Frequently Asked Questions — SBA Shuttered Venue Operators Grants, April 8, 2021

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Frequently Asked Questions on the Shuttered Venue Operators Grant program issued by the U.S. Small Business Administration, with answers as of April 8, 2021 and items marked as new or updated from the April 6, 2021 version. The document describes SVOG as Section 324 of the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues Act, signed into law Dec. 27, 2020 as part of H.R. 133 Consolidated Appropriations Act, 2021, and notes amendments under Title V, Sec. 5006 made by the American Rescue Plan Act of March 11, 2021. Its contents list sections on eligibility, definitions, application, use of funds, business size and employees, revenue, subsidiaries and affiliates, and the supplemental phase. Answers address the requirement that a business have been in operation as of February 29, 2020, alternative earned revenue loss comparisons, and DUNS number requirements for affiliates.

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Shuttered Venue Operators Grants 
Frequently Asked Questions | April 8, 2021 
 
 
The Shuttered Venue Operators Grant (SVOG) program is Section 324 of the Economic Aid to Hard-Hit 
Small Businesses, Nonprofits and Venues Act (Economic Aid Act) signed into law on Dec. 27, 2020, and 
was part of H.R. 133 Consolidated Appropriations Act, 2021. To see the full text, download the PDF of the 
enrolled bill, go to page 812 for the Economic Aid to Hard-Hit Small Businesses, Nonprofits and Venues 
Act (Division N, Title III) and then to page 841 for Section 324: Grants for Shuttered Venue Operators. The 
American Rescue Plan Act, signed into law on March 11, 2021, included SVOG amendments under Title V, 
Sec. 5006 to the Economic Aid Act.  
 
Following are answers as of April 8, 2021 (those marked with * are new and/or updated from the April 6, 
2021, version), to frequently asked questions about the SVOG program. These will be updated as new 
information comes available and additional program details are finalized.  
 
Contents 
Eligibility ......................................................................................................................................................... 1 
All Applicants ............................................................................................................................................. 1 
Museum or Movie Theatre Operator ......................................................................................................... 7 
Live Venue Operator or Promoter ............................................................................................................. 8 
Talent Representatives ............................................................................................................................ 12 
Definitions ..................................................................................................................................................... 12 
Application .................................................................................................................................................... 16 
Use of Funds ................................................................................................................................................. 27 
Business Size/Employees ............................................................................................................................. 31 
Revenue ........................................................................................................................................................ 33 
Subsidiaries & Affiliates ................................................................................................................................ 37 
Supplemental Phase .................................................................................................................................... 40 
 
Eligibility 
All Applicants 
1. What is an “eligible entity” for an SVOG? 
Eligible entities may be live venue operators or promoters, theatrical producers, live performing arts 
organization operators, museum operators, motion picture theatre operators, and talent 
representatives, per the Economic Aid Act. Additionally, entities of these types owned by state or 
local governments (for example, museums or historic homes) are eligible to apply if the 
governmentally-owned entity also acts solely as a venue operator, museum, etc. and not also include 
other types of entities. For example, a city parks and recreation department that operated a 

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bandstand in a public square along with running various nature parks would not qualify as an eligible 
entity for an SVOG. Finally, each subsidiary business owned by an eligible entity that also meets the 
eligibility requirements on its own rights will qualify as an eligible entity.  
 
2. When does a business have to have been established to be eligible to apply for an SVOG?  
The business must have been in operation as of February 29, 2020. 
 
3. Is an entity not in business in 2019 but conducting business operations on Feb. 29, 2020, eligible 
to apply for an SVOG? 
Yes, if an entity was not in business during 2019 but was conducting business operations on Feb. 29, 
2020, including incurring costs of necessary start-up, preparatory activities in the lead time before an 
anticipated opening date, it is eligible to apply if it can show the required earned revenue loss. In 
situations like this, the SBA will use the following alternative method for demonstrating revenue loss 
based on the approach the Agency is using with the PPP: Firms not in operation in 2019 may qualify 
for an SVOG if their gross earned revenues for the second, third, or fourth quarter of 2020 
demonstrate a reduction of not less than 25% from their gross earned revenue for the first quarter of 
2020. For firms that had commenced start-up operations but were unable to open as anticipated due 
to the pandemic, they would only be eligible under this alternate method if they had earned revenue 
in the first quarter of 2020 from sources such as advance ticket sales, merchandising, etc. Firms which 
had been conducting business operations and incurring expenses in 2020 in a pre-opening capacity 
but which had no earned revenue for the first quarter of 2020 would not be eligible to apply. 
 
4. Is an entity that applied for and received a Paycheck Protection Program loan in July 2020 
eligible to apply for an SVOG? 
Yes, if an entity applied and was approved for a PPP loan prior to Dec. 27, 2020, it is eligible to apply 
for an SVOG.  
 
5. Is an entity that applied for a First Draw or Second Draw PPP loan on or after Dec. 27, 2020, 
eligible to apply for an SVOG?   
Yes. While entities originally were prohibited from receiving both forms of SBA assistance, the 
American Rescue Plan Act, which became law on March 11, 2021, removed this restriction. However, 
under the law, entities will be ineligible for a PPP loan AFTER they receive an SVOG.  
 
6. No longer relevant / deleted per the American Rescue Plan being signed into law.  
 
7. Is a mobile entity with no fixed performance space eligible to apply?  
No. Among other requirements, the Economic Aid Act requires a venue to have defined performance 
and audience spaces. If a particular venue cannot meet this requirement, it is not eligible to apply for 
an SVOG.  
 
