Coronavirus Policy Comment Letters
The Real Estate Roundtable's 8-Point Plan to Reform the PPP
View Letter (Congressional Leadership)
View Letter (Treasury & SBA)
On April 8, The Real Estate Roundtable submitted their 8-Point Plain to Reform the Payroll Protection Program (PPP) to Congressional Leadership, Treasury Secretary Mnuchin and Small Business Administrator Carranza.
The Roundtable fully supports the intent of the Payroll Protection Program (PPP) in the CARES Act, and the efforts to interpret and implement the program under unprecedented time constraints. The Roundtable shares your goals to get PPP funds to struggling individuals, families and businesses as soon as possible. However, it is our strong view that the PPP platform needs to be clarified and in some aspects improved to provide the much needed protections for U.S. workers and the businesses that employ them.
1. Expressly Waive SBA’s Business “Ineligibility” Rule Governing its “Regular” Loan Programs, to Give Real Estate and Other Industries Clarity on Their PPP Eligibility.
2. LLPs and LLCs as Duly Formed and Recognized Under State Law Should be Their Own Entity Eligible for PPP Loans.
3. Congress Waived the SBA “Affiliation Rules” Only for Restaurants and Hotels. It Should Not Pick Industry “Winners and Losers,” and Should Waive the Affiliation Rules for All Industries.
4. Loan Amounts Should be Calculated Relative to Business “Operating Expenses” — Not Only “Payroll Expenses.”
5. SBA and Treasury Should Not Restrict PPP Loans and Forgiven Amounts with a “One Size Fits All” Rule that Limits Coverage for Rent and Other Business Expenses.
6. Property Owners Should Have Flexibility to Work with Their 3rd-Party Management Companies in Counting Workers for the “500-Employee” Threshold.
7. Businesses Should Have Flexibility to Not Count Part-Time Employees in the “500 Cap” – Because if the Cap is Exceeded None of Its Employees Get Payroll Protection.
8. Multifamily Building Owners Should be Eligible for PPP Loans to Help Cover Mortgage Principal — During the CARES Act Period that Tenants Are Protected from Evictions.
We urge Congress and the Administration’s agencies to enact these improvements as swiftly as possible.