As the second draw of Paycheck Protection Program (PPP2) funding opens to businesses still struggling from the crippling economic effects of the COVID-19 pandemic, the eligibility for not-for-profits to participate in the program has changed. Previously, under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, only not-for-profit organizations identifying as 501(c)(3) and (19) with no more than 500 employees, were eligible to participate. With the signing of the Consolidated Appropriations Act of 2021, not-for-profits categorized as 501(c)(6) organizations will now be eligible to receive PPP2 funding through March 31, 2021.
In order to be considered for PPP2 funding, the 501(c)(6) organization:
- Must be in operation as of February 15, 2020
- Must not employ more than 300 employees
- Must not receive more than 15% of receipts from lobbying
- Lobbying activities must not comprise more than 15% of the not-for-profit’s total activities
- Lobbying activities did not exceed $1,000,000 during the most recent tax year that ended prior to February 15, 2020
While this is great news for 501(c)(6) organizations, more guidance is needed. We are committed to providing you with information and resources needed to make informed decisions. We will continue to update this article with new information as it becomes available.