SBA publishes FAQ for grants to tiered site operators
A set of frequently asked questions released by the US Small Business Administration does not specify a start date for the new Subsidy for shutter room operators (SVOG) but recommends actions that potential applications should take while the SBA builds the application platform.
The $ 15 billion SVOG was created by The Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act, PL 116-260, the COVID-19 relief bill that was enacted in late December and also revived the Paycheck Protection Program (PPP).
The relaunched PPP, also administered by the SBA, began accepting applications on January 11, but no start date has been announced for the Shuttered Venue program, which will provide eligible applicants with grants equal to 45% of their earnings. gross earned, up to a maximum of $ 10 million.
What Site Operators Should Do Now
In the Faq on shuttered sites, released Jan. 29, the SBA says “works fast” to open the program’s application window, and potential applications should frequently visit www.sba.gov/coronavirusrelief for updates. In the meantime, the SBA said, potential SVOG applicants should take steps to prepare as the SBA works to create the application platform for the program.
Specifically, entities are encouraged to get a Dun & Bradstreet (DUNS) so that they can then enroll in the Rewards Management System (SAM.gov). Other identifiers, such as an individual tax identification number or an employer identification number, cannot be used.
Entities that have or receive a DUNS number should immediately begin registering on SAM.gov, as SAM registration can take up to two weeks after submission.
In addition, the SBA recommends that potential applicants gather documents showing the number of employees and their monthly income so that they can calculate the average number of eligible employees that the entity has had in the previous 12 months. The FAQs provide tips on how to determine the number of employees on page 6.
SVOG applicants will also need to determine and document the extent of the loss of gross earned income experienced in 2020 compared to 2019. The FAQs provide details on how to calculate income on pages 6-7. Other information required includes floor plans, copies of contracts and other evidence.
Entities eligible for a SVOG, in accordance with the Law on Economic Aid, may be operators or promoters of performance venues, theater producers, operators of performing arts organizations, museum operators, cinema operators and talent representatives. The FAQs add that entities of these types owned by state or local governments are eligible if the government-owned entity acts only as a site operator, such as for a museum or historic house, and does not also manage other types of entities. For example, a city parks and recreation department that operates a bandstand in a public square but also manages several nature parks would not be eligible to apply for an SVOG.
Additionally, applicants for SVOG grants must meet the following eligibility requirements.
- Must have been in service on February 29, 2020.
- Must not have a pending application for a PPP loan. If the entity has requested a first or second draw PPP loan on or after December 27, 2020, it cannot apply for an SVOG until its PPP loan request is declined. Entities cannot apply for a PPP loan and SVOG at the same time. However, an entity that applied for and received a PPP loan during the first iteration of the PPP last year is eligible to apply for a SVOG.
- Must have defined representation and audience spaces with fixed seats (which are defined as seats permanently attached to the floor or floor.) Economic Aid Law does not allow temporary, removable seating arrangements , modular, convertible or others. This means that mobile entities such as a circus, fair, or business that provide talent for events such as weddings are not eligible for a Shuttered Venue grant if they do not meet the space requirements of the venue. representation and fixed seats.
- External sites can apply for a SVOG if they are otherwise eligible under the rules of their entity type. For example, a drive-in cinema without fixed seats does not meet the requirement that a cinema operator must have at least one auditorium with a cinema screen and fixed seats for the audience.
A site operator is not eligible for an SVOG if any of the following conditions apply.
- He received a PPP loan on or after December 27, 2020.
- It is a publicly traded company, or is majority owned and controlled by a publicly traded company.
- He presents live performances or sells products or services of a lascivious sexual nature.
- Over 10% of its gross revenues in 2019 came from the federal government (not counting disaster assistance).
- It owns or operates halls, theaters, museums or artistic agencies in more than one country; owns or operates venues, theaters, museums or arts agencies in more than 10 states; AND it had over 500 employees as of February 29, 2020.
Additional more specific questions on the eligibility of entities are dealt with on pages 3 and 4 of the Faq.
AICPA experts discuss the latest news on P3s and other small business assistance programs at a virtual town hall held most weeks Thursday at 3 p.m. ET. The webcasts, which offer CIP credits, are free to AICPA members. Go to AICPA Town Hall Series web page for more information and to register.
the AICPA Paycheck Protection Program Resource Page houses resources and tools produced by the AICPA to help cope with the economic impact of the coronavirus.
Accounting firms can prepare and process PPP applications on the CPA business financing portal, created by AICPA, CPA.com and fintech partner Biz2Credit.
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– Jeff drew ([email protected]) is a JofA senior editor.