WHILE CHURCH DOORS ARE CLOSED OR LIMITED TO 10 PEOPLE, THE LOOMING THREAT OF GOVERNMENT FUNDING MAY PROVE DEADLY.
Leaders of the Southern Baptist and The Gospel Coalition, among others, are encouraging / coaching / lobbying for churches to take the Covid-19 Stimulus. This never before and unthinkable move will spell the end of church as we know it in America as churches now become debtors /grant recipients of the Government through the Small Business Administration.
Before anyone screams “The gates of Hell will not prevail against the church”., let us fully affirm that the real church of Jesus Christ will never cease to exist.
Matthew 16:18 King James Version
18 “And I say also unto thee, That you art Peter, and upon this rock I will build my church; and the gates of hell shall not prevail against it.”
But ALL is about to change in the institutional church in America. The church has enjoyed freedom and protections from Government interference , state occupation and dictates and any government involvement in the churches affairs. This Constitutional refuge is about to evaporate and everything turned on it’s head as the church and ministries become funded by the Federal Government Stimulus in the form of the Covid BAIL OUT through the Small Business Administration.
PLEASE – No ultra pious surrenders of “personal rights and freedoms ” or theological and eschatological reasoning to avoid these deadly realities or to justify participation in the Stimulus . Only two things are likely driving these decisions- fear and inability to trust the Lord at His word …and pragmatism – the lipstick on the kiss of death.
WE CANNOT DEFEND STUPIDITY WITH PIETY OR THEOLOGY !
APOSTASY IS A BIBLICAL REALITY
The foundation of the Lord stands sure and Jesus will build His church -but individual churches and entire movements do go apostate as the Lord Himself warns repeatedly in in the Gospels and in Revelation 2 and 3.
Already ,many churches, ministries and entire denominational missions departments have become entangled with Faith Based Partnerships and the grants which accompany those programs. NOW many more of America’s churches will justify taking the bail out in the midst of the economic crisis of the 2002 Covid-19 Pandemic .
WHAT IS THE PROBLEM?
As loan / grant / bail out recipients Churches will be under Small Business Administration obligations for the 10 year life span of the loan or forever if the loan is converted to a grant and not repaid.Also churches who take the funding now will likely not hesitate to do so again in the case of another economic crisis. These bad decisions have long term consequences.
TO BE SPECIFIC
* CHURCHES CAN’T CRY FOUL.
Churches will no longer be able to simply cry “Separation of Church and State ” when demands are placed on them by the Government after taking public funding. The wall of protections in the Constitution provided in the “Free Exercise ” & ” Non Establishment ” clauses will forever be a “pierced veil” in the future.
*SIGNING THEIR RIGHTS AWAY
As the signatures go onto SBA forms – compliance with “non discrimination & inclusion” agreements become MANDATORY . This comes after marriage has been redefined and just ahead of the LGBTQ Equality Act or Fairness for All legislation making sexual minority status equal to race. SOGI , the legal language of “Sexual Identity and Gender Identity will provide all that is needed to force church into sweeping compliance with inclusive culture. SBA and all other federal agencies already have many similar policies in place but soon being LGBTQ will be a civil right added to the 1964 Civil Rights Act and all other federal non discrimination laws and agency guidelines. The church taking government funding and in debt or obligation to the Small Business Administration WILL COMPLY in all future hiring practices and similar areas where these ever expanding laws apply.
*CHURCHES ENJOY TAX EXEMPT STATUS .
Churches are grandfathered into non profit status . They do not even have to apply for it or for approval status. Status is automatic. The tax exempt status of churches and non profits mean,other than payroll withholding from employees, Churches do NOT pay taxes into the system. They do not have to file tax returns.
Other “para-church” ministries do have to file 990 non profit forms but do NOT pay taxes on income like “for profit” business do. Churches again do not even have to file 990 forms with the IRS . Opposition to churches non profit status EXIST and is already growing in progressive circles as seen in the 2020 Democratic Party during the primary season as several candidates object to and call for an end of church tax and legal exemptions and protections if those churches “discriminate” or are politically active on the conservative side. NOW after churches are receiving government bail outs and grants – the exemptions and protections will be FAR more VULNERABLE . If you are not paying in, why should you be taking money out and yet be protected with a “license to discriminate”? This will become the mantra of the progressive movement.
*CHURCHES DO NOT PAY PROPERTY TAXES .
In a conversation with Southern Baptist thought leader Albert Mohler of SBTS in 2014 regarding the dangers posed to churches by the forthcoming (at the time) SCOTUS case making gay marriage the law of the land, Mohler confirmed that “losing property tax exemptions would devastate many large churches and Christian Institutions “.