8. What disqualifies an entity from SVOG eligibility? 
The following types of circumstances would preclude an otherwise eligible firm from an SVOG: 
• 
It does not have a place of business located in the United States, does not operate primarily 
within the U.S., and does not make a significant contribution to the U.S. economy through 
payment of taxes or use of American products, materials or labor. 
• 
It was not in operation as of Feb. 29, 2020. 
• 
It is a publicly traded corporation, or is majority owned and controlled by a publicly traded 
corporation. 

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• 
It presents live performances or sells products or services of a prurient sexual nature. 
• 
More than 10% of its 2019 gross revenue came from the federal government (not counting 
disaster assistance) 
• 
It owns or operates venues, theatres, museums or talent agencies in more than one country, 
owns or operates venues, theatres, museums or talent agencies in more than ten states, AND it 
had more than 500 employees as of Feb. 29, 2020. 
• 
Five other firms with which it is affiliated have already received SVOG awards. 
• 
It is a museum and other museums with which it is affiliated have already received $10 million in 
SVOG funding. 
 
9. If an entity is part of a private university, how will the SBA apply the SVOG eligibility barrier 
that prohibits organizations which received more than 10% of their 2019 gross revenue from 
Federal funding? 
If a private university-based eligible entity lacks separate legal existence from its parent university, or 
has separate legal existence but is majority owned and controlled by the university, it will have to 
look to the gross revenue of its parent university when determining whether it passes the barrier 
against having more than 10% of its 2019 gross revenue come from Federal sources (excluding 
disaster assistance). If a private university owns less than a majority of an eligible entity with separate 
legal existence, the entity only needs to consider whether more than 10% of its own 2019 gross 
revenue came from Federal funding. NOTE: Public university-based eligible entities are not subject to 
the 10% cap on the Federal share of their gross revenue because they are owned by state or local 
governments. 
 
10. If a museum or live venue operator or promoter is a sub-unit of a university without separate 
legal existence, but a separate non-profit foundation exists solely to receive donations to the 
university-owned museum or live venue operator or promoter, is that foundation eligible for an 
SVOG even if it has no economic or business activity apart from receiving and passing along 
donations? 
No. Under such an arrangement the foundation’s principal business activity would be serving as a 
fiscal agent for the university-owned museum or live venue operator or promoter rather than acting 
as a museum operator or live venue operator or promoter as is required by the Economic Aid Act. 
 
11. Does the SVOG eligibility exclusion of entities that received more than 10% of their 2019 gross 
revenue from the Federal government apply to eligible entities owned by tribal, state or local 
governments, including entities owned by public colleges and universities?  
No. The Economic Aid Act establishes an alternate eligibility restriction for government-owned 
entities. Under that, government-owned entities cannot contain any other government-owned 
entities apart from the live venue operator or promoter, live performing arts organization operator, 
museum operator, movie theatre operator, or talent representative. If the SBA applied the SVOG 
eligibility rule restricting entities that receive more than 10% of their gross revenue from the Federal 
government to government-owned entities, this would deny eligibility to all state-owned entities. 
The Economic Aid Act explicitly makes such entities eligible (It appears no state receives less than 
approximately 20% of its gross revenue from the Federal government), so the SBA is not applying this 
rule.  
 
12. For college and university-owned entities seeking eligibility, does the 10% federal funding 
barrier include financial aid that is awarded to students such as Pell grants?  

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Yes. Based upon the treatment given Pell grants by the Department of Education, they would be 
included in the amount of Federal funding provided to college and university-owned entities that do 
not have separate legal existence. 
 
13. Can a mobile, portable, or touring facility be a qualifying venue for an SVOG?  
Yes. Any venue, including traveling tent shows such as circuses and festivals, that meets all the space-
related requirements in the Economic Aid Act (e.g., defined performance and audience spaces, 
lighting rig, etc.) will be considered an SVOG-qualifying venue. If a particular venue cannot meet 
these requirements, it is not eligible to apply for an SVOG. 
 
14. If an eligible entity has applied for or received any grants, loans, or other funding from a state 
or local governmental relief program is it still eligible to receive an SVOG? 
Yes. Receipt of pandemic-related or other assistance from state or local governments does not 
disqualify an eligible entity from the SVOG program, though an eligible entity must ensure that it 
does not claim any costs or expenses under its SVOG that it has already received reimbursement or 
other payment for under another award or program. 
 
15. No longer relevant / deleted per the American Rescue Plan being signed into law.  
 
16. Are service and support companies that provide stages, lighting, sound, casts, and other 
support for live performing arts events or which showcase performers or pre-packaged 
productions to potential buyers eligible to apply for an SVOG? 
No. The Economic Aid Act is designed to assist only those eligible entities identified in the statute. 
SVOGs are not available for service providers that support eligible entities. 
 
17. Are entities whose broader business operations include hosting live performing arts events, 
such as agricultural fairs or party boats/pleasure cruises that feature concerts, eligible to apply 
for an SVOG?  
No. Only entities whose principal business activity is being a live venue operator/promoter/theatrical 
producer/live performing arts organization operator, museum operator, motion picture theatre 
operator, or talent representative are eligible for SVOGs under the Economic Aid Act. Although an 
agricultural fair or entertainment cruise may include live performing arts events, their principal 
business activity is something other than serving as one of eligible entity types in the statute. 
 
18. Are eligible entities currently involved in bankruptcy proceedings eligible to apply for an SVOG? 
Possibly. Eligible entities undergoing a reorganization form of bankruptcy (such as Chapter 11 or 
Chapter 13) may apply for an SVOG if they entered bankruptcy after Feb. 29, 2020. However, entities 
undergoing a liquidation form of bankruptcy (such as Chapter 7) are not eligible. In addition, SVOGs 
made to entities undergoing reorganization bankruptcy may, in SBA’s discretion, be subject to 
special restrictions or requirements designed to reduce the risk of loss of taxpayer funds. 
 
