ASAE has asked the Administration for swift guidance implementing the year-end COVID-19 stimulus law that will enable as many deserving 501(c)(6) organizations as possible to access relief programs such as the Paycheck Protection Program (PPP).
In a Dec. 22 letter to Treasury Secretary Steven Mnuchin and SBA Administrator Jovita Carranza, ASAE President and CEO Susan Robertson said the year-end bill will provide long-awaited relief for many 501(c)(6) associations but regulatory guidance should clearly define 501(c)(6) “lobbying receipts” as revenue generated by the nonprofit for the express purpose of financing lobbying activities; define “lobbying activities” under the same parameters set by the Lobbying Disclosure Act; and clarify that the timeframe for PPP qualifying conditions should be the most recent tax year that ended prior to February 15, 2020.
“These necessary steps will help direct essential relief to deserving 501(c)(6) organizations that exist to support every industry and serve as a foundational instrument of American economy, society and democracy,” ASAE’s Robertson said.
SBA’s only guidance for PPP applicants so far has been to state that the agency will “allow lenders to rely on certifications of the borrower in order to determine eligibility of the borrower and use of loan proceeds and to rely on specified documents provided by the borrower to determine qualifying loan amount and eligibility for loan forgiveness.” ASAE is awaiting more information from SBA specific to the qualifying conditions for 501(c)(6) eligibility.
Read ASAE’s issue brief for more information on the COVID-19 relief package passed by Congress last month.