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FW: Federal PPP Loans

SP
Suzanne Paulson
Thu, Apr 16, 2020 3:06 PM

For what it’s worth.  I received this from a grant administrator for a small town in Oklahoma who I trust is on top of these issues.

The only one that I have total clarification on at this time is through FAA for airports.  I would encourage all airports small and large to be in touch with their contacts whether that is your FAA contact or your local OAC contact for information on these grants.  Everything else is still being worked on for guidelines as far as I know.

When I looked at DOJ or Dept. of Justice you had to have already been approved for a grant to qualify.  Unless this changes it leaves out a lot of communities.  I keep watching for any funding available of course.  AFG or Assistance to Firefighters Grants keeps teasing that there is 100 million for PPE but they haven't come across with guidelines as of yet.  Having the money is one thing but putting applications and guidelines in place can take a while.  FAA was able to do this quickly due to they offer grants on a regular basis and only had to tweak this system they currently use.

If your town has an airport, it looks like the grant info is at:  https://www.faa.gov/airports/special_programs/covid-19-airports/.

Suzie
OMAG’s COVID-19 Info Page: https://www.omag.org/covid19-faq
Suzanne D. Paulson
General Counsel
spaulson@omag.orgmailto:spaulson@omag.org

From: Robert Thompson rthompson@cheekfalcone.com
Sent: Thursday, April 16, 2020 9:49 AM
To: Suzanne Paulson spaulson@omag.org; Mat Thomas mat@mthomaslaw.net; Mark Ramsey MRamsey@soonerlaw.com
Subject: RE: [Oama] Federal PPP Loans

I believe Suzanne has identified the source of the many programs that may be of benefit to municipalities.  I have read and researched numerous documents,  in support  of clients and even my own firm,  and I do not see anywhere that political subdivisions are eligible for PPP.  Municipalities are not listed among the entities that can apply.  They just don’t meet the definition of “Business” under the act.  However,  the only way to know for sure is for a municipality to apply through a local bank and see if get approved and funded ( assuming there will be money available for funding).

Robert C. Thompson
Cheek & Falcone, PLLC
6301 Waterford Blvd., Suite 320
Oklahoma City,  Okla.  73118
direct telephone:405-286-9560
direct fax: 405-286-9680
Firm telephone: 405-286-9191
rthompson@cheekfalcone.commailto:rthompson@cheekfalcone.com

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From: Oama <oama-bounces@lists.imla.orgmailto:oama-bounces@lists.imla.org> On Behalf Of Suzanne Paulson via Oama
Sent: Thursday, April 16, 2020 9:40 AM
To: Mat Thomas <mat@mthomaslaw.netmailto:mat@mthomaslaw.net>; Mark Ramsey <MRamsey@soonerlaw.commailto:MRamsey@soonerlaw.com>
Cc: oama@lists.imla.orgmailto:oama@lists.imla.org
Subject: Re: [Oama] Federal PPP Loans

This does not answer the question about the PPP but it looks like municipalities may be eligible for some local government grant programs.  If I hear more about it I will pass it on.

  • The CARES Act authorizes a $5 billion allocation to the Community Development Block Grant (CDBG) to address COVID-19 for services to senior citizens and the homeless. Of that allocation, $2 billion would be distributed using the existing formula, $1 billion would go to states based on a formula developed by Department of Housing and Urban Development (HUD) for COVID-19 (the states will then allocate to both entitlement and non-entitlement communities), and the remaining $2 billion will go to the states and localities based on a formula to be developed by HUD within 30 days.
  • $850 million is authorized to the Department of Justice for the Byrne Justice Assistance grant program to assist state and local law enforcement and jails prevent, prepare for and respond to COVID-19.
  • $1.5 billion is authorized for the Department of Health and Human Services (HHS) for the Center for Disease Control’s (CDC) State and Local Preparedness Grants for state and local preparedness and response activities. Funds provided under this category can be used for grants for the rent, lease, purchase, acquisition, construction, alteration or renovation of non-federally owned facilities to improve preparedness and response capabilities at state and local levels.
  • $1 billion for the HHS Community Services Block Grant Program for grants to states and local community-based organizations to provide a wide range of human, social services and emergency assistance.

