Legislative Updates
At Concordia Plan Services we care deeply for the well-being of the ministries and members we serve. This is true at all times, but our concern is especially heightened as we work to understand the impact of COVID-19. Please use the following resources to answer some of your questions about the impact of COVID-19. God bless you and your ministry during this challenging time.
RESOURCES
- Paycheck Protection Program loans: Organizations that received a PPP loan in 2020 are, in some cases, eligible to apply for and receive a second loan. See the Q&A document for more information, including the additional types of expenses that loan proceeds can be used to cover.
- A resource document detailing additional provisions of the act, including those related to pandemic unemployment assistance, recovery rebates for individuals and tax credits for paid sick and family leave. The document includes links to the original information on these topics from the CARES Act and Families First Coronavirus Response Act.
- FSA flexibility through the Consolidated Appropriations Act: The December 2020 appropriations act has provisions that provide temporary relief for health and dependent care flexible spending arrangements (FSAs). This relief is especially impactful as many workers were not able to use all of their FSA funds in 2020 and are at risk of losing those funds. See the document to learn about the relief options available to employers.
RESOURCES
More than $300 billion has been added to Paycheck Protection Program funding and is available through small business loans. If your ministry has not yet applied for a PPP loan there is still time and we encourage you to look into this option.
The Lutheran Federal Credit Union (LFCU) is positioned to become a Small Business Association approved lender for these loans. Applying through the LFCU may be an option for current LFCU members and/or ministries struggling to find a lender that will accept their application. Any ministry that wishes to apply through the LFCU must first apply for LFCU membership. For more information, click here.
Status
- Signed into law 3/27/20
Who it applies to
- Small business loans as described in act available to employers with fewer than 500 workers.
Resources
CARES Act Topics
Paycheck Protection Program (Small Business Loans) - CARES Act Summary
More than $300 billion has been added to Paycheck Protection Program funding and is available through small business loans. If your ministry has not yet applied for a PPP loan there is still time and we encourage you to look into this option.
The Lutheran Federal Credit Union (LFCU) is positioned to become a Small Business Association approved lender for these loans. Applying through the LFCU may be an option for current LFCU members and/or ministries struggling to find a lender that will accept their application. Any ministry that wishes to apply through the LFCU must first apply for LFCU membership. For more information, click here.
If your ministry has received a PPP loan:
Court Orders Disclosure of all PPP Loan Recipients and Amounts: Date of SBA Compliance Unknown
Flexibility Act: New Terms for PPP Loans
Choosing the Right Application for PPP Loan Forgiveness
Application for Loan Forgiveness
Application for Loan Forgiveness – EZ version
Forgiveness Application Form 3508S for loans $50,000 and under
SBA Guidance on Loan Forgiveness
LCEF Conversation with SBA Reps on Loan Forgiveness
Review Procedures and Borrower Responsibilities
Note: This document was published before the Flexibility Act was passed in early June. This information may be subject to change.
Additional options made available by legislation
Loan Forgiveness: Steps to Take if You Receive a Loan
If your ministry has not yet applied for a PPP loan:
Additional options made available by legislation
What Your Ministry Needs to Know about Applying for Loans
Clarification on Housing Allowance
If your ministry applied for a loan and was rejected:
Additional options made available by legislation
Small Business Administration Information
Summary of SBA Rules Regarding PPP Loan Program
- SBA Rules Regarding PPP Loan Program
Note: This document was published before the Flexibility Act was passed in early June. This information may be subject to change.
SBA Guidance and Loan Resources Webpage
PPP Loans and Religious Entities
SBA FAQs for Religious Entities on PPP and EIDL Loans
Joint Congressional Letter on Nonprofit Eligibility
Senator Rubio Encourages Churches to Apply for PPP Loans and Addresses Questions about Churches Accepting Federal Money
Lutheran Church Extension Fund Guidance on CARES Act
- Note: since the publishing of this article, the SBA has published its guidance and religious organizations are not precluded from applying for PPP Loans
- Payroll Taxes Delay (Social Security taxes)
- Employee Retention Credit
- Main Street Lending Program
- The Federal Reserve Board recently announced the availability of new loans for tax-exempt organizations through their Main Street Lending Program. These loans are separate and different from the Paycheck Protection
Program loans that were made available earlier this year.
There are several requirements for an organization to be eligible, including that it employs at least 10 employees and that non-donation revenues are equal to or greater than 60% of expenses for the period from 2017 through 2019. This requirement may make it challenging for churches to qualify. Loans through this program are not forgivable. For more information, click here.
- The Federal Reserve Board recently announced the availability of new loans for tax-exempt organizations through their Main Street Lending Program. These loans are separate and different from the Paycheck Protection
Program loans that were made available earlier this year.
- Economic Stabilization Loans (for ministries with 500+ employees)
- Pandemic Unemployment Assistance Program (expands unemployment eligibility)
- Charitable Contributions Incentives
- Recovery Rebates for Individuals
- Student Loan Relief
- Retirement Plan Changes (403(b) distributions)
The CARES Act provides opportunities to access funds from your 403(b) account or other retirement savings accounts if you have suffered serious financial harm due to the economic effects of COVID-19.
If you are experiencing financial stress, this may seem like a quick fix. But before making any decisions to tap into your 403(b) savings, it is important to understand the consequences of a distribution and consider alternatives. To help you make an informed decision, click here to view important considerations before you make a withdrawal from your CRSP account or other retirement savings accounts.
To learn more watch the webinar on the CRSP and CARES Act or contact one of our financial wellness educators:
- Karen Wilhelms - Karen.Wilhelms@ConcordiaPlans.org
- Laura Scheer - Laura.Scheer@ConcordiaPlans.org
- Health Plan Changes (COVID-19 coverage)
- HHS and Dept. of Education Funding (available to non-public schools)
Status
- Signed into law 3/18/20
Who it applies to
- The law applies to ministries with fewer than 500 workers. Exceptions are available for employers with fewer than 50 workers.
Resources
- High-level summary
- FFCRA Update 9/14/20
- This content was published by a very reputable law firm, Ballard Spahr, LLP. Thank you to Jean Hemphill of that firm, whose work for the Church Alliance has been invaluable, for allowing us to utilize this content.
- IRS Guidance on Paid Sick Leave and Paid Family Leave Credit
- "Paid Sick and Family Leave under FFCRA" presentation by Attorney Scott Cruz of Greensfelder, Hemker & Gale, P.C.
- Department of Labor Fact Sheet for Employers
- Department of Labor Fact Sheet for Employees
- Department of Labor Q&A
- IRS Guidance
- Clarification of Paid Leave Parameters
- IRS Form 7200: Advance Payment of Employer Credits
- Instructions for IRS Form 7200
- IRS Tax Credit FAQs
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