19. Are entities located in US territories eligible to apply for an SVOG? 
Yes. Under the Economic Aid Act, in addition to those located in states, eligible entities in the District 
of Columbia, the Commonwealth of Puerto Rico, and any other territory or possession of the United 
States (e.g., Guam, American Samoa, the U.S. Virgin Islands) are able apply for an SVOG. 
 
20. Is an entity that received CARES Act funding eligible to apply? (previously #4 under Museums or 
Movie Theatre Operator, thus moving questions 4-12 on March 5 version up one number) 

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Yes. Per the Economic Aid Act, receipt of CARES Act funding does not disqualify an entity for SVOGs. 
 
21. How will receiving a PPP loan affect an eligible entity’s SVOG award? 
Per the American Rescue Plan Act, any entity that receives a PPP loan on or after Dec. 27, 2020 
(whether First Draw or Second Draw), will have the PPP loan amount deducted from the SVOG 
amount. For example, if a jazz club received a PPP loan for $10,000 on Feb. 1, 2021, and then applied 
for and received an SVOG which, based on the amount of its earned revenue loss would have been 
$100,000, the jazz club’s SVOG will be reduced by $10,000 and it will receive a $90,000 SVOG. Any PPP 
borrower that received a PPP loan before Dec. 27, 2020, however, will not have the PPP loan amount 
deducted from any subsequent SVOG. 
  
22. If a portion of my PPP loan was forgiven, will that affect how much of the loan amount is 
deducted from my SVOG? 
No. The full amount of any PPP loan received on or after Dec. 27, 2020, must be deducted from an 
entity’s SVOG without regard to whether a portion of that PPP loan was forgiven or not. If the entity 
received a PPP loan prior to Dec. 27, 2020, the PPP loan and/or its forgiveness status is not factored 
into an SVOG. 
 
23. What will the SBA do if an eligible entity has two or more business activities with essentially the 
same level of combined revenues, costs, staff time, assets, contracts, etc.? 
Where an eligible entity has multiple lines of business that are essentially tied regarding their share of 
the entity's overall business activity, they will all be deemed its principal business activities. 
 
24. Does a cruise ship count as a qualifying venue for promoters or producers to stage 
performances on or for a talent representative to book performers on?  
It is possible. A cruise ship may serve as a qualifying venue for the business activities of eligible 
entities if it meets all the venue requirements established under the Economic Aid Act (defined 
performance and audience spaces, lighting rig, mixing equipment, etc.), but a cruise ship would not 
be eligible for an SVOG itself. 
 
25. Must a live venue operator, promoter, theatrical producer, live performing arts organization, or 
talent representative stage all its events or book all of its clients at qualifying venues? 
No. While an eligible entity must use qualifying venues for the majority of the events it stages or 
books clients into, non-qualifying venues may also be used. 
 
26. If an entity qualifies under two different categories of eligible entities (for example, a museum 
and a live venue operator) which category should be used when applying? 
If an entity can meet all the requirements for more than one type of eligible entity, it is recommended 
the entity pick the entity type that gives the strongest case for eligibility or that best represents how 
the entity views itself. 
 
27. What is the “de minimis gross revenue” from the sale of products or services, or presentation of 
any materials of a prurient sexual nature that allows an entity to be eligible for an SVOG?  
Based on SBA policy in the area of eligibility for Agency financial assistance programs, 5% or less is 
considered a de minimis amount of gross revenue. 
 
28. *Upon further consideration this was revised; see: #37 above Eligibility > All Applicants.  

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29. Are eligible entities owned by public universities, including municipally-owned colleges, 
considered government-owned eligible entities for the SVOG program? 
Yes. Eligible entities owned by public universities will be subject to all the same restrictions and 
exceptions as other government-owned entities.  
 
30. If a university owns and operates two eligible entities that are not separate legal entities from 
the university, but are managed by two different university departments with their own budget 
lines and professional staffing (though their budgets roll up into the larger university system 
budget and staff members are university employees), may the two eligible entities each apply 
for an SVOG if they meet all the required criteria? 
Only if it is a public university. If the university is a private institution, it would be subject to the 
restriction against the submission of multiple applications under a single EIN. In that case, both 
entities would have to be combined into a single application submitted under the university’s EIN. 
 
31. If an entity receives state funding that originated from the federal government, does this count 
toward the 10% eligibility threshold for revenue from the federal government? 
Yes, unless that funding originated as federal disaster assistance. 
 
32. What types of tribal government-owned entities are eligible to apply? 
Tribal-owned museums are eligible for SVOGs, consistent with the language Congress used in writing 
the Economic Aid Act. 
 
33. Because government-owned eligible entities generally operate as divisions of tribal, state or 
local governments and do not have their own EINs or separate legal existence, will the SBA look 
to the governmental owners of such entities for purposes of determining an applicant’s 
principal business activity just as it will with privately-owned eligible entities that use a parent 
company’s EIN? 
No, the SBA will treat these entities separately in reviewing their SVOG applications to ensure 
Congress’ intent to have these funds available to government-owned cultural institutions. The SBA 
will confine its examination of the principal business activity of a government-owned eligible entity 
to the operations of that entity itself and not more broadly consider the operations of its government 
owner, even where the entity uses the government owner’s EIN.  
 
34. Are government-owned eligible entities able to receive SVOGs during the first or second priority 
periods? 
No. Congress designed the first and second priority periods to assist the eligible entities that have 
faced the most significant losses while having limited means to make up for lost revenue. Tribal, state 
and local governments have access to taxpayer funds and other resources which private individuals 
or organizations lack.  
 
