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To: Parish business managers, school business managers, pastors and principals
From: Michael Warren, Director of Financial Services, Office of Finance
SBA/PPP RULES – The SBA has recently broadened their rules from the guidance sent out in April. The rules originally stated 8 weeks for payroll costs to be “earned and paid”, which has now expanded to 24 weeks.
The SBA also created at least one version of a “forgiveness worksheet”, which is attached, along with detailed instructions. This “Easy” worksheet (“PPP Loan Forgiveness Application Form 3508EZ”) was written to provide a basis for summarizing all payroll costs, and details a number of representations that must be stated, met and initialed.
Banks are not yet ready for the “forgiveness” process to start, but may be by early July. And they may well have another set of instructions to be followed.
Brad Wilson has recommended that all locations work to maximize their “forgiveness” request on actual payroll costs, rather than supplementing with other costs that may be more difficult to obtain speedy approval for. Although the Full Time Equivalent (FTE) computations are not included on this form, there are a couple of references to having NOT reduced personnel, or salaries within the “covered period” or “alternate covered period”.
The parish management needs to read the SBA rules and the instructions attached to this form, and make appropriate decisions. You may need to consider other forms available from the SBA. These rules are ever-changing. Assuming your staff size has remained constant, the “Easy” form is likely the best “forgiveness” form to complete.
FORGIVENESS REQUEST PROCESS – We are dealing with 8+ banks. Each bank may or may not require paperwork beyond what the “Easy” form calls for. As an authorized agent for each parish and school, the Office of Finance finalized almost all of the 102 loans. In this “forgiveness” stage, we will again work to assist you, your pastor/principal and your Parish Finance Council by acting again as your intermediary with the bank, when the banks are ready for the process to begin.
When that date arrives, we will ask that each location prepare a Loan Forgiveness Request Package (including any additional paperwork required by your bank), and then, send the Package to our Office by email to file on your behalf. Once we receive the bank’s confirmation of forgiveness – which may take up to 60 days – we will transfer that amount of the original loan funds to your bank account.
INDEPENDENT LOANS – For those locations that obtained PPP loans independently, you should follow the bank’s guidance and give us an update once you find out what amount of your loan was forgiven. We assume all loans will be entirely forgiven, but must have adequate backup to support the request.
FORGIVENESS PACKAGE – Your parish/school “package” should include a fully completed copy of the 2-page EASY worksheet (attached), signed by the president of your incorporated entity (the pastor or principal), and any supportive payroll cost reports, such as the Paychex report noted below.
PAYCHEX REPORT – Paychex has developed a Loan Forgiveness Report and it is available for each location to run. Copies of that report were emailed to each locations late last week. The report is report ID CAREFRGV, the PPP Loan Forgiveness Worksheet. Users can edit the report and enter the first check date for the period of their loan and the last check date for the period of their loan.
Each location will need to determine what dates to use.
COMPLETED LOAN FORGIVENESS PACKAGE – Once you have compiled the packet, it should be emailed to the Office of Finance (LoanForgiveness@archatl.com).
LOCATIONS WITH NO LOANS – There were 22 locations that did not obtain a PPP loan, generally due to very small staff size. Brad has asked that we continue to evaluate what type of funding might be made available to help these locations.
Please let us know if you have further questions. Thanks.