Stay updated on the pandemic as it relates to our industry
National REIA and our partners, like the general public, are concerned about the growing spread of COVID-19 internationally and the impact it will have here in the United States.
We continue to monitor the rapidly changing situation related to the spread of COVID-19. We understand that concerns for health, safety, and the impact on on your business, are affecting our members. National REIA is working to keep our local Chapters and associations, and their local members updated as possible on items that are important for our industry and our member’s businesses
On April 19, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule requiring “debt collectors” to provide written notice to renters of their rights under the CDC’s eviction moratorium order and prohibiting “debt collectors” from misrepresenting renters’ eligibility for protection from eviction under the moratorium. The rule will go into effect on May 3 and last through the duration of the CDC Order, which was recently extended through June 30, 2021.
To understand whether the rule applies to you, click here to read more.
COVID-19 Info for Investors
As we determine the extent of how the changes in federal policies and state and local decisions might affect our members, we will keep you informed. We have assembled a team of professionals to address our member’s business concerns. Our updates are being broadcast on Fridays at 4 p.m. These updates will be livestreamed and available for later viewing. Please check your email for the invite. If you did not receive the email please contact us at [email protected] to request call-in details.
REIA Counsel, our COO/Director of Legislative Affairs, and our partners at NAA and NMHC are helping to prepare guidance for our members in how to best operate in this environment. A document will be emailed to members and will be covered in our aforementioned virtual meetingw. We all hope the current coronavirus situation moves on quickly without more impact to public health or the economy; but if it continues, REIA will be proactive in providing resources to our membership. Stay tuned as we post and distribute updates as they are made available.
Please also note that to recognize your own legal responsibility, you need to contact your legal counsel to understand better how to limit your liability as you make modifications to your “normal” operations and communicate with your residents.
If your residents are having challenges paying rent due to unemployment, layoffs, or other COVID-19 related issues you can find information to help them find assistance here. You can also find information on your requirements as an employer and possible assistance at the same link.
You may also want to contact your tax professional as changes are being announced ongoing related to filing and paying taxes by the “normal” April 15th deadline.
Please see the instructions our partners at NAA and NMHC made available for multifamily operators below. Many apply to single-family or small to moderate-sized rental communities as well. We are currently working to explore issues that may be specific to smaller owners and are compiling a document for our use specifically.
COVID-19 Info for Associations
In light of the Federal Government’s declaration of COVID-19 as a pandemic, National REIA is issuing guidelines for the protection of the health and safety of our members. Please be aware that as you address any COVID-19 concerns, you need only to address facts and should lean upon the federal agencies and local health departments for guidance and statements of fact. This limits your liability. Please see the pdf from the CDC for guidance on COVID. https://www.cdc.gov/coronavirus/2019-ncov/downloads/fs-CERC-Infectious-Disease.pdf and https://www.cdc.gov/coronavirus/2019-ncov/about/share-facts-h.pdf
The REIA Board and Staff has cancelled all face-to-face meetings, including visiting REIAs across the country and meetings with vendors and partners. We have also issued recommendations to our groups to cancel all meetings, including all education sessions, seminars, and committee meetings in the next eight weeks resulting from the most updated CDC guidelines. https://www.cdc.gov/coronavirus/2019-ncov/community/large-events/mass-gatherings-ready-for-covid-19.html
Ultimately, public health and safety will be paramount and overrule even statutory requirements for meeting procedures. In a health crisis like COVID-19, the situation can change from day to day. REIA boards and owners should be guided by local, state, and federal authorities (such as the CDC), and association decisions should be reasonable based on that guidance. If you have not yet spoken to your county health department, call today to make contact and confirm your association will be notified if the current recommendations change. You can find the list of contact information for health departments nationwide here.
COVID-19 Small Business Resources
The U.S. Small Business Administration is offering designated states and territories low-interest federal disaster loans for working capital to small businesses suffering substantial economic injury from COVID-19. These loans may be used to pay fixed debts, payroll, accounts payable and other bills that a business cannot pay due to COVID-19. Terms are determined on a case-by-case basis, based upon each borrower’s ability to repay. Apply for an EIDL at www.sba.gov/disaster. Due to website traffic, please exercise patience. For additional information, please contact the SBA disaster assistance customer service center. Call 1-800-659-2955 (TTY: 1-800-877-8339) or e-mail [email protected]
SBA Updates Criteria on States for Requesting Disaster Assistance Loans for Small Businesses Impacted by Coronavirus (COVID-19)
Release Date: Tuesday, March 17, 2020
Release Number: 20-26
Contact: [email protected], (202) 205-7036
WASHINGTON – Today, as part of the Trump Administration’s aggressive, whole-of-government efforts to combat the Coronavirus outbreak (COVID-19) and minimize economic disruption to the nation’s 30 million small businesses, U.S. Small Business Administration Administrator Jovita Carranza issued revised criteria for states or territories seeking an economic injury declaration related to Coronavirus (COVID-19).
The relaxed criteria will have two immediate impacts:
- Faster, Easier Qualification Process for States Seeking SBA Disaster Assistance. Historically, the SBA has required that any state or territory impacted by disaster provide documentation certifying that at least five small businesses have suffered substantial economic injury as a result of a disaster, with at least one business located in each declared county/parish. Under the just-released, revised criteria, states or territories are only required to certify that at least five small businesses within the state/territory have suffered substantial economic injury, regardless of where those businesses are located.
