In late December, Congress passed Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, establishing parameters for expanding the Paycheck Protection Program to reopen it for initial loans and also to allow a second draw of funds.
If an employer did not receive PPP funding during the first round of loans, they may review the program here, and apply for an initial loan through a participating financial institution, using the SBA application.
The new Second Draw program is described here. Employers are eligible for a second draw if:
- they received a PPP loan and demonstrated (or will demonstrate) that they used the full amount of their first loan for forgiveable expenses,
- their “gross receipts” during any quarter of 2020 was reduced by at least 25% when compared to the same quarter of 2019, and
- they have ongoing concerns about the economic impact of the pandemic on their operations.
The amount available is based on the average monthly payroll during either 2019 or 2020, again excluding any individual compensation that exceeds $100,000.
“Gross receipts” are defined by IRS definitions. Remember that for a non-profit organization, external financial reports are expected to be prepared using an accrual basis. This means that gross receipts:
- includes all receipts — contributions, restricted contributions, fundraising, preschool tuition, etc. — without subtracting any expenses;
- excludes forgiven PPP loan amounts;
- excludes deferred revenue such as payments for a wedding next summer or building use prepaid for January, including such payments in the quarter that the services were provided;
- includes contributions in the year they are for — that is, excludes pre-paid pledge contributions for future years and includes contributions paid for the prior year that are received after the end of the year; and
- excludes capital and investment gains or losses, but includes interest and dividends.
To calculate payroll,
- begin with all gross pay,
- include pastor’s housing and SECA allowances,
- exclude National Paid Leave (FFCRA), and
- exclude amounts in excess of $100,000 per employee.
The Second Draw application is available here: Second Draw PPP application, and is submitted through a participating financial institution.