35. *Are performing arts groups like choirs, dance companies, etc. eligible for SVOG awards? 
Yes, if they can meet the definition of a performing arts organization operator and all the relevant 
eligibility criteria, such groups would be eligible for an SVOG. 
  
36. *If an entity has no staff or payroll does it qualify for the program? 
Yes. For example, an entity such as a promoter or talent representative that operated as a sole 
proprietorship or single member LLC with no employees could be eligible for an SVOG. In such a case, 

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it would use its SVOG funding for non-payroll costs such as the payment of rent, utilities, scheduled 
debts, maintenance fees, taxes, etc. 
 
37. *If an SVOG related business was previously owned or operated by an ineligible entity (for 
example, a movie theatre owned by a national chain listed on a stock exchange) but has since 
been sold or otherwise transferred to an owner or operator that does meet the eligibility 
criteria could the transferred business serve as the basis for, or be included in, an SVOG 
application? 
Yes. The SBA will determine SVOG eligibility as of the date an entity submits its application for the 
program. The fact that a venue, theater, etc. was previously owned or operated by an ineligible 
organization will not affect an applicant’s eligibility for an SVOG. 
Museum or Movie Theatre Operator 
1. Is a museum or movie theatre with a multipurpose room with movable seating eligible to apply? 
No. The Economic Aid Act specifically requires fixed seating for qualifying amphitheaters of museums 
and motion picture theatre operators and makes no allowance for temporary, removable, modular, 
convertible, or other non-fixed seating arrangements. As such, museums and motion picture theatre 
operators cannot satisfy this requirement with other forms of seating. NOTE: There is no fixed seating 
requirement for other types of eligible entities. 
 
2. Is a museum or movie theatre with outdoor fixed seating eligible to apply?  
Yes. The Economic Aid Act does not require qualifying venues to be indoors. If the venue meets the 
applicable eligibility requirements, it should be eligible to apply for an SVOG. 
 
3. Is a museum partially funded with state dollars eligible to apply?  
Yes. While there are specific eligibility rules for entities owned by state or local governments, the 
receipt of funding from a state government does not affect its eligibility. 
 
4. Is a drive-in movie theatre without fixed seating eligible to apply?  
No. Per the Economic Aid Act, a motion picture theatre operator must have at least one auditorium 
with a motion picture screen and fixed audience seating, so a drive-in movie theatre is not eligible to 
apply for an SVOG.  
 
5. Will the SBA consider programming in museums’ seasonally-operated outdoor amphitheaters 
provided regularly during when outdoor amphitheaters are open to be regular programming? 
Yes. If a seasonally-operated outdoor amphitheater meets the standard of hosting an average of 4 
events per month over the course of a year, the SBA may consider the museum to have provided 
regular programming. For example, a museum with an outdoor amphitheater that is open 6 months 
of the year and provides daily programming during that seasonal operation would meet the regular 
programming standard because it had an average of 15 events per month over the course of a year of 
operation (182 events per year divided by 12 months equals an average of 15 events per month). 
 
6. If a museum has more than one qualified auditorium, theater, or lecture hall, does regular 
programming need to occur in each, or is it sufficient to have regular programming across all 
the qualifying presentation spaces?   
A museum may aggregate programming across all such spaces for purposes of meeting the regular 
programming requirement rather than looking at each qualifying presentation space individually if a 
museum has multiple qualifying presentation spaces (auditoriums, theaters, or performance or 

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lecture halls). 
 
7. What happens if a motion picture theatre is owned by one entity, but operated (managed) by a 
separate entity? Are both entities eligible for an SVOG in such a case?  If so, what will the earned 
revenues of the two companies be based upon?  
Yes. Under the Economic Aid Act, owners and operators of motion picture theatres are considered 
eligible entities. In cases where both the owner and the operator of a qualifying motion picture 
theatre are awarded SVOGs, each will base its earned revenues upon its share of those payments 
received as a condition of its ownership or operation of the motion picture theatre (e.g., space rental, 
ticket sales, management fees, digital projection reimbursements, and other non-gratuitous 
payments or transfers) as allocated by contract, lease, or other formal legal agreement. In such cases, 
all earned revenues and claimed grant expenses must be tracked and accounted for separately to 
avoid any overlap or double-counting. 
 
8. Is a landlord who owns a shopping center that includes a movie theatre eligible to apply for an 
SVOG given they ‘own or operate’ an eligible motion picture theatre?   
No. Because a shopping center owner’s principal business activity would most likely be owning or 
operating a shopping center rather than owning or operating a motion picture theatre, it is doubtful 
it would be eligible for an SVOG. 
 
9. *Upon further consideration this was revised and combined with a similar question: #37 above 
Eligibility > All Applicants.  
 
10. Could a company that operates multiple movie theatres with the same Employer Identification 
Number on Feb. 29, 2020, obtain separate EINs for each movie theatre after that date to have 
those theaters considered separate entities consistent with SBA’s treatment of ownership 
transfers executed after Feb. 29, 2020? 
No. Because these movie theatres were not eligible entities on their own on or before Feb. 29, 2020, 
legal status changes after that deadline cannot be treated the same as ownership changes of eligible 
entities made after Feb. 29, 2020. Under the Economic Aid Act, a person or entity must have been an 
eligible entity as of Feb. 29, 2020, to qualify for an SVOG. 
 
11. To qualify as regular programming, does the programming provided in a museum’s theater 
need to be ticketed and open to the general public?  
No. To qualify as regular programming, events held in a museum’s theater or lecture hall do not need 
to be ticketed or open to all museum attendees. 
 
