More Info on Paycheck Protection Program

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.



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


COVID-19 Update March 31

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.


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.

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CARES Act Loans – A bit more detail

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


Wage and Hour Division FFCRA Poster Issued

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.

Department of Labor Issues New Guidance on FFCRA

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.

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Gins And the Coronavirus Pandemic

Well this is an unprecedented situation we face. I can’t remember anything quite like this. We’ve received a few calls and emails asking some very good questions as we move into the second full week of the screeching halt that has become life in the US.

One of the most important things to remember is that given the current circumstances, it appears that the virus will work its way through society over time. Over how much time seems to be one of the most pressing questions. Without some significant changes, it’s not a matter of if but when someone you know will be affected by the virus. The outcomes in all but a few cases are good. The vast majority of people do get better. What I have read today is that most will get better in a few days just treating the symptoms. Some will require a hospital stay and that could be a significant time away from work even if the hospital stay is short. The idea is to keep the wave of patients to the hospitals below their capacity.

All of the things that we have seen implemented have been to reduce the impact to the medical community and ultimately to humanity. So what does that mean for you the cotton ginner? The first thing it means it to make sure anyone who is symptomatic to stay at home. It also means following the CDC guidelines and using common sense. Keeping distance, implementing increased hand washing and use of sanitizers and PPE where washing and distancing are not as practical. Keeping gatherings to a minimum or eliminate them altogether.

A really good place to start is the CDC. Follow their Guidelines for employers. Another source of information for employers is OSHA. OSHA put out Guidelines for employers last week at This has been updated and will continue to be as this evolves. We work closely with Fisher and Phillips who are a nationwide law firm. They have started a COVID-19 response team of lawyers on how employers can prepare and help themselves moving through this. Please go to their page on the COVID response. It is also continually updated as they see necessary. All these pages should be checked often.

As far as government response. Of course, you need to follow the guidelines in your local area. We’ve seen and will continue to see stronger response in some areas over others. Congress has passed one bill and will pass more to help alleviate the impact on employers and employees. Please refer to THIS SUMMARY of the first bill. It provides for up to 80 hours of paid sick leave and expands job protections for employees to all businesses. Please refer to the Summary for more details. President Trump just today said there will be relief for small businesses along with bailouts for airlines and cruise industries but no details were given.

This is a very VERY VERY fluid situation. In just over a week we went from a handful of cases to thousands and whole cities being put on lock down with highly restrictive travel. We’re monitoring the situation and please let us know if we can help.

PS: Keller and Heckman put out info on Insurance and the Coronovirus