Recently, the availability of PPP loans was expanded to include most Section 501(c)(6) organizations—including trade associations, professional societies, business leagues, and chambers of commerce—and to destination marketing organizations. Under this expansion, section 501(c)(6) organizations are eligible to apply for PPP loans as long as they:
A. Are not engaged in significant lobbying activities, meaning 1) no more than 15% of revenues are received from lobbying activities; no more than 15% of total activities comprise lobbying activities; and lobbying activity costs did not exceed $1 million during the most recent tax year ended prior to February 15, 2020.
B. Have 300 or fewer employees.
C. Are not a professional sports league, political campaign, or political activities organization. and
D. Meet other program requirements.
The new law did not, however, clarify the definition of "lobbying activities" and how such activities would be measured. However, on March 3, 2021, the SBA clarified that the definition of "lobbying activities" set forth in the Lobbying Disclosure Act (LDA) should be used by Section 501(c)(6) organizations for purposes of determining their eligibility for PPP loans.