Live Venue Operator or Promoter 
1. Is a wedding/event venue eligible to apply? 
It is not likely. Per the Economic Aid Act and specific eligibility criteria applying to Live Venue 
Operators, it appears wedding venue operators would likely fail to meet multiple requirements (for 
example: sale of tickets, promotion of events to the public, defined audience and performing space, 
lighting rig, sound mixing equipment, employment of sound engineers, stage managers box office 
managers, etc.). 
 
2. Is a sports stadium or venue used for concerts and other live, non-sport performances eligible 
to apply? 

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It is not likely. While sports are not a form of performing art, if the operator of a sports stadium or 
similar athletic arena can meet the statutory definition of an eligible entity under the Economic Aid 
Act, including the requirement that its principal business activity must be the organization, 
promotion, management, or hosting of live concerts, comedy shows, theatrical productions or other 
events by performing artists, it should be eligible to apply for an SVOG.  
 
3. Is a restaurant that features live music eligible to apply? 
No, if the principal line of business is restaurant operation rather than live venue operation, the 
business would not be eligible to apply for an SVOG.  
 
4. Is a dinner theatre eligible to apply? 
It is possible. A dinner theatre could qualify if its principal business activity is the organization, 
promotion, management, or hosting of live concerts, comedy shows, theatrical productions or other 
events by performing artists, rather than restaurant operations, and meets all other applicable 
eligibility criteria. 
 
5. Is a performing arts center owned and operated by a government, state college (as a college 
department) eligible to apply? 
Yes. State, county, and municipal government-owned entities, including colleges, may be eligible to 
apply for an SVOG. 
 
6. Is a company that uses 1099 (independent contractor) workers/talent (vs. W2) eligible to apply?  
Yes. Per the Economic Aid Act, payments made to independent contractors as reported on an entity’s 
Form-1099 are an allowable use of grant funds. As such, an entity that used independent contractors 
would be eligible to apply for an SVOG. 
 
7. We hire a lot of independent contractors for events; as a subsidiary service provider for or at 
live venues and events, does this fit the talent placement eligibility? 
No, this does not fit the definition of a subsidiary, but rather defines a secondary service provider. 
The SBA does not believe a secondary service provider supplying support to qualifying venues meets 
any eligible entity definition. 
 
8. Is a theatrical production management business with revenue generated by the production 
management eligible to apply (under the talent representative definition)?  
It is possible. A theatrical producer may be eligible to apply for an SVOG even if less than 70% of its 
revenue came from cover charges or ticket sales. Under the Economic Aid Act, it also may be eligible 
to apply if, as its principal business activity, it has production tickets available for public purchase an 
average of not less than 60 days before the performance date. 
 
9. Is a talent agency that books actors at live venues, but does not operate a live venue, eligible to 
apply? 
Yes. A talent agency is eligible to apply if 70% of its operations is managing, booking or representing 
performers who appear primarily at live venues. If it is less than 70%, it is not eligible to apply for an 
SVOG. 
 
10. Does a ticket broker or reseller qualify as a live venue operator or promoter?  
No. The Economic Aid Act’s live venue operator or promoter definition requires an entity to have as 
its principal business activity either: (1) Organizing, promoting, producing, managing, or hosting 

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events by performing artists for which admission fees are charged and performers are paid based on 
a percentage of sales, a guarantee, or other mutually beneficial formal arrangement; or (2) Publicly 
selling tickets on average 60 days in advance of performing arts events for which performers are paid 
based on a percentage of sales, a guarantee, or other mutually beneficial formal arrangement. While 
ticket brokers or resellers do deal in tickets to performing arts events and may do so 60 days in 
advance, performers are not paid from these transactions as the SBA reads the second prong of the 
live venue operator or promoter definition to require. Further, as one of their commonly used names 
implies and because they operate in the aftermarket, ticket brokers or resellers may be viewed not as 
being principally in the business of selling tickets, but instead as being principally in the business of 
reselling them. As such, ticket brokers or resellers do not meet the criteria found in the definition of 
live venue operator or promoter.  
 
11. What criteria will the SBA apply when determining whether a particular form of live 
entertainment constitutes a performing arts event for an SVOG? 
The SBA believes performing arts as related to the SVOG program means events such as musical 
concerts, comedy shows, theatrical productions, dance performances, or other live renderings of 
similarly artistic works. This is based on review of the Economic Aid Act text, SBA’s consultation with 
other Federal agencies with area expertise and examination of definitions of what constitutes the 
performing arts under Federal law.  
 
12. Is an air show operator eligible to apply? 
No. The live venue operator or promoter definition under the Economic Aid Act requires an entity to 
either put on performing arts events at qualifying venues or sell advance tickets to performing arts 
events at qualifying venues. While an air show is a form of live entertainment, in SBA’s opinion it does 
not constitute a performing art. As such, air show operators do not qualify as live venue operators or 
promoters. 
 
13. If a venue’s box office is staffed by volunteers is it eligible to apply?  
Yes. Among the criteria included in the live venue operator or promoter definition is a requirement 
that a qualifying venue must engage at least one individual to perform at least two of the following 
roles: sound engineer, booker, promoter, stage manager security personnel, and box office manager. 
The Economic Aid Act does not reference any hired box office staff other than a box office manager 
and does not absolutely require even that position. As such, the use of volunteers to staff a venue’s 
box office would not preclude it from being eligible to apply for an SVOG. 
 
14. Is a theatrical producer that stages performances in multiple venues eligible to apply? 
Yes. Provided the venues a theatrical producer uses meet the qualifications listed in the Economic Aid 
Act (e.g., defined performance and audience spaces, sound mixing equipment, a lighting rig, etc.) 
there is no limit upon the number of venues at which a producer may host events. 
 
