Dear John,

On Tuesday, the DC Circuit denied our appeal and upheld the lower court’s opinion that the Paycheck Protection Program ([link removed]) is a government subsidy and not a loan. This means that the existing SBA rules that exclude businesses that derive more than 50% of their revenues from “political and lobbying activity” are still in effect.

However, many AAPC members who do political work have a variety of income streams or offer services that will enable them to still qualify. Given the SBA’s limited guidance on who is eligible and who is not for PPP loans, this is a highly individualized determination. If you are interested in taking advantage of PPP, we encourage you to consult with your own counsel and your lenders to determine your eligibility before the program is set to expire on June 30^th.

Though we may not have gotten the result we wanted this time, the fight for fair treatment of our member firms was worth it. Stay well, friends…

Rose Kapolczynski
AAPC President

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