That Catholic News Service report said that Catholic lobbyists worked, in the week the legislation creating the program was actually passed, to ensure that as rules were devised by Department of Treasury officials, that Catholic entities civilly distinct from each other would not be regarded as one entity, which might place the consolidated entities above a 500-employee eligibility cap.
In the Church's canon law, parishes are distinct legal entities from each other and from dioceses, and while diocesan bishops exercise legislative and judicial authority over parishes, parishes do not constitute subsidiaries of dioceses. Nor do affiliated entities like Catholic Charities, Catholic schools and universities, or Catholic hospitals, which are ordinarily overseen by lay boards on which bishops often have only ordinary voting membership, if that.
The Catholic Church is a web of organizations connected by faith, mission, sacraments, and oversight, but those organizations are not uniformly administered as subsidiaries or under the direct control of local bishops.
While parishes generally pay annual fees to dioceses, the funds of distinct canonical entities may not be permissibly commingled, and canon law requires that the civil structures of parishes, dioceses, and other Catholic entities reflect their canonical reality.
Nevertheless, the complex organizational structure of the Catholic Church made it possible that several Catholic entities in the same place might be regarded by the SBA as one entity. The effort of the USCCB lobbyists was to ensure that wouldn't be the case, the Catholic News Service report explained.
That effort was successful.
An April 3 FAQ document from the SBA explained that the general loan rules provided that if faith-based organizations had an affiliation related to "religious beliefs about church authority or internal constitution, or because the legal, financial, or other structural relationships between your organization and other organizations reflect an expression of such beliefs," they would qualify for an exemption to rules that would ordinarily count "affiliated" organizations as one entity for purposes eligibility determination.
However, faith-based organizations "affiliated with other organizations solely for non-religious reasons, such as administrative convenience...would be subject to the affiliation rules," the SBA explained.
In the United States, both parishes and dioceses are facing serious financial shortfalls and in Rome, the Vatican has run sizeable budget deficits for years. While the Catholic Church has assets of artistic, cultural, and historic value, those are not easily liquidated, and with few exceptions, Catholic entities around the world have been facing a serious cash crunch for years.
In his statement, Coakley acknowledged that "more than 100 Catholic schools have announced that they plan to close, with hundreds more facing an uncertain future. Businesses, hospitals, schools, and churches all across the country are facing many of the exact same problems."
"We will continue advocating for everyone negatively affected by this terrible pandemic, praying for all the sick, for all who have died and are in mourning, and especially the poor and vulnerable at this time of great need."
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