15. The Economic Aid Act specifies artists performing at qualifying venues must be paid fairly and 
not “play for free or solely for tips, except for fundraisers or similar charitable events.” Would 
nonprofit organizations that host performances which include volunteer choruses and/or 
student performers be able to meet this requirement?  
Yes. Provided the events a nonprofit live performing arts organization stages are produced and 
managed primarily by paid employees, the use of volunteers in the production casts would not 
disqualify it. 
 

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16. Does a live venue operator who qualifies as an “eligible person or entity” remain eligible for an 
SVOG if that live venue operator has a minority investor (less than 51% ownership) that has 
more than 500 employees, locations in 11 or more states, and locations in 2 or more countries? 
Is that the only ownership/control-related grounds for disqualifying someone? 
Yes. The Economic Aid Act speaks only of majority ownership and control in the context of the 
disqualifying conditions related to being listed on a stock exchange or to the geographic scope of 
operations and number of employees. There are no other control requirements in the statute. 
 
17. Does a free music festival that earns revenue through sales of merchandise and concessions but 
does not charge admission meet the requirements of either an eligible entity or qualifying 
venue? 
No. Under the Economic Aid Act, a live venue operator must, among other things, apply a cover 
charge through ticketing or front door entrance fee or sell tickets an average of at least 60 days in 
advance of performances to be eligible for an SVOG. Additionally, to serve as a qualifying venue, a 
location must impose a paid ticket or cover charge to attend most performances.  
 
18. If an entity is currently presenting only live online shows, does that count as currently in 
business? 
Yes. The SBA will consider venues operating in an online-only shows capacity as currently in business 
if the entity meets the eligibility criteria for business operations prior to Feb. 29, 2020. 
 
19. If an entity has a performance/music group (e.g. jazz orchestra) that goes on tour and is paid 
performance fees for playing in other venues, can these performance fees be counted as part of 
the earned revenues to meet the threshold of not less than 70% of the earned revenue must 
come from live event cover charges or ticket sales, production fees or reimbursements, 
nonprofit educational initiatives, or the sale of food, beverages, or merchandise? 
Yes. These fees should be included in the earned revenue for all SVOG program purposes. 
 
20. For an entity that stages both free and ticketed performing arts events, do food and beverage 
and merchandise sales derived from the free events count toward the requirement that not less 
than 70% of earned revenue must come from live event cover charges or ticket sales, 
production fees or reimbursements, nonprofit educational initiatives, or the sale of food, 
beverages, or merchandise? 
Yes, assuming there was a paid ticket or cover charge required to attend most of the performing arts 
events staged by the entity. 
 
21. If a live venue operator, theatrical producer, promoter, or live performing arts organization 
operator does not offer tickets 60 days in advance will that make them ineligible? 
Not necessarily. The requirement that such entities offer tickets for purchase by the public an 
average of at least 60 days in advance of performing arts events is just one option for proving SVOG 
eligibility. The other option for such entities is to show that at least 70% of their earned revenue 
comes from cover charges, ticket sales, production fees or reimbursements, nonprofit educational 
initiatives, or sales of food, beverages, or merchandise derived from performing arts events. 
 
22. If a nonprofit operates a theatre and stages live ticketed performances with the bulk of its 
revenue coming from educational programs where the performers are not paid by ticket sale 
revenue or cover charges, but as educators, is it eligible?  

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It depends on whether the programs could be considered performing arts events and whether the 
nonprofit can meet either the earned revenue percentage or advance ticket sales eligibility 
requirement. 
 
23. If an individual or entity owns a venue under one LLC (Venue LLC) and operates it under another 
LLC (Operator) can it apply for an SVOG under one LLC and use the funds to pay costs associated 
with both LLCs? For example, if Venue LLC received an SVOG award could it pay salaries 
incurred under Operator LLC, which employs the staff that run the events at the venue, as well 
as paying the mortgage and utility bills it owes? 
No. Because neither LLC owns the other, neither LLC could be bundled into an SVOG award held by 
the other. However, if the individual or entity which owned the two LLCs received an SVOG award 
under its own name, they could include the revenues and costs of both LLCs in a combined grant. 
Two or more separate legal entities can only be included in one SVOG award if one of them owns at 
least 51% of the others or if a single entity or individual owns at least 51% of all of them. In such a 
case, it would have to be the entity or individual that is the majority owner which applied for and 
received the SVOG award. 
Talent Representatives 
1. Are both agents and managers considered talent representatives with respect to SVOGs? 
Yes. Under the Economic Aid Act talent representatives can be agents and/or managers for 
musicians, comedians, actors, or similar performing artist. 
Definitions 
1. How is “principal business activity” being defined? 
The SBA is drawing from its years of experience in ascertaining a firm’s primary industry under the 
SBA size regulations (13 C.F.R. § 121.107) to define “principal business activity.” To determine a given 
firm’s principal business activity, the SBA will consider the distribution of an entity’s receipts, 
employees and costs of doing business among the different lines of business activity in which its 
business operations occurred for the most recently completed fiscal year. An entity's principal 
business activity will be the one in which it has the greatest combined amount of revenues, expenses, 
employees and work hours, assets, contracts, and other business activity as compared to all its other 
lines of business. The SBA may also consider other factors, such as the distribution of patents, 
contract awards, and assets, as appropriate. 
 
2. How is “majority owned or controlled” being defined? 
Across its various programs, the SBA defines majority ownership and control to mean that at least 
51% of the ownership interests in an entity (regardless of its legal structure) are held by a single 
individual or entity. 
 