- Expanded, Statewide Access to SBA Disaster Assistance Loans for Small Businesses. SBA disaster assistance loans are typically only available to small businesses within counties identified as disaster areas by a Governor. Under the revised criteria issued today, disaster assistance loans will be available statewide following an economic injury declaration. This will apply to current and future disaster assistance declarations related to Coronavirus.
“We’re very encouraged that banks and financial institutions are responding to the President’s efforts to mobilize an unprecedented public-private response to the Coronavirus (COVID-19) outbreak. As a result, most small businesses that need credit during these uncertain times will be able to obtain it. However, our goal is to ensure that credit is available to any and all small businesses that need credit but are unable to access it on reasonable terms through traditional lending channels,” said Administrator Carranza. “To that end, the SBA is relaxing the criteria through which states or territories may formally request an economic injury declaration, effective immediately. Furthermore, once an economic injury declaration has been made in a state or territory, the new rules allow the affected small businesses within the state or territory to apply for a disaster assistance loan.”
SBA’s Economic Injury Disaster Loans offer up to $2 million in assistance for each affected small business. These loans can provide vital economic support to small businesses to help overcome the temporary loss of revenue they are experiencing.
Process for Accessing SBA’s Coronavirus (COVID-19) Disaster Relief Lending
- The U.S. Small Business Administration is offering designated states and territories low-interest federal disaster loans for working capital to small businesses suffering substantial economic injury as a result of the Coronavirus (COVID-19). Upon a request received from a state’s or territory’s Governor, SBA will issue under its own authority, as provided by the Coronavirus Preparedness and Response Supplemental Appropriations Act that was recently signed by the President, an Economic Injury Disaster Loan declaration.
- Any such Economic Injury Disaster Loan assistance declaration issued by the SBA makes loans available statewide to small businesses and private, non-profit organizations to help alleviate economic injury caused by the Coronavirus (COVID-19).
- SBA’s Office of Disaster Assistance will coordinate with the state’s or territory’s Governor to submit the request for Economic Injury Disaster Loan assistance.
- Once a declaration is made, the information on the application process for Economic Injury Disaster Loan assistance will be made available to affected small businesses within the state.
- These loans may be used to pay fixed debts, payroll, accounts payable and other bills that can’t be paid because of the disaster’s impact. The interest rate is 3.75% for small businesses. The interest rate for non-profits is 2.75%.
- SBA offers loans with long-term repayments in order to keep payments affordable, up to a maximum of 30 years. Terms are determined on a case-by-case basis, based upon each borrower’s ability to repay.
- SBA’s Economic Injury Disaster Loans are just one piece of the expanded focus of the federal government’s coordinated response, and the SBA is strongly committed to providing the most effective and customer-focused response possible.
Businesses impacted by the current public health crisis can find details about the SBA Economic Injury Disaster Loan Program is available at SBA.gov/Disaster.
SBA and Treasury Release Paycheck Protection Program Loan Forgiveness Application
The form and instructions inform borrowers on how to apply for PPP loan forgiveness, consistent with the CARES Act. SBA will soon issue regulations and guidance to further assist borrowers as they complete their applications, and to provide lenders with guidance on their responsibilities. Click here to read more.
The U.S. Department of the Treasury and U.S. Small Business Administration released new information regarding the Paycheck Protection Program:
- Interim Final Rule on Eligibility of Certain Electric Cooperatives
- SBA launched a new search functionality within the E-Tran Servicing section of the Capital Access Financial System (CAFS). This tool will help PPP lenders review loans in their portfolios. Lenders should review all fields in these files for accuracy and completeness.
- Please complete your review and make necessary changes no later than 5 PM EDT on Friday, May 15, 2020. Click here for instructions on how to access CAFS and update records in “Research” status.
Assistance for Small Businesses
The Paycheck Protection Program is providing small businesses with the resources they need to maintain their payroll, hire back employees who may have been laid off, and cover applicable overhead.
- Top-line Overview of PPP
- SBA Paycheck Protection Program Loan Report
- SBA Paycheck Protection Program Loan Report Round 2 – Updated 5/3
- Summary of Paycheck Protection Program Round 2 Data – Updated 5/14
- More information
- Search Tool: Find an Eligible Lender
- Borrower Application Form
- Applicable Affiliation Rules
- How to Calculate Loan Amounts
- More information
- Lender Application Form
- Lender Application Form for Federally Insured Depository Institutions, Federally Insured Credit Unions, and Farm Credit System Institutions
- Lender Application Form for Non-Bank and Non-Insured Depository Institution Lenders
- Lender Assistance Hotline: (833) 572-0502
- Frequently Asked Questions – Updated 5/13
- Interim Final Rule 1
- Interim Final Rule on Applicable Affiliation Rules
- Interim Final Rule on Additional Eligibility Criteria and Requirements for Certain Pledges of Loans
- Interim Final Rule on Requirements for Promissory Notes, Authorizations, Affiliation, and Eligibility
- Interim Final Rule on Additional Criterion for Seasonal Employers
- Interim Final Rule on Disbursements
- Interim Final Rule on Corporate Groups and Non-Bank and Non-Insured Depository Institution Lenders
- Interim Final Rule on Nondiscrimination and Additional Eligibility Criteria – Updated 5/5
- Interim Final Rule on Loan Increases – Updated 5/13
- Interim Final Rule on Eligibility of Certain Electric Cooperatives – Updated 5/14