According to Mohler this includes SBTS Mohler’s own institution SBTS which Mohler points out would be “having to pay property tax on millions of dollars worth of real estate…the same is true for large churches. “. So even the ever circular talking reformed guru Albert Mohler gets that concern.
*Church Leaders will not bite the hand that feeds them. Going forward , any pastor who takes Covid -19 Stimulus funding will be far less likely to speak up to this or any future administration.
THE SIMPLE OPTION
Churches can allow employees to file for unemployment which they have paid into individually as part of the Covid -19 relief expansion of unemployment benefits . THERE is NO SOUND reason to involve the church itself in government funding to aid employees.
As we shall see , the Southern Baptist ERLC/ SBC Executive Committee, and others have lobbied FOR church inclusion in the Stimulus. They may have been inspired by self interest to have the Stimulus money flow through the churches to employees rather than direct payment in unemployment benefits to the staff individually.
One thing these lobbing efforts by ERLC and Guide Stone’s larger Church Alliance cannot say is “they did not have time to consider or had not thought these danger through !”. THE INSTITUTIONAL CHURCH IS DEAD
WHEN CHURCH DOORS OPEN/SERVICES RESUME EVERYTHING WILL HAVE CHANGED !
IF your church, or perhaps even worse, your pastor decides for your church, to take the Stimulus Bail Out – your church will never be the same autonomous entity.
It will be a debtor to the SBA, a federal government agency and no different than any other “business” who owes money and compliance to and in the eyes of the government.
WHY NOT HAVE IN HOUSE FINANCIAL HELP?
With Guide Stones Financial vast wealth in the tens of Billions- why is there no in house rescue /loan plan for Southern Baptist churches? Why have other denominations not proposed that ?
DOING IT TO THEMSELVES-LOBBYING FOR DESTRUCTION
As the Covid-19 two trillion dollar Stimulus details came out, some other facts and concerns came with it. According to Southern Baptist Convention Executive Committee interview this week Guide Stone Financial the retirement and financial giant of the SBC and the Ethics and Religious Liberties Commission – both ERLC and Guide Stone’s broader lobby group “Church Alliance” had actually aggressively lobbied for Churches to be included in accessing Government grants / loans as part of the Stimulus .
The CARES Act and Your Church
“Jonathan Howe and Harold Loftin”
SBC Executive Committee and Guide Stone “informed Pastors how the Stimulus Money works as
churches are eligible to participate in Small Business Administration Loans which might become grants
to those who qualify for such a conversion of the debt into grants.
Disaster Loan Assistance loans from Small Business Administration available to churches
Posted: April 01, 2020 By Roy Hayhurst , Director, Denominational and Public Relations Services
DALLAS “The U.S. Small Business Administration’s COVID-19 Economic Injury Disaster Loans will be available to churches and ministries. The loans provide another category of assistance that initially had seemed to be unavailable to churches.” “Churches and pastors have options available to them depending on their own situations and convictions,” GuideStone® President O.S. Hawkins said. “It is good that the options are available for pastors and churches who may need to access the federal relief that is being made available due to economic circumstances that are beyond their control.” “While we would never tell a pastor what he must do, it is good that the options are available for pastors and churches who may wish to avail themselves of the options available through this legislation.”
The application can be accessed by visiting covid19relief.sba.gov/#/.
“Initially, the regulations spoke of ‘private nonprofits,’ which seemed to exclude churches and ministries,” said Harold Loftin, chief legal officer for GuideStone. “However, the Small Business Administration is taking a broader view as it relates to the corona virus Economic Injury Disaster Loans, as it specifically allows for faith-based organizations to apply for the loans.” “Applicants for a loan in response to COVID-19 from an SBA Economic Injury Disaster Loan can request an advance of up to $10,000 that is to be issued within three days of application. Funds can be used for sick leave due to COVID-19, maintaining payroll to retain employees during economic interruption, rent, mortgage payments and other limited obligations. These funds do not have to be repaid, even if the loan requested is denied, effectively making the initial $10,000 a grant.” “If the same applicant obtains a Paycheck Protection Program loan through the Small Business Administration, the $10,000 forgiven under the Economic Injury Disaster Loan reduces what can be forgiven under the Paycheck Protection Program loan.” “Support for including faith-based organizations, including churches, in the economic relief is bipartisan in Washington. On Tuesday (March 31), four members of the U.S. House of Representatives — Cedric Richmond, a Louisiana Democrat; James Clyburn, a South Carolina Democrat; and Mike Johnson and Steve Scalise, both Louisiana Republicans — wrote Treasury Secretary Steven Mnuchin, Labor Secretary Eugene Scalia and Small Business Administration Administrator Jovita Carranza. In the letter, the congressmen wrote, “We can assure you that Congress did not intend to require non-profits to possess an exemption determination letter to be eligible for assistance through any other section of the CARES Act either.”