Suzie

OMAG’s COVID-19 Info Page: https://www.omag.org/covid19-faqhttps://nam05.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.omag.org%2Fcovid19-faq&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312136430&sdata=R1f2QNOwAGtrpbdOImd3Xyh2ci3E8EtmfT3hADRLg5c%3D&reserved=0

Suzanne D. Paulson
General Counsel
spaulson@omag.orgmailto:spaulson@omag.org

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Edmond, OK  73013
Phone: 405.657.1444
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From: Oama <oama-bounces@lists.imla.orgmailto:oama-bounces@lists.imla.org> On Behalf Of Mat Thomas
Sent: Thursday, April 16, 2020 9:32 AM
To: Mark Ramsey <MRamsey@soonerlaw.commailto:MRamsey@soonerlaw.com>
Cc: oama@lists.imla.orgmailto:oama@lists.imla.org
Subject: Re: [Oama] Federal PPP Loans

I don’t know if anything that would prevent a town. But it’s a mess. Get a good local banker that can guide you.
-mat

On Apr 16, 2020, at 09:29, Mark Ramsey <MRamsey@soonerlaw.commailto:MRamsey@soonerlaw.com> wrote:

Thanks, Mat. I’ve heard Congress is considering adding another $250 billion to the program.

From: Mat Thomas <mat@mthomaslaw.netmailto:mat@mthomaslaw.net>
Sent: Thursday, April 16, 2020 9:26 AM
To: Mark Ramsey <MRamsey@soonerlaw.commailto:MRamsey@soonerlaw.com>
Cc: oama@lists.imla.orgmailto:oama@lists.imla.org
Subject: Re: [Oama] Federal PPP Loans

If my sources are correct that money is essentially already gone. The program was terribly run and disorganized. From what I could tell if an applicant has an EIN and an employee they could apply.
-mat

On Apr 16, 2020, at 09:23, Mark Ramsey <MRamsey@soonerlaw.commailto:MRamsey@soonerlaw.com> wrote:

The Oklahoma Municipal League has a FAQ list concerning “Payroll Protection Program” loans, which is a $350 billion program which is part of the pandemic relief package passed by Congress.  Based on the information in the FAQ list, I don’t see a way for municipalities to participate in the program.  Even if they could under federal law, the Oklahoma Constitution would only allow debt for the fiscal year, which would not be much help.  The municipal beneficiary public works authority may qualify, however.

  1. Does anyone believe municipalities can participate in PPP loans?  Under what conditions?

  2. Does anyone have any experience with PPP loans for a municipal public works authority?

Thanks!

