

Once again, eligibility refers to access to “credit elsewhere,” or the “liquidity” of the borrower. So, under these rules, the SBA could review your loan and determine you had credit elsewhere or other funds, and require you to pay back the loan in full or in part. Banks lose out on this one too, as the SBA can withhold the bank fee or “claw” it back if they make this determination. The SBA will still guarantee these loans, however.

Many business groups, including the Independent Community Bankers Association (ICBA), are lobbying aggressively for a true “safe harbor,” for which loans under $1 million will be considered eligible, not reviewable, and forgiven. The overwhelming majority of PPP loans are under $1 million. Even without this, audits of this nature will likely be rare as the SBA lacks the capacity to conduct a large number of them. However, if your loan is over $2 million and you had sufficient liquidity or credit elsewhere, you may consider repaying the loan or be prepared for an audit.

2. The loan forgiveness process could take up to 5 months

Once you file the forgiveness application with your bank, it will have 60 days to review it and let you know the amount of forgiveness. The bank will then notify the SBA of the amount of forgiveness and the SBA will have 90 days to approve the bank’s decision.

The SBA can request more information from your lender or nonprofit directly and then will approve the amount in whole or in part. If the SBA determines a portion or all of the loan did not meet the guidelines for eligibility or forgiveness, it can request repayment of the loan or “pursue other available remedies.” The guidelines do not explain what these other remedies might be. Borrowers do have the right to appeal decisions rejecting forgiveness to the SBA.

It is important to note the SBA now requires borrowers to keep all files and paperwork on PPP loans for six years. The regulation states...VISIT HERE TO READ ENTIRE ARTICLE


Inside Charity is pleased to report that over 200,000 executives, staff, board members, ministry leaders and volunteers rely on Inside Charity for their nonprofit news. We're grateful to everyone who has participated and want to encourage as many as people as possible to continue to share their experiences. Your written comments and contributions have helped your colleagues navigate this process.

We are all in the throes of the global pandemic. Charities everywhere are feeling the effects of isolation measures, business shutdowns, travel bans, and markets crashing. InsideCharity is here to make sure receive the information you require to navigate these unprecedented times. We're in direct contact with the financial experts at the SBA to provide you real-time updates you need to navigate CARE Act funding.

VISIT HERE TO SUBSCRIBE

We look forward to hearing from you. Simply reply to this email or subscribe above to ensure you receive CARES Act Updates every time the Federal Government makes them available.

Warmly,

James P. LaRose, CNE, CDE, CNC

Senior Editor


You are subscribed to this email as lojban@lojban.org.
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