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Families First Coronavirus Response Act (FFCRA) Key Deadlines. Early Details on CARES Act Loans.
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Date: 03/29/2020
Issue Number: 041

Families First Coronavirus Response Act (the “FFCRA”) Key Deadlines. Early Details on CARES Act Loans.


NPA Members:

This is an NPA Issue Alert: With passage of the FFCRA and CARES Act there is immediate demand for details on deadlines, qualifications, and loans. Early information received appears below. Information is sourced from multiple sources noted at the end of this alert. Special thanks to the Airport Ground Transportation Association and Dunn, DeSantis, Walt & Kendrick.

Arent Fox LLP has prepared a series of loan program summaries with rules, interest rates, and relevant information about loan programs.
 
KEY PROVISIONS of the CARES ACT
CARES Act Summary

Enhanced Unemployment Benefits Enhanced Unemployment Insurance Benefits: $600 from the federal level in addition to state benefits up to 39 weeks.

Mid-size & Larger $500 Billion Loan Program

PayCheck Protection Program Summary

Chapter 11 Restructuring Summary

CARES Act and Family Medical & Leave Act Coverage

FFRCA Employees Sick & Medical Leave Enhancement: Deadlines upcoming. This law has two pieces: 1) an expansion of the Family Medical Leave Act (FMLA); and 2) a new Federal Emergency Paid Sick Leave. Both are effective starting April 1, 2020. (See Update No. 2 for detailed information.)

Businesses with 50 or More Employees: On or before April 1, 2020, large employers (with 50 or more employees) who still have workers on the books need to start notifying employees by sending out the DOL’s model notice. A link to the DOL’s FAQ is also helpful to provide to employees. (See Update No.4 for more detailed information.)

Non-enforcement period - Although there is a grace period (March 18, 2020, to April 17, 2020) before enforcement starts, start prepping your HR department to handle employee inquiries relating to the new laws.

During the grace period, employers must have acted reasonably and in good faith to comply with the Act. This means that violations are remedied and the employee is made whole as soon as practicable by the employer, the violations were not willful, and the employer provides the DOL with a written commitment to comply with the Act in the future.

Reminder Employer Must Comply with Local Public Health Orders: The employer must continue to track and remain compliant with any applicable local public health orders. 

For example, in San Diego, amended public health orders state that employers must not require a doctor’s note from employees requesting sick leave. This continues to apply to requests for leave under the FFCRA.

Penalties for non-compliance (for example: not paying employees who take the sick leave) will be considered a failure to pay minimum wage. Such failures will expose employers to penalties under the FLSA.

We will post more information as received. Be sure to visit WeAreParking.org for the latest updates and to access free member resources, as we navigate the crisis.

With best regards,

Christine Banning, IOM, CAE
President, National Parking Association
202.296.4336
ChristineBanning@weareparking.org

Sources: U.S. Small Business Administration, U.S. Chamber of Commerce, Airport Ground Transportation Association, Dunn, DeSantis, Walt & Kendrick, Arent Fox

NPA Industry Partners

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