Well said and well captured summary of a serious misconduct. The consequences of these mgmt and board actions and decisions are not known yet.

Fyi, below is the copy of one of several of my email to John Viola and Steve Phillips. This one was sent on April 26.  Never got a reply.

Slobodan

April 26, 2020

Hi John and Steve,

Below is the additional information from my recent research that I would like to share with you. I would also appreciate answers to these questions:

1. Did OPA obtain expert 3rd party opinions on its eligibility to apply for the PPP loan as a 501(c)(4) nonprofit type business entity?

2. If yes who are those 3rd parties?

3. Did you obtain Board's approval to prior to filling the loan applications?

4. If the Board's approval was not obtained why not and who decided on that?

5. Did your task force's (work group) research efforts involve / include anyone from the Budget and Finance Committee and the OPA Treasurer?

I have already mailed you the results of my earlier research. Hope that helped explain why my interest to know what kind of data helped OPA determine that its business entity qualifies for the PPP loan.

During my additional research I found below information of special interest and importance. I also included the web link sources to the following information:

- Community Association Institute (CAI) Guide to SBA PPP on its website;

- An opinion by a law firm on the subject which nonprofits are eligible;

- Press Release from Senator Rubio. He chairs the Small Business Committee.

Regards,
Slobodan

A. CAI Guide the the SBA PPP (relevant text and the web link)

Who can apply for a PPP Loan?
Businesses with fewer than 500 employees are eligible to apply for PPP loans. Types of businesses include sole proprietors, independent contractors, self-employed individuals, 501(c)(3) charities, veterans’ service organizations, and certain Tribal businesses. All applicants must provide documentation proving the applicant was operational prior to February 15, 2020.

Eligible entities include 501C3 and veteran-related non-profits and small businesses (under 500 employees). Please check with your bank and other professionals for information regarding eligibility. Specifically, the following CAI members may be eligible.

Management companies
Association business partners

B. Opinion from law firm Venable LLP (I also included relevant web link):

Despite calls by nonprofit and trade association leaders to include all types of nonprofit organizations as eligible loan recipients under the Paycheck Protection Program, the final version of that section of the CARES Act only includes entities organized under sections 501(c)(3) and 501(c)(19) of the Code. With that said, emergency financial relief for other types of nonprofits, such as 501(c)(4) social welfare organizations and 501(c)(6) trade and professional associations, is available under a separate section of the legislation addressing emergency Economic Injury Disaster Loan (EIDL) grants. In addition, nonprofit organizations of all types that do not receive SBA Paycheck Protection Program 7(a) loans are also eligible for Employee Retention Payroll Tax Credits under Section 2301 of the CARES A

C. Press Release from Senator Rubio

Rubio: Small Business Committee Will Use Subpoena Power to Review Paycheck Protection Program Compliance