(See the attached copy of the letter.)
“The recognition of the importance of faith-based organizations, especially churches, to their communities and to their staff is welcome from these members of Congress,” Hawkins said. “We applaud the members of Congress and the members of the Trump administration who are working diligently to ensure economic relief for all Americans, especially pastors and churches who serve the physical and spiritual needs of the communities they serve.”
Roy Hayhurst is director of denominational and public relations for GuideStone Financial Resources of the Southern Baptist Convention®.
THE GUIDE STONE DISCLAIMER
“While we would never tell a pastor what he must do, it is good that the options are available for pastors and churches who may wish to avail themselves of the options available through this legislation.”
COVID-19 Pandemic Phase III Stimulus Package
“The COVID-19 Pandemic Phase III Stimulus Package provides potential relief for churches and pastors. This outcome is thanks to efforts by the Church Alliance – a national coalition of large and historic church benefit boards (including GuideStone) – and Southern Baptist partners who worked to ensure churches and pastors have the same options as small businesses and self-employed individuals attempting to financially weather the economic turmoil wrought by COVID-19. GuideStone’s Legal team has prepared a lengthy Q&A for churches and pastors looking for answers to how this stimulus package may impact them.” (Guide Stone may also be considering the impact on the Health Care Coverage they offer church employees.)
CHURCH ALLIANCE GUIDE STONES LARGER UMBRELLA LOBBY
“The Church Alliance strives to ensure that legislative and regulatory initiatives continue to fully address, protect and support the unique nature of retirement and health benefit plans operated by churches, religious institutions and affiliated organizations.”
“Since 1975 the Church Alliance has interacted with political leaders and government agencies on behalf of its member organizations to protect the retirement and health benefits provided to more than 1 million clergy, lay workers and their family members.” “The Church Alliance uses a number of methods to communicate its message to political and government leaders, including: Contracting with professional legislative partners Writing comment letters Attending meetings with stakeholders”
“The Church Alliance does not make contributions to political candidates.”
EVEN CHURCH ALLIANCE LEGAL TEAM HAVE DOUBTS/QUESTIONS.
IT IS STILL UNCLEAR: THE CHURCH ALLIANCE LEGAL TEAM LETTER TO SBA
Recent Comment Letter
“On April 1, 2020, the Church Alliance sent a letter to Jovita Carranza, Administrator of the U.S. Small Business Administration (SBA). The letter asked the SBA to clearly acknowledge that religious organizations are eligible to apply for the Paycheck…”
“On behalf of the Church Alliance, thank you for your leadership in helping businesses and nonprofits with relief as they navigate the challenges presented by COVID-19. We are writing to ask that the U.S. Small Business Administration (SBA) explicitly acknowledge that all nonprofit organizations, including churches, synagogues, and other religiously-affiliated organizations (“religious organizations”), are eligible to apply for the Paycheck Protection Program (PPP) loans established under Section 1102 of H.R. 748, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and to receive loan forgiveness under Section 1105 of the CARES Act. As the SBA issues guidance around this newly created program, the Church Alliance would appreciate consideration of the issues discussed below.”
“The Church Alliance would also appreciate clarification as to whether acceptance of a PPP loan would lead to the recipient being considered the recipient of federal funds. Currently, many religious organizations do not receive any federal funding. The Church Alliance would like it clarified that if such organizations were to receive PPP loans, such amounts would not, in and of themselves, result in the classification of the borrower as the recipient of federal funds.”
TGC/JOE CARTER FIRST TO THE PUNCH TO SELL STIMULUS TO CHURCHES.
THE GOSPEL COALITION WAS FIRST TO SCHOOL CHURCHES ON HOW TO CASH IN.
TGC was helping gin up concern about fund raising during the Covid-19 Crisis
TGC then sent out Joe Carter ,resident expert in outside funding for churches and Seminaries via his work at Acton Institute , ERLC , Oikonomia Network and TGC.
Joe Carter’s article was published and fully informed the morning following the Stimulus passage
“How does this legislation affect churches and small nonprofits?”“Churches, nonprofits, and Christian schools that are 501c3 (as well as most small businesses) with fewer than 500 employees are eligible for the $367 billion in Small Business Administration (SBA) loan guarantees and subsidies. This legislation increases the maximum 7(a) loan (i.e., the SBA loan program for providing financial assistance) amount to $10 million and would expand allowable uses for such loans to include employee salaries, insurance premiums, mortgage payments, payroll support (including paid sick or medical leave), and other debt obligations.”
