Prayers of Health and Safety to all of you and your communities! Blue Stone Strategy Group has been following the Stimulus funding that is being provided by the US Govt. to Tribes. The SBA Payroll Protection Program Loan was previously not available to Casinos, but with the new funding legislation passed this week the language has been changed to include Gaming Operations! The original guidance suggested that most tribal gaming operations would be ineligible to participate in the program if these businesses derived over 50% of their revenues from gaming. Tribes and states with legal gaming enterprises worked hard to oppose this limited and arbitrary criteria for inclusion within the program.
The Small Business Administration (SBA) published interim final regulatory guidelines today including a change to their guidance regarding the Paycheck Protection Program (PPP) that would make most Tribal Gaming Operations eligible for the program! The new interim final rule removes the criteria and states that “a business that is otherwise eligible for a PPP Loan is not rendered ineligible due to its receipt of legal gaming revenues, and 13 CFR 120.110(g) is inapplicable to PPP loans.”
The PPP is a loan program within the CARES Act that allows businesses with fewer than 500 employees to apply for loans to cover payroll and other operational expenses that have been disrupted due to the COVID-19 pandemic. The PPP is a stop gap loan to fund keeping employees hired, it is basically based on average monthly cost of staffing and is funded based on that amount for X 2.5 Months. This loan is 100% forgivable if the awardee ensures that the funds were used for their intended purposes over the determined covered period. Blue Stone recommends that you immediately reach out to your banks and ask for their support in getting the PPP Loan Application submitted. We are available to discuss further and can send out more background on the program parameters if you would like.
Interim Final regulatory guidelines
The CARES Act: Sec. 1102 – Paycheck Protection Program
SBA Site: The Paycheck Protection Program
Paycheck Protection Program FAQ (4/23/20)