If you are going to accept these government funds for your ministry, CLA urges ministries to proceed with prayerful caution and extreme diligence before accepting government funding available under this legislation.
- The specifics concerning Congressional oversight on the use of funds provided through the CARES Act (as announced by Speaker Pelosi) have yet to be presented and explained. The SBA has stated that they will be providing rules of oversight and investigation which would apply to any ministry that applies for and receives funds.
- These investigations and oversight can provide for both criminal and civil liability. Remember, the government has the right to review your books and procedures under these programs, long after this program is over.
- The financial benefits from this legislation are unquestionably a form of government funding. If a ministry holds a religious belief against the receipt of government funds to finance their ministry, that should preclude taking part in these programs.
- The SBA has clearly stated: “Receipt of a loan through any SBA program constitutes Federal financial assistance and carries with it the application of certain nondiscrimination obligations. Any legal obligations that you incur through your receipt of this loan are not permanent, and once the loan is paid or forgiven, those nondiscrimination obligations will no longer apply.”
- If you elect to receive government funds, our advice is to not keep these funds in your general accounts, but place them in special accounts where you can meticulously self-audit how every penny is used. Remember, the government has the right to review your books and procedures under these programs, long after this program is over.
- Please continue to remember the Christian Law Association in prayer. Thankfully, by the determination of Christian legislators we are working with, as well as the relationships of key pastors with their legislators, and most importantly by the grace of God, we have seen a significant impact to this point. SBA released guidelines that addressed many of the Constitutional issues we proposed but there is still significant work to be done.
The Christian Law Association is continually in discussions regarding this program with Congressional Leadership to clarify the impact of potential rules to the ministries and will provide updates as they become available. If you have any questions or matters we can clarify, please contact the Christian Law Association (888-252-1969) (Info@christianlaw.org).
Please continue to pray for us as we are helping churches with these unprecedented events. The Christian Law Association is a faith-based ministry and does not charge for their legal assistance.