As you know the CARES Act was passed into law a few weeks ago and last Friday Small Business Administration (SBA) lenders began accepting applications. We have heard that Wells Fargo has already reached its max of $10 Billion in PPP funds and has stopped accepting applications.
Here are a few things we have discovered in the past week:
- The SBA provided guidance not a formalized process, procedure, or uniform application. So, every lender has created their own application process and is interpreting the guidance through its own lens.
- Every lender is asking different types of questions and most have not formatted the application process with non-profits in mind.
- Typically, they ask a question about “affiliated group” or “common management”. For you those answers are “NO”, we are NOT under common management.
- Most major denominations have a shared 501c3 non-profit exemption. So, churches do not need their own separate 501c3 exemption. That being said, many banks may still ask for our exemption documents. If you don’t have a copy of yours, please contact the SED office.
- Any church personnel paid as independent contractors (1099) need to apply on their own and may not be included in in a church application. These individuals must apply on their own as self-employed persons. This is another reason why churches should already be correctly employing their pastors and staff as common law employees who receive W-2s.
- The official guidance makes a reference to wages and “similar compensation” that may be included in the loan application, and this language applies to housing allowance. However, housing allowance is not included in 941s, so churches may get push back from banks who are not familiar with ministers housing allowances as a legal form of clergy compensation. Please be prepared to explain this.
- If you encounter an ownership question that requires naming an individual, please contact Paul Glenn for advice.
If you have questions or need assistance, please contact Paul Glenn at firstname.lastname@example.org or his cell, 704.239.0569.