Mark H. Ramsey
For the Firm
Taylor, Foster, Mallett,
Downs, Ramsey & Russell, P.C.
P.O. Box 309
Claremore, OK 74018
918-343-4100
918-343-4900 fax
mramsey@soonerlaw.commailto:apixley@soonerlaw.com
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For what it’s worth. I received this from a grant administrator for a small town in Oklahoma who I trust is on top of these issues. The only one that I have total clarification on at this time is through FAA for airports. I would encourage all airports small and large to be in touch with their contacts whether that is your FAA contact or your local OAC contact for information on these grants. Everything else is still being worked on for guidelines as far as I know. When I looked at DOJ or Dept. of Justice you had to have already been approved for a grant to qualify. Unless this changes it leaves out a lot of communities. I keep watching for any funding available of course. AFG or Assistance to Firefighters Grants keeps teasing that there is 100 million for PPE but they haven't come across with guidelines as of yet. Having the money is one thing but putting applications and guidelines in place can take a while. FAA was able to do this quickly due to they offer grants on a regular basis and only had to tweak this system they currently use. If your town has an airport, it looks like the grant info is at: https://www.faa.gov/airports/special_programs/covid-19-airports/. Suzie OMAG’s COVID-19 Info Page: https://www.omag.org/covid19-faq Suzanne D. Paulson General Counsel spaulson@omag.org<mailto:spaulson@omag.org> From: Robert Thompson <rthompson@cheekfalcone.com> Sent: Thursday, April 16, 2020 9:49 AM To: Suzanne Paulson <spaulson@omag.org>; Mat Thomas <mat@mthomaslaw.net>; Mark Ramsey <MRamsey@soonerlaw.com> Subject: RE: [Oama] Federal PPP Loans I believe Suzanne has identified the source of the many programs that may be of benefit to municipalities. I have read and researched numerous documents, in support of clients and even my own firm, and I do not see anywhere that political subdivisions are eligible for PPP. Municipalities are not listed among the entities that can apply. They just don’t meet the definition of “Business” under the act. However, the only way to know for sure is for a municipality to apply through a local bank and see if get approved and funded ( assuming there will be money available for funding). Robert C. Thompson Cheek & Falcone, PLLC 6301 Waterford Blvd., Suite 320 Oklahoma City, Okla. 73118 direct telephone:405-286-9560 direct fax: 405-286-9680 Firm telephone: 405-286-9191 rthompson@cheekfalcone.com<mailto:rthompson@cheekfalcone.com> CONFIDENTIALITY NOTE: This e-mail and any attachments may contain confidential information that is protected by legal privilege. If you are not the intended recipient, be aware that any disclosure, copying, distribution or use of this e-mail or any attachment is prohibited. If you have received this e-mail in error, please notify us immediately by returning it to the sender and delete this copy from your system. Thank you for your cooperation. Visit us at our website http://www.cheekfalcone.com/<https://nam05.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.cheekfalcone.com%2F&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312126432&sdata=v%2F0hwXdzQ30C%2BS3w675ehD3%2FnmWhHLf6OO3nz90P9Rw%3D&reserved=0> From: Oama <oama-bounces@lists.imla.org<mailto:oama-bounces@lists.imla.org>> On Behalf Of Suzanne Paulson via Oama Sent: Thursday, April 16, 2020 9:40 AM To: Mat Thomas <mat@mthomaslaw.net<mailto:mat@mthomaslaw.net>>; Mark Ramsey <MRamsey@soonerlaw.com<mailto:MRamsey@soonerlaw.com>> Cc: oama@lists.imla.org<mailto:oama@lists.imla.org> Subject: Re: [Oama] Federal PPP Loans This does not answer the question about the PPP but it looks like municipalities may be eligible for some local government grant programs. If I hear more about it I will pass it on. * The CARES Act authorizes a $5 billion allocation to the Community Development Block Grant (CDBG) to address COVID-19 for services to senior citizens and the homeless. Of that allocation, $2 billion would be distributed using the existing formula, $1 billion would go to states based on a formula developed by Department of Housing and Urban Development (HUD) for COVID-19 (the states will then allocate to both entitlement and non-entitlement communities), and the remaining $2 billion will go to the states and localities based on a formula to be developed by HUD within 30 days. * $850 million is authorized to the Department of Justice for the Byrne Justice Assistance grant program to assist state and local law enforcement and jails prevent, prepare for and respond to COVID-19. * $1.5 billion is authorized for the Department of Health and Human Services (HHS) for the Center for Disease Control’s (CDC) State and Local Preparedness Grants for state and local preparedness and response activities. Funds provided under this category can be used for grants for the rent, lease, purchase, acquisition, construction, alteration or renovation of non-federally owned facilities to improve preparedness and response capabilities at state and local levels. * $1 billion for the HHS Community Services Block Grant Program for grants to states and local community-based organizations to provide a wide range of human, social services and emergency assistance. Suzie OMAG’s COVID-19 Info Page: https://www.omag.org/covid19-faq<https://nam05.