Updated June 8, 2020
PPP borrowers should: (1) keep up with new guidance at treasury.gov
; (2) confirm and reinforce the organization’s religious identity for legal purposes; and (3) communicate with the board regarding the use of the loan funds. In addition to tracking expenditures and implementing procedures to comply with the loan certifications and SBA regulations, PPP borrowers should also keep up with new SBA guidance. Because the PPP was implemented very rapidly, the SBA and Department of Treasury
have been issuing clarifying guidance on a rolling basis to address problems and clear up confusion. For example, the PPP FAQ document
is updated several times each week. To keep key leaders up to date, the organization should designate an individual responsible for tracking updates to the administration of the loan programs. Organizations also should review their corporate documents, employee handbook, and other documentation to evaluate whether the organization’s religious identity is clearly articulated and to take any necessary steps to update those documents as appropriate. Our friends at ADF have compiled a helpful religious liberty checklist
that organizations can use to self-assess the extent to which they are following best practices for religious organizations. Finally, during the loan period, the board should be updated regularly on the use of the loan funds and relevant updates. This could be done through a meeting or via email summaries. As always, if a meeting is held, written minutes should be developed and kept in the corporate records.