We have put together a list of resources for exhibitors to refer to. This information is intended to be used as a general resource and does not constitute legal advice. Please consult with individual counsel for any legal advice related to the contents of these resources or the coronavirus pandemic more generally.
State Reopening Information and Resources for Businesses
NATO COVID-19 State by State Reopening Information [updated 20 October]
State and Local Reopening Guidelines [updated regularly]
State and Local COVID-19 Resources for Businesses [updated regularly]
Movie Theater Requirement Tracker [updated regularly]
Operations Resources for Reopening
Global Reopening tracking [updated regularly]
Other CDC links:
Federal Legislative Updates [as of 8 July]:
On March 27, President Trump signed into law the CARES Act, phase III stimulus legislation that includes funding for a loan guarantee program; expanded SBA loan opportunities; various tax provisions; and an expansion of the unemployment insurance program. NATO will be posting resources on a rolling basis as they become available. Bookmark this page for updates.
On April 24, President Trump signed legislation authorizing an additional $310 billion for the Paycheck Protection Program and $60 billion for the Economic Injury Disaster Loans.
In late May/early June, Congress passed the Paycheck Protection Program Flexibility Act, legislation revising the Paycheck Protection Program terms. Congress passed further legislation authorizing the PPP loans through August 8.
NATO Summary Memos
Click below to read NATO’s summary memos on various aspects of the CARES Act (memos will be updated as new information becomes available):
Main Street Lending Facilities Webinar Slides [updated 7 July]
NATO Summary of PPP and EIDL Rules [updated May 26] **subject to revision pending PPPFA regulation**
NATO Summary of Alternate Debt Relief Under Standard SBA Loans [posted 8 April]
NATO Summary of Unemployment Insurance Guidance [posted 6 April]
NATO FAQ on CARES Act Loan Programs [posted 2 April]
Federal Reserve Main Street Lending Facilities (Businesses with up to 15,000 employees or $5 billion in 2019 revenue)
On July 6, 2020, the Federal Reserve announced that the three Main Street Lending Facilities authorized by the CARES Act for businesses with up to 15,000 employees or $5 billion in revenue in 2019 are fully operational and open for loans. Click below for resources:
Frequently Asked Questions [updated 15 July]
List of Participating Lenders [published 8 July, updated frequently]
Main Street Lending Facilities Webinar Slides [updated 7 July]
Federal Reserve Main Street Lending Program Forms and Agreements [updated 11 June]
New Loans Term Sheet [updated 8 June]
Priority Loans Term Sheet [updated 8 June]
Expanded Loans Term Sheet [updated 8 June]
SBA Paycheck Protection Program Loans (Businesses with up to 500 employees)
Eligible theater owners can apply for Paycheck Protection Plan loans starting April 3. Interested exhibitors should talk with lenders about the application process. Resources published by the Treasury Department are here in order of how recently they have been issued or updated. The Paycheck Protection Program Flexibility Act passed in June amends some of the underlying loan terms. New regulation promulgated under the PPPFA is linked below.
Frequently Asked Questions [updated 25 June]
Borrower Application [updated 24 June]
Guidance on Refinancing EIDL Loans [issued 22 June]
Seasonal Employers – Interim Final Rule [issued 28 April]
Disbursements – Interim Final Rule [issued 28 April]
Affiliation Rules – Interim Final Rule [issued 3 April]
SBA Disaster Loans (Businesses with up to 500 employees)
Eligible theater owners can apply for disaster loans through the Small Business Administration. Click here to read NATO’s memo on the disaster loans: Small Business Administration Disaster Loans Memo to Members. Additionally, here are SBA Webinar Slides that describe the application process and who is eligible to apply.
Corporate Credit Facilities
On April 9, the Federal Reserve published fact sheets on corporate credit facilities, which serve as a funding backstop for corporate debt issued by eligible issuers. The fact sheets are linked below:
Primary Market Corporate Credit Facility [issued 9 April]
Secondary Market Corporate Credit Facility [issued 9 April]
OSHA Guidance for Restaurants and Businesses Offering Curbside or Takeout Service
OSHA published guidance including tips that can help reduce workers’ risk of exposure to the coronavirus for the restaurant and beverage industries and offering takeout or curbside pickup services during the COVID-19 pandemic:
Paid Sick and Emergency Leave (Employers with fewer than 500 employees)
On March 18, Congress passed the Family First Coronavirus Response Act requiring employers with fewer than 500 employees to provide paid sick and emergency leave. The legislation goes into effect on April 1, 2020. The law applies to leave taken between April 1, 2020-December 31, 2020. DOL posted a temporary rule on April 1 regarding the leave requirements. The regulation clarifies that if a worksite was closed before April 1, 2020 and an employer stops paying an employee because the employer does not have work for them to do, the employee is NOT eligible to receive paid sick or emergency leave. However, the employee may be eligible for unemployment insurance benefits. This is true whether the employer closed the worksite pursuant to a government directive OR for lack of business.
Click below to read a summary of the Families First Coronavirus Response Act:
Click below for guidance published by the Department of Labor:
Temporary Rule [updated 16 September]
Click here to read NATO’s UPDATED summary of the requirements that reflects the DOL’s announcement:
Coronavirus Paid Leave Memo to Members [posted 23 March]
Click below to read the IRS’s description of the how the paid sick and emergency leave tax credits will be implemented:
IRS Description of Paid Leave Tax Credit [issued 20 March]
Employee Retention Tax Credit
The Treasury Department has put out a Q&A on the employee retention tax credit. NOTE: Companies that obtain SBA 7(a) loans are not eligible for the tax credit.
Qualified Improvement Property Guidance from IRS
Section 2307 of the CARES Act amends the tax code to allow qualified improvement property to be eligible for 100% bonus depreciation, fixing the so-called “retail glitch.” The amendment is retroactive to the 2018 tax return. This change could provide substantial tax relief. To capitalize on this savings opportunity, businesses should first determine if they are eligible to amend their 2018 tax returns and, if already filed, their 2019 tax returns. Eligible businesses should also take advantage of the full cost write-off for 2020. This 100% bonus depreciation is set to start phasing out in 2023 and expire in 2027. On April 17 the IRS issued guidance on how taxpayers can take advantage of the technical correction to the QIP rules and change their depreciation schedule:
IRS Guidance on Implementing QIP Depreciation [issued 17 April]
Other Important Resources
OSHA Guidance on Returning to Work [posted 18 June 2020]
OSHA Seven Steps to Correctly Wear a Respirator at Work [updated 4 May]