The SBA has updated their cronoavirus assistance page. That has shed more light on the Paycheck protection program. Additionally the Treasury Department has issued some additional guidance on the program as well. We recommend you visit this website often and poke around. The links on SBA’s site have changed often and don’t always take you where you think you need to go. I’m sure they are overwhelmed at this point as well. Some of the best information can be found on the Treasury website linked below as well.

The program total availability is $349 Billion. It appears this will be used for the payroll portion of the loans. According to the Treasury guidance linked below, it is expected that although the loans can be for 2 months of Rent, Utilities, and Mortgage Interest as well as Payroll, only 25% of non-payroll portion of the loan will be forgiven while all of the payroll expenses will be. This is an estimate by Commerce so that it will use the $349 Billion for paychecks. The rest can be paid back over a two year period with no pre-payment penalty.

The small business applications can begin processing as early as tomorrow April 3. We recommend if you are anticipating using one of these loans, to work with your lender TODAY. Additionally the National Cotton Council has posted a summary page with a number of assistance programs.

TREASURY PAGE ON PPP FOR SMALL BUSINESS

SBA PAGE ON SMALL BUSINESS ASSISTANCE PROGRAMS

NCC COVID-19 ASSISTANCE PAGE (Requires NCC Member Password)

DSF

This could be a long post so buckle up. There are several things that need to be consolidated into one place and I will attempt to do that here.

As of this writing there have been three phases of assistance that has been put together by the Federal Government to help businesses get through the uncertainty of the COVID-19 emergency. The three were the original declaration and availability of some SBA loans. The second was the Families First Coronavirus Relief Act (FFCRA) and the third is the recently passed Coronavirus Aid, Relief and Economic Security Act (CARES). The latter two of these have some things that most gins will need to pay attention to. Additionally, we intend to explore the ability for gins to stay open and gin workers to travel to and from work each day even under a shelter-in-place or stay-at-home order.

FFCRA

Under the FFCRA, there were two pieces that have been covered in this blog but there have been some slight clarifications. Under the Emergency Sick Leave provisions employees can take up to two weeks off paid by the employer for a number of reasons. Those reasons are explained on the Department of Labor’s Wage and Hour page that can be found here. One confusing piece of that is reason #1 on the list. It states that the individual Is subject to a Federal, State, or local quarantine or isolation order related to COVID-19. This does not mean that the business shut down due to a shelter in place order but that the EMPLOYEE cannot leave their home for any reason because of a lock-down quarantine as we’ve seen on a very limited basis. Under the Emergency Family and Medical Leave Act provisions of the FFCRA, an employee can take an additional 10 weeks (total of 12) off if they have to take care of a child due to a coronavirus related school or daycare closing.

So the Coronavirus Aid, Relief and Economic Security Act (CARES act) has passed the House and Senate and President Trump signed it not long later. There are a lot of people that have done analyses of the provisions of the bill and this is not intended to replace or supplant any of those.

The one provision in this bill that may be helpful to many of our members is the addition of two loan programs intended to help small businesses. The bill made changes to the Economic Injury Disaster Loan program. I believe it increases the borrowing ability and made some other guarantee changes.

Another provision is the addition of a Paycheck Protection Program. This is a guarantee program up to 2Million dollars that will allow borrowers to pay rent, payroll and other expenses for two months and have that portion of the loan forgiven. The way I understand it (rumors mostly) the borrower could get the loan based on estimate of the expenses. At the end of the 2 months, pay back any excess borrowed and the amount used for those expenses would be forgiven. There are a number of qualifications and restrictions.

One of the better sources I’ve seen so far is a Baker Donelson analysis found HERE. They break these loan programs down in pretty good detail. Please work with your banker and accountant to see which of these programs will work for you but I would recommend not ignoring these as it could mean free money for a few months.

Baker Donelson Analysis

SBA Coronavirus Loan Page

DSF

As a follow-up to yesterday’s article, the Department of Labor (DoL) Wage and Hour division (WHD) has issued the poster referenced in the article. You can download the poster HERE.

In addition to the poster, the WHD has developed a web page with a lot of Questions and Answers regarding the requirements and benefits under this act. That web page can be found HERE and contains a lot more information than we had available yesterday. I recommend reviewing this web page as well as downloading and posting the poster as required.

Give us a call or email us if you have any questions.

The Department of Labor Wage and Hour Division (DoL) has issued guidance on how to prepare and respond to the Families First Coronavirus Response Act (FFCRA). Specifically the DoL’s guidance deals with the two main components that will affect both employers and employees when it goes into effect on April 1, 2020. Those components are the expanded Family and Medical Leave Act (FMLA) and the Emergency Paid-Leave program. Both can have an effect on every gin.

The Paid Sick Leave component requires all employers provide two weeks (up to 80 hrs) of paid leave for employees that are quarantined because of a Federal, State or Local order or advice of health care professional. This employee would be paid at their full rate for the two weeks. If the employee must miss work to take care of an individual that is under quarantine or if they must take care of a child that is out of school or cannot find day-care due to Coronavirus issues, that employee would be paid at 2/3 regular rate of pay for the two weeks.