3. How is “fixed seating” being defined as a requirement for museums and movie theatre 
operators? 
Fixed seating is seating permanently fixed to the floor or ground or which is so heavy or cumbersome 
as to make removing it impractical, per the Economic Aid Act. Where fixed seating is required for a 
museum auditorium or movie theatre, a majority of the seating provided in that space must meet the 
definition of fixed seating. 
 
4. How is “museum” being defined?   

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A museum is a public, tribal, or private nonprofit agency or institution organized on a permanent 
basis for essentially educational, cultural heritage, or aesthetic purposes, that uses a professional 
staff, owns or uses tangible objects, cares for the tangible objects, and exhibits the tangible objects to 
the public on a regular basis. This includes aquariums, arboretums, botanical gardens, art museums, 
children’s museums, general museums, historic houses and sites, history museums, nature centers, 
natural history and anthropology museums, planetariums, science and technology centers, 
specialized museums, and zoological parks. The SBA has based this definition on a few sources, 
including the Economic Aid Act, which directs the SBA to define museum based on 20 U.S.C. § 9172, 
as well as guidance published by the Institute of Museum and Library Services.  
 
5. How is “regular programming” being defined as a requirement for museums? 
While it may vary depending on the circumstances, generally the SBA is defining regular 
programming to mean programming provided on an ongoing and near-continuous basis of an 
average of at least four times a month over the course of a year in its qualifying theatre, lecture hall, 
or similar venue. 
 
6. Would heavy bleachers pushed back against the wall when not in use but never removed from a 
theater qualify as fixed seating? 
Yes. Any cumbersome seating not easily or regularly removed from a theater will be considered fixed. 
 
7. How is “promoter” being defined? 
A promoter is an entity or individual that organizes live events by performing artists and carries out 
tasks (other than as a vendor or service provider) such as renting a performance site, contracting with 
artists or a production company for the performance, marketing events, and collecting gate receipts. 
A promoter must have: (1) a profit (net income or loss) interest in the live event’s presentation; and 
(2) sole or joint rights to control the financial terms of the live event’s presentation, use of the venue, 
and/or marketing of the event. Promoters may own and/or operate live venues or contract for space 
and may include festival promoters or the promotion of live performing arts events at outdoor, 
festival spaces that have all the required characteristics of a qualifying venue. 
 
8. How is “theatrical producer” being defined? 
A theatrical producer is an eligible individual or entity (including the entity that employs the 
performers in a theatrical production) which has the responsibility for creating, producing, or 
operating live theatrical productions and that have either a non-passive profit (net income or loss) 
interest in a theatrical production (other than as a vendor or service provider) or sole or joint rights to 
control a theatrical production. Theatrical producers are responsible for functions such as 
negotiating debt or equity financing with lenders or investors, financial and tax reporting, and closing 
the production. The term “theatrical producer” does not include individuals or entities that provide 
financial support for a theatrical production without either a non-passive profit (net income or loss) 
interest or the control described above.  
 
9. How is “performing arts organization operator” being defined? 
A performing arts organization operator is any entity (including a theatrical management business) 
which meets the criteria established under the Economic Aid Act and whose principal business 
activity is to create, produce, perform, and/or present live performances for audiences in qualifying 
venues, including amphitheaters, concert halls, auditoriums, theatres, clubs, festivals, and schools. 
 
10. How are “cover charges” being defined as a requirement for live venue operator or promoter? 

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The SBA defines “cover charges” to encompass front door entrance fees, food or beverage 
minimums, or other similar charges required to gain admission to a venue, whether collected via 
ticket sales, addition to a tab, or direct payment.  
 
11. How is “defined performance space” being defined for live venue operator or promoter? 
A defined performance space is the distinct physical space reserved solely for the presentation of a 
performance, such as drama, music, dance, comedy, or other live performing arts activity. 
 
12. How is “defined audience space” being defined as a requirement for live venue operator or 
promoter? 
The defined audience space is the distinct physical area in which the audience experiences the 
performance for qualifying venues that host live performing arts events (not including museums and 
movie theatres).  
 
13. How is “mixing equipment” being defined as a requirement for live venue operator or 
promoter? 
Mixing equipment is a sound mixer that mixes two or more audio signals together, provides one or 
more output signals, allows adjustment of levels and enhancement of sound with equalization and 
effects, and creates monitor feeds.  
 
14. How is “public address system” being defined as a requirement for live venue operator or 
promoter? 
A public address system is an electronic system with at least one microphone, amplifier, and 
loudspeaker which increases the volume of a human voice, musical instrument, or other acoustic 
sound source or recorded sound or music. 
  
15. How is “lighting rig” being defined as a requirement for live venue operator or promoter? 
A lighting rig is a structure that holds lights in place for illuminating a stage or other defined 
performance space. 
 
16. How is “sound engineer” being defined as a requirement for live venue operator or promoter? 
A sound engineer is an individual who helps to produce a live performance by managing or 
enhancing source levels of sound, including by equalization and audio effects, mixing, reproduction, 
and reinforcement of sound. 
 
17. How is “booker” being defined as a requirement for live venue operator or promoter?  
A booker is an individual (e.g. a talent buyer) who books bands or other performing artists for venues 
and fields inquiries from performing artists and performing and their agents or representatives. 
 
18. How is “stage manager” being defined as a requirement for live venue operator or promoter? 
A stage manager is an individual who supervises the performance space and physical aspects of a 
production and oversees the performance space while a production is in progress.  
 
19. How is “security personnel” being defined as a requirement for live venue operator or 
promoter? 
Security personnel are individuals hired for a live event to provide protection and aid for attendees, 
performers, and venue employees. Duties of security personnel may include monitoring the event, 
maintaining order, escorting attendees out of events, and suppressing disturbances. 