“For almost all churches, the loan amount they can receive will be equal to their total average monthly payroll costs for the preceding 12 months (March 2019 to February 2020) multiplied by 2.5. For example, a church that has an average monthly payroll cost of $50,000 would be eligible for a loan of $125,000.”
“The loan requires a “good faith” certification that the funds will be used to support ongoing operations, retain workers, and/or maintain payroll or make mortgage, lease, and utility payments. The loan is forgivable (i.e., doesn’t require repayment) if the church employed the same number of people (or more) during the loan period as they did in 2019. Funds that are not forgiven have a loan maturity of 2 years, and loan payments under this program are not due for six months No fees are included for the loan, and no collateral or personal guarantees will be required.”
“Since the loan comes from the SBA, most churches will want to contact the bank they currently use for information on how to apply for this program. This loan program ends on December 31, 2020.”
THE MONEY TRAIN IS LEAVING THE STATION
By the next day the Executive Committee of the SBC and Guide Stone had jumped in. By Thursday Russell Moore of the Ethics and Religious Liberty Commission was reassuring pastors that taking the funds did not violate separation of church and state- at least according to Democrat Russell Moore .
“Over the past week, several pastors have asked us if a church or ministry taking advantage of newly approved government-backed Small Business Administration (SBA) loans would be wrong. Would such a church be now a government-funded enterprise? Russell Moore doesn’t think so, and here’s why:”
APRIL 3RD ERLC IS GIVING FULL INSTRUCTIONS ON HOW CHURCHES CAN GET THE STUMULUS
“What are the religious liberty concerns with this financial aid?”
“Russell Moore, ERLC president, recently addressed this question in his article, Do SBA-backed loans violate the separation of church and state? Moore wrote in response to several pastors who asked us the same question, “is a church or ministry taking advantage of newly approved government-backed Small Business Administration (SBA) loans wrong to do so? Would such a church be now a government-funded enterprise?” Moore does not think so and we’d encourage you to read his full article for why.”
When can my church apply for this loan?
“Churches can begin applying for the program on Friday, April 3. The deadline for submitting your application is June 30, 2020. However, because there is a funding cap, you should apply as soon as possible.”
How do I apply to the program?
“The application for the Paycheck Protection Program can be filled out and downloaded at this link. Once completed, you can submit the form to your Small Business Administration (SBA) participating lender. You will also need to provide your lender with payroll documentation.”
How do I find an SBA participating lender?
“The easiest way is to simply ask the bank which currently manages your accounts if they are participating in the program. Although the SBA is working on a web page where you can view approved lenders near you, that resource is currently not available.”
How many loans can I take out under this program?
“The Paycheck Protection Program can only be used to acquire one loan for your church. If you use this program, though, it may prevent your church from being eligible for the CARE Act’s delayed payroll tax provisions. (That provision allows an employer to defer paying their portion of an employee’s Social Security taxes through the end of 2020. Half of the deferred amount will be due at the end of 2021 and the other half will be due at the end of 2022.)”
What can my church use the loan for?
“The proceeds of the loan can be used to pay for payroll costs (including benefits) and for interest on mortgage obligations (incurred before Feb. 15, 2020); rent (under lease agreements in force before Feb. 15, 2020); and utilities (for which service began before Feb. 15, 2020).”
What counts as payroll costs?
“For churches, payroll costs include salary, wages, and commissions (capped at $100,000 on an annualized basis for each employee); employee benefits (including costs for vacation, parental, family, medical, or sick leave); allowance for separation or dismissal; payments required for the provisions of group health care benefits including insurance premiums; and payment of any retirement benefit; and state and local taxes assessed on compensation.”
( ERLC ASKED THE SURREAL QUESTION )
How much money can my church borrow under this program?
“The loan amount can total up to two months of your average monthly payroll costs from the last year plus an additional 25% of that amount.” “This can be calculated by taking the average monthly payroll and multiplying by 2.5. For purposes of calculating “Average Monthly Payroll” on the application, you will use the average monthly payroll for 2019, excluding costs over $100,000 on an annualized basis for each employee. If your church or organization began in 2020, the average monthly payroll may be calculated using the time period from Jan. 1, 2020 to Feb. 29, 2020, excluding costs over $100,000 on an annualized basis for each employee.” “As an example, let’s consider a church that has three employees who had total annual payroll costs in 2019 of $120,000, $75,000, and $50,000. The church’s actual average monthly payroll for 2019 would be $20,416 ($245,000 a year/12 months). But because of the $100,000 cap per employee, the allowable average monthly payroll would be $18,750. We then take that number and multiply it by 2.5. The church would thus qualify for a total loan amount of $46,875.” Does my church have to pay back the loan?
