The Church Alliance Files Second Letter with SBA (May 5, 2020)
On May 5, 2020, the Church Alliance filed a comment letter with the U.S. Small Business Administration (SBA) responding to its request for comments on its recently published final interim rule regarding the Paycheck Protection Program (PPP). The letter thanked the SBA for its support in helping non-profits work through COVID-19 challenges and focused on the unique difficulties for schools seeking forgiveness of PPP loans. Because of the timing of the pandemic, timing of PPP loan disbursements, and statutory periods for calculating forgiveness, the traditional school calendar puts schools at a tremendous disadvantage such that 100% forgiveness may not be attainable. Our letter offers a an approach to the forgiveness calculations that will avoid penalizing schools for their seasonality. The letter seeks answers to several other open forgiveness questions and asks whether forgiveness of a PPP loan would trigger the requirement for a single audit under the Single Audit Act of 1984.