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.omag.org%2Fcovid19-faq&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312136430&sdata=R1f2QNOwAGtrpbdOImd3Xyh2ci3E8EtmfT3hADRLg5c%3D&reserved=0> Suzanne D. Paulson General Counsel spaulson@omag.org<mailto:spaulson@omag.org> [OMAG-Logo] 3650 S. Boulevard Edmond, OK 73013 Phone: 405.657.1444 Fax: 405.657.1401 OMAG Web Site<https://nam05.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.omag.org%2F&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312136430&sdata=%2B5Fs8JM9kQscwVMtM4zXmaPletPvDY6FPQiv%2BTcsI0Y%3D&reserved=0> Follow us on: [cid:image002.png@01D613D4.01591C60]<https://nam05.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.facebook.com%2Fpages%2FOklahoma-Municipal-Assurance-Group%2F217733311740931%3Fref%3Dstream&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312146422&sdata=ok%2BgWT8j0kASUdsj8sfXTtwzLwIR92la6hMqqN1rynw%3D&reserved=0> [cid:image003.png@01D613D4.01591C60] <https://nam05.safelinks.protection.outlook.com/?url=https%3A%2F%2Ftwitter.com%2Fomag1977&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312146422&sdata=IWInCQkpFWrtCyyWnwXJNjET3YFivKIvXydYhZ%2FhKIU%3D&reserved=0> [cid:image004.png@01D613D4.01591C60] <https://nam05.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.linkedin.com%2Fcompany%2Foklahoma-municipal-assurance-group&data=02%7C01%7Cspaulson%40omag.org%7Cbd4c7e8156944934df6f08d7e21544db%7Cb13aadd514d84b918cf485be9d556ad7%7C1%7C0%7C637226453312156421&sdata=jZGeVPT5usIjiKfKgcfXtkkySv17KVwAIZXdzOsL%2BcM%3D&reserved=0> From: Oama <oama-bounces@lists.imla.org<mailto:oama-bounces@lists.imla.org>> On Behalf Of Mat Thomas Sent: Thursday, April 16, 2020 9:32 AM To: Mark Ramsey <MRamsey@soonerlaw.com<mailto:MRamsey@soonerlaw.com>> Cc: oama@lists.imla.org<mailto:oama@lists.imla.org> Subject: Re: [Oama] Federal PPP Loans I don’t know if anything that would prevent a town. But it’s a mess. Get a good local banker that can guide you. -mat On Apr 16, 2020, at 09:29, Mark Ramsey <MRamsey@soonerlaw.com<mailto:MRamsey@soonerlaw.com>> wrote:  Thanks, Mat. I’ve heard Congress is considering adding another $250 billion to the program. From: Mat Thomas <mat@mthomaslaw.net<mailto:mat@mthomaslaw.net>> Sent: Thursday, April 16, 2020 9:26 AM To: Mark Ramsey <MRamsey@soonerlaw.com<mailto:MRamsey@soonerlaw.com>> Cc: oama@lists.imla.org<mailto:oama@lists.imla.org> Subject: Re: [Oama] Federal PPP Loans If my sources are correct that money is essentially already gone. The program was terribly run and disorganized. From what I could tell if an applicant has an EIN and an employee they could apply. -mat On Apr 16, 2020, at 09:23, Mark Ramsey <MRamsey@soonerlaw.com<mailto:MRamsey@soonerlaw.com>> wrote:  The Oklahoma Municipal League has a FAQ list concerning “Payroll Protection Program” loans, which is a $350 billion program which is part of the pandemic relief package passed by Congress. Based on the information in the FAQ list, I don’t see a way for municipalities to participate in the program. Even if they could under federal law, the Oklahoma Constitution would only allow debt for the fiscal year, which would not be much help. The municipal beneficiary public works authority may qualify, however. 1. Does anyone believe municipalities can participate in PPP loans? Under what conditions? 2. Does anyone have any experience with PPP loans for a municipal public works authority? Thanks! Mark H. Ramsey For the Firm Taylor, Foster, Mallett, Downs, Ramsey & Russell, P.C. P.O. Box 309 Claremore, OK 74018 918-343-4100 918-343-4900 fax mramsey@soonerlaw.com<mailto:apixley@soonerlaw.com> The information contained in this electronic mail transmission (including any accompanying attachments) is intended solely for its authorized recipient(s), and may be confidential and/or legally privileged. If you are not an intended recipient, or responsible for delivering some or all of this transmission to an intended recipient, you have received this transmission in error and are hereby notified that you are strictly prohibited from reading, copying, printing, distributing or disclosing any of the information contained in it. In that event, please contact us immediately by telephone (918) 343-4100 or by electronic mail at postmaster@soonerlaw.com<mailto:postmaster@soonerlaw.com> and delete the original and all copies of this transmission (including any attachments) without reading or saving in any manner. 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