Vol. XIX, Issue 29

May 21, 2020

CARES Act Update—PPP and Paying CRSP-DB and Pre-82 Contributions Early

Related to Paycheck Protection Program (PPP) loans under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), United Methodist Church annual conference officers have asked Wespath about paying Clergy Retirement Security Program (CRSP) defined benefit (DB) contributions and Pre-82 Plan contributions earlier than the end of the year for certain clergy, e.g., clergy included in annual conference payroll. Wespath will accept early payment of CRSP-DB and Pre-82 contributions (full or partial contributions) to assist plan sponsors in using PPP funds for forgivable payroll costs. Wespath is working on a process to provide CRSP plan sponsors with confirmation documentation for such contributions, to assist plan sponsors who are PPP borrowers in supplying their lender with documentation related to PPP Loan Forgiveness Applications. Preliminary loan forgiveness details were described in the May 19, 2020 On Board Express.

Confirmation documentation from Wespath would include information such as:

Please note: As administrator and recordkeeper for the UMC retirement plans, Wespath will assist plan sponsors who are PPP borrowers as we are able; however, Wespath cannot 1) determine what costs or what portions of defined benefit plan contributions are forgivable payroll costs under the PPP, nor 2) represent that any amounts are forgivable.

Plan sponsors should contact their Plan Sponsor Manager at Wespath to arrange for such payments.

Wespath is collaborating with the General Council on Finance and Administration (GCFA) to create a UMC guide to the PPP Loan Forgiveness Application, which should be available soon. Still, some open questions about forgiveness remain, which may only be clarified through additional regulatory guidance from the Treasury Department (Treasury) and Small Business Administration (SBA).

CARES Act Update—Congress Contemplating PPP Modifications

On May 20, 2020, the House of Representatives introduced HR 6886, the Paycheck Protection Program Flexibility Act of 2020. The bipartisan bill is intended to address some of the most common concerns about the Paycheck Protection Program (PPP), which was part of the CARES Act. The House is expected to vote on the bill next week under its new remote-vote-by-proxy mechanism. If approved by the House, the fate of the bill in the Senate is less clear. The Senate is scheduled to be in recess next week, so the earliest action in the Senate is likely to be after Senators return. Rarely do stand-alone bills like this move quickly through both houses of Congress. However, last week the Senate introduced its own bill to amend the PPP. Moreover, the President and Treasury Secretary have expressed interest in fixing perceived concerns with the PPP to meet the needs of businesses.

If enacted, HR 6886 would:

If H.R. 6886 becomes law, these changes would be effective as though enacted on the date CARES was enacted (March 27, 2020) and would apply to all PPP loans issued, past or future.

Wespath continues to monitor guidance and developments related to the CARES Act. Please direct any questions you may have to Tony Prestipino, Andy Hendren, Steve Clark or Jim O'Connell.

Weekly Updates to Participants

This week's participant e-blast communication was sent yesterday, May 20. It highlights how using social media could create security risks and shares ways to protect your private information in public forums. It also announces an enhancement of Benefits Access thatís coming in June. Click here to view the full email. Participants who intend to retire in July received a different version of the e-blast that also included information about an upcoming Retirement Webinar and reasons to consider keeping their retirement investments at Wespath even after they retire.

Wespath Holiday Closing—Memorial Day

Wespath will be closed on Monday, May 25, in observance of Memorial Day. Customer Service assistance will be unavailable that day.

Benefits Access for participants can be used to access account information and complete transactions 24 hours a day, seven days a week. The automated phone system, accessible by calling 1-800-851-2201, will also be available for participants.

The Benefits Access Portal for Plan Sponsors and Wespath Institutional Investor Portal will be available to plan sponsors, conferences and institutions.

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