The CARES Act, PPP, FFCRA and Your Church

 


The North Georgia Conference will continue to update resources and information on PPP Loans and Loan Forgiveness and other relevant portions of the CARES Act. 

 

PPP Loan Forgiveness

  • SBA Guidance on Good Faith Certification
  • Loan Forgiveness Summary and Application
  • Notes on PPP Loan Forgiveness from NGUMC Treasurer
  • Updated (June 16, 2020) SBA Loan Forgiveness Form and Instructions
  • Update: On August 4, 2020, the U.S. Treasury Department and Small Business Administration (SBA) published a set of FAQs about Paycheck Protection Program (PPP) Loan Forgiveness. While some of the FAQs repeat existing guidance in the SBA’s regulations and forms and instructions, the August 4 FAQs provide some new information that may be helpful for PPP borrowers.
  • The IRS has ruled that expenditures made with PPP loan proceeds cannot also be deducted from gross business revenue. In Revenue Ruling 2020-27, the agency lays out the policy with additional details:
    • Borrowers that hold a reasonable expectation that their loans will be forgiven may not claim as business expenses any costs that are otherwise deductible, if these costs were covered by PPP loan funds. 
    • This policy holds true whether or not the borrower has applied for forgiveness at the end of the taxable year.
  • Revenue Procedure 2020-51 defines a safe harbor procedure that allows PPP borrowers to recapture the value of those lost deductions should the loan not be forgiven. Loan recipients can follow the safe harbor procedure to deduct those expenses from taxable revenue after receiving confirmation that their application for forgiveness has been rejected or if they decide not to request forgiveness after all. 

 

Families First Coronavirus Response Act Overview

On March 19, 2020, the President signed the Families First Corona Virus Response Act (FFCRA) into law. FFCRA was created to ensure the safety of American workers. The FFCRA requires certain employers to provide their employees with paid sick leave and expanded family and medical leave for specified reasons related to COVID-19. These provisions will apply from April 1, 2020 through December 31, 2020. In general, employees of private sector employers with fewer than 500 employees, and certain public sector employers, are eligible for up to two weeks of fully or partially paid sick leave for COVID-19 related reasons, and may be eligible for up to an additional 10 weeks of partially paid expanded family and medical leave to care for the employee’s child.

The GCFA Legal and Human Resources Departments have reviewed the legislation and have provided a list of frequently asked questions with their interpretation of the FFCRA legislation which can be found here:

The FFCRA also requires that the following be posted at your work location or emailed to all employees if offices are closed:

 

More CARES Act Updates and Resources

The Families First Coronavirus Response Act (“FFCRA”) concerning paid leave for employees, the Paycheck Protection Program (PPP), and the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act related to unemployment insurance and church staff all have implications for local churches. 

A number of organizations are working to interpret the act as it relates to churches and non-profits. We will continue to update this page with useful analysis.

Note that information is developing every day.


IRS Employee Retention Credit (for churches not receiving the PPP Loan):

 

More CARES Act Information: