The Christian Law Association has been receiving hundreds of contacts each day regarding the applicability of certain provisions from the CARES Act to their ministry. We have been working with key congressional personnel about these important elements.
We strongly recommend each ministry to proceed with EXTREME CAUTION before accepting government funding. Your ministry’s religious liberty may depend on this caution.
- THE CURRENT LAW CONTAINS NO EXPRESS GUARANTEE THAT THE LOANS WILL BE FORGIVEN BY THE GOVERNMENT.
- Banks still do not know all of the rules and regulations the government will be placing on a ministry’s acceptance of the government funding because they have not yet been written.
- Our CLA attorneys, and other experts, anticipate that the rules and regulations could remove long-recognized exemptions available to churches in their hiring practices and in the provision of their services to those who attend.
- Ministry officials must also be very diligent, if they have furloughed staff because of the state stay-at-home mandates, that they do not allow the furloughed staff to continue to carry out their normal job responsibilities.
- Lawsuits that we have prevailed in for fifty years have often been won because the ministry never received government funds as a matter of faith and principle.
- The receipt of these funds by a ministry is clearly the receipt of government funds, and they could be used against the interests of the ministry in future litigation.
Our attorneys are diligently analyzing these guidelines and regulations as they are released, and we will be providing more information as it becomes available. Until that time, we must advise every ministry to be cautious. Accepting the government money could jeopardize ministry protections.
If any group or person is encouraging you to proceed with this program without carefully advising you about these limitations and potential consequences, please be extremely careful. The fact that you or your ministry took government money without fully understanding the ramification of these consequences will not excuse you from the consequences.
The Christian Law Association is diligently discussing this program with key congressional personnel to clarify the impact of potential rules to the ministries, but that wording has not yet been put into law. As we continue discussions, we will be sending more clarification.