General
USCCB Letter to the SBA Commenting on SBA Interim Final Rules (2020)
Comments on SBA Interim Final Rules (April 21, 2020)
On behalf of the United States Conference of Catholic Bishops, we submit the following comments on two interim final rules issued by the Small Business Administration on the paycheck protection program (PPP) and published on April 15, 2020. 85 Fed. Reg. 20811 (IFR); 85 Fed. Reg. 20817 (Supplemental IFR).
We are grateful to the SBA for the guidance that the two rules provide on the loan eligibility of nonprofit organizations. We are especially grateful for the SBA’s recognition of the unique circumstances of faith-based organizations (FBOs) and the constitutional, statutory, and regulatory protections for religious liberty that apply to them.
We therefore urge the SBA to clarify that loans received by FBOs under the CARES Act do not subject them to the federal requirements ordinarily associated with the receipt of federal funds, including requirements imposed by SBA’s own pre-existing regulations. The current circumstances are undeniably unique. Those circumstances demand a unique and decisive response from the SBA so that nonprofit organizations that need continued funding to meet their payroll will not be impeded by unrelated obligations that Congress neither contemplated nor intended.