April 9, 2020

Government Relations Daily Summary

The following are informational items that may impact your respective practice areas. The COVID-19 has significantly changed all of our business practices.  Government and private sector enterprises continue to respond to the crisis and to maintain a sense of continuity of operations. It is our intent with the Government Relations Daily Summary to keep you informed of developing guidance and pronouncements that may impact your practice and your clients.  


Department of Employment Security
Agency Suspends Late Wage Report Filing Fee
The Illinois Department of Employment Security announced that employers will not face a penalty fee for filing their February 2020 wage reports late. Wage reports are filed by employers and businesses on a monthly basis and document the number of workers and the wages each worker is paid during that month.  Employers are still encouraged to file their February 2020 wage reports, which were due to IDES on March 31, 2020 as soon as possible.  IDES Waiver Announcement
Governor’s Office of Management and Budget
GATA Due Dates
The Governor’s Office of Management and Budget (GOMB) has adopted the automatic six-month extension, including the requirement for documentation of the reason for State of Illinois grantees subject to all audits required by GATA. GOMB has informed all state agencies of this automatic extension for audits not submitted by March 19th.  This would include the Consolidated Year End Financial Report required under GATA.  See GOMBE announcement.  See OMB-M-20-11 and 17.
Remote Notarization
Secretary of State Guidance
The Secretary of State’s Office has issued Guidance for Remote Notaries and Consumers. Governor Pritzker’s Executive Order 2020-14 authorized notarizations remotely using real-time electronic technologies that feature high-quality audio-visual communication.  Secretary of State Guidance .  Similarly, the Illinois Department of Financial and Professional Regulation issued a release specifying the acceptance of remote notarization in real estate transactions and financial transactions. IDFPR release.
Paycheck Protection Program

The Illinois CPA Society has received a number of inquiries and feedback from members regarding the Paycheck Protection Program.  At issue is the role of the “agent” and payment of the “agent.”  CPAs and CPA Firms have approached their roles and assisting their respective clients from differing perspectives.  We have been in communication with the Community Bankers Association of Illinois, the Illinois Bankers Association and the Small Business Administration in an effort to address uncertainties and to maximize relief for PPP applicants.  Here are several suggestions for CPAs serving as agents for their clients in applying for the PPP Program:
• Discuss your role as an agent during the application process with the lender.  This makes them aware of your role as an agent and expectation of payment from loan fees.  Discuss your expectation of payment for services rendered as provided by guidance from the Small Business Administration.  If lender specifies, they will not pay your fee, consider recommending another lender to your client.
• Some financial institutions have learned after-the-fact of the existence of an "agent"  and have received statements for fees before the loan was closed.  In some instances, the bank could not verify if an  agent provided  services to the applicant.  The steps mentioned above along with your business acumen will go a long way in notifying the lender of your services and work.
There is still uncertainty in the PPP process, and we are learning as we go along.  ICPAS will continue working with stakeholders to provide you with up-to-date information to assist you and your clients.  See  ICPAS Letter to SBA re PPP and Agents wherein we ask SBA to take the lead in working with stakeholders to add clarity and understanding to the PPP process.

ICPAS Webinar Recording
CARES Act: Unraveling the PPP and ERC for Small and Mid-Sized Businesses 

In case you missed it, you’ll find a recording of today’s CARES Act: Unraveling the PPP and ERC for Small and Mid-Sized Businesses webinar, along with the PowerPoint slides and other supporting documentation at our coronavirus information and resources page.

AICPA PPP Resources

FAQs & Lender Documents
AICPA has created a PPP resource page with a variety of resources. SBA’s FAQs and broad recommendations for lenders documents have been recently added to the resource page.  Additional resources include Federal payroll tax reports; compensation; group health care benefits and retirement plan benefits and guidance for Average Monthly Payroll costs calculations. AICPA COVID-19 Resource Center.
Internal Revenue Service-Tax
Filing FAQs

The AICPA Tax and Policy Team created an FAQ document responding to frequent questions due to unique challenges of this filings season. The FAQs address seven key areas and the 20 most frequently asked questions on tax filing and payment relief. 
See ICPAS Government Relations Digital Library of COVID-19 Regulatory Updates.