“Under certain conditions, the loan is forgivable”
BAPTIST PLAYING POLITICS
Democrat Moore played politics with Covid care . ” Russell Moore, president of the ERLC, weighed into this ethical dilemma with a Christian response with an opinion piece in The New York Times last week. Moore notes how “this pandemic will change us, change our economy, our culture,” and that we should remember that “one day we will tell our grandchildren how we lived, how we loved, during the Great Pandemic.”
ARE THE CONCERNS ADDRESSED ?
April 2nd Baptist Pressed published this article “
YET the “guarantees are vague and the reality is ERLC and Guide Stone Baptist entities gladly lobbied for including Churches and promoted / coached participation while still unable to answer these concerns.
WHAT IS AN INTERIM FINAL RULE ?
ERLC- You must be joking as churches are already filing for the funding. With the sad and shaky history of the ERLC under Russell Moore you cannot trust these ERLC guys ideals of “religious freedom protections “. Given their long history of ongoing platforming gay activist change agents, attacking the “nuclear family ” and the ERLC staffers and Fellows open push of Revoice LGBTQ Flourishing in the Church- clearly the ERLC would not be pushing for the lines of protection to be drawn in the same places as most Southern Baptist or broader Biblical conservatives.
“The interim final rule provided guidance stipulating: “All loans … will be made consistent with constitutional, statutory, and regulatory protections for religious liberty …”It reiterates an SBA regulation that states: “Nothing in [SBA nondiscrimination regulations] shall apply to a religious corporation, association, educational institution or society with respect to the membership or the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution or society of its religious activities.”
Additional guidance is expected to be issued Friday by the SBA. Its intent is two-pronged: To help lenders understand the program does not exclude faith-based organizations; and to help churches and other faith-based nonprofits understand the religious liberty protections.Travis Wussow, the ERLC’s general counsel and vice president for public policy, said he was grateful for the resolution and expressed gratitude for the work of the Trump Administration throughout the process.
“It is significant that SBA’s new regulations state that the religious freedom rights of houses of worship and faith-based nonprofits will be upheld in this new loan guarantee program,” Wussow said. “We look forward to further guidance from the Administration, and we’re grateful for the hard work being done to ensure that this new program works for houses of worship.”
Whether or not your church should take the Cares Act Stimulus should be a church body / membership decision, NOT solely the pastors. Pastors can and do often leave churches to go on to their next job and pulpit. IF THEY HAVE BUYERS REMORSE .. pastors can start afresh with a church that did not encumber itself while leaving the poor decision behind with the church they led into taking the SBA money.
Pastors have latitude- the church does not. The church needs to decide prayerfully and informed fully of the dangers and long term impact.
NOTE- Again with Guide Stones Financial vast wealth in the tens of Billions- why is there no in house rescue /loan plan for Southern Baptist churches? Why have other denominations not proposed that ?
NO CHURCH SHOULD LEAVE THIS DANGEROUS DECISION TO THE PASTORS OR TO POTENTIAL “YES MEN” ON HIS ELDER OR DEACON BOARDS.
Consider the Constitution and the protections and freedoms and status the church has enjoyed for over two centuries in America. Consider the church we will be leaving to the next generation(s) if the world stands. ABOVE ALL- consider prayerfully the Word of God and Biblical history that God’s people can and should and must trust Him in Faith in times of crisis and NOT lean on their own wisdom and self justifications.
We must not depend on the “ARM OF FLESH ” if we are to remain the Church of the Living God and not a debtor and a beggar at Babylons doorstep.
TRUST GOD -HE DOES NOT LIE
5 Thus says the Lord:
“Cursed is the man who trusts in man And makes flesh his strength, Whose heart departs from the Lord. 6 For he shall be like a shrub in the desert, And shall not see when good comes, But shall inhabit the parched places in the wilderness, In a salt land which is not inhabited.
7 “Blessed is the man who trusts in the Lord, And whose hope is the Lord. 8 For he shall be like a tree planted by the waters, Which spreads out its roots by the river, And will not fear when heat comes; But its leaf will be green, And will not be anxious in the year of drought, Nor will cease from yielding fruit.
This article was originally published on Thirty Pieces of Silver, and is reposted with permission from the author, Thomas Littleton.
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