15 | P a g e  
 
20. How is “box office manager” being defined as a requirement for live venue operator or 
promoter?  
A box office manager is an individual who is responsible for overseeing the sale of all tickets or receipt 
of admission fees, and may include the task of ensuring the security of payments exchanged. 
 
21. How is “being paid fairly” for a performer being defined?  
Being paid fairly means that event performers are paid in an amount based on a percentage of sales, 
a guarantee (in writing or standard contract), or another mutually beneficial formal agreement. 
Venues may also compensate performers by sharing an agreed upon portion of revenues received 
through door fees along with drink or meal tickets that may fall below 1099 reporting requirements.  
 
22. How is “talent representative” being defined? 
A talent representative is an agent or manager for whom no less than 70% of their business 
operations (as measured with reference to their overall revenues, costs, devotion of time, contracts, 
and other indicia of business activity) involves the representation or management of two or more 
artists or entertainers. These operations must involve booking or representing musicians, comedians, 
actors, or similar performing artists primarily at live events staged in venues or at festivals in 
exchange for compensation founded on the number of tickets sold or a similar basis (including flat 
fee guarantees). 
 
23. How is “disaster assistance” being defined and does it include stimulus checks, unemployment 
insurance payments, loan forgiveness, or other forms of debt relief? 
For purposes of the SVOG, if such assistance originated from funding provided under either the 
Stafford Act (41 USC 5121 et seq.) or the CARES Act (Pub. L. No. 116-136) it would be considered 
federal disaster assistance (even if it was delivered by a tribal, state or local government) and 
excluded from an eligible entity’s gross revenue. If the funding came from any other source it would 
have to be included in gross revenue. In no event would assistance of this sort be considered earned 
revenue. 
 
24. How are “worker protection expenditures” being defined? 
Under the Economic Aid Act, worker protection expenditures are defined to mean an operating or 
capital expenditure which helps an entity adapt its business activities to comply with guidance or 
requirements issued by a Federal, state, or local health authority related to the maintenance of 
standards for sanitation, social distancing, or any other worker or customer safety requirement 
related to the COVID-19 pandemic. Such expenditures must be incurred between March 1, 2020, and 
the date on which the COVID-19 national emergency declared by the President expires. Worker 
protection expenditures may include the purchase, maintenance, or renovation of items such as a 
drive-through window facility; a ventilation or air filtration system; a physical barrier such as a sneeze 
guard; an expansion of additional indoor, outdoor, or combined business space; an onsite or offsite 
health screening capability; and personal protective equipment. 
 
25. How is the phrase “capital expenditures related to producing a theatrical or live performing 
arts production” being defined for the cap on allowable expenses? Does this refer to build-outs 
for a venue for the presentation of live performances in general, or just to those capital 
expenditures related to one particular production? 
The SBA interprets the restriction against SVOG recipients primarily using grant funds to pay 
advertising, production transportation, and capital expenditures related to producing a theatrical or 

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live performing arts production, concert, exhibition, or comedy show as referring to all such costs in 
general rather than those relating only to one specific production or show. 
Application 
1. What can an entity do to get ready to apply? 
As the SBA works on building the application platform, it would be in your best interest to reference 
the SVOG Eligibility Requirements and register for a DUNS number so you can then register in the 
System for Award Management (SAM.gov). Also, gather documents that demonstrate your number of 
employees and monthly revenues so you can calculate the average number of qualifying employees 
you had over the prior 12 months. Next, determine the amount of gross revenue loss you suffered 
between 2019 and 2020 to see if you qualify for one of the priority periods. Lastly, calculate the extent 
of gross earned revenue loss you experienced between 2019 and 2020 to see if you qualify for the 
non-priority period. This and additional information such as floor plans, contract copies and other 
evidence will be needed to apply for an SVOG and can be found in the SVOG Preliminary Application 
Checklist (this is a preliminary list and not all-inclusive). 
  
2. Must applicants register in the System for Award Management (SAM.gov) or can they use other 
identifiers like Individual Taxpayer Identification Numbers or Employer Identification Numbers 
to apply for an SVOG?  
SVOG applicants need to register with the federal government’s SAM at www.SAM.gov to apply and 
cannot use an ITIN, EIN, or other means of identification or registration. Interested parties are 
encouraged to obtain a Dun and Bradstreet (DUNS) number (a prerequisite for SAM registration) as 
soon as possible. With a DUNS number, interested parties then should immediately begin registering 
in SAM.gov, as the SAM registration may take up to two weeks once submitted.  
 
3. When will SVOG applications open? 
The SBA expects open SVOG applications on April 8, 2021. We encourage you to stay up to date by 
frequently visiting www.sba.gov/svogrant for information. 
 
4. If an eligible entity is a hybrid nonprofit/governmental entity, should it apply under the 
nonprofit’s name and submit documentation demonstrating the public/private partnership 
aspect of its structure? 
Yes. The SBA agrees that would appear to be the best approach to take under such circumstances. 
 
5. If all SVOG program funds are expended during the program’s initial phase, what will the SBA 
do with regard to making supplemental awards? 
If all SVOG funding is expended during the program’s initial phase (or funds run out before the SBA 
can make fully funded supplemental awards to all eligible entities), the SBA intends to issue zero 
dollar ‘placeholder’ supplemental awards that could subsequently be modified to add funds in the 
event Congress appropriates additional monies for the program. Under this approach, an eligible 
entity that received a zero-dollar placeholder grant would still be entitled to the six-month extension 
afforded to recipients of supplemental phase awards. 
 
6. How will capital funds, restricted grants, or investment income affect an entity’s SVOG 
application?  
The SBA will take such financial resources into consideration when the Agency is examining an 
eligible entity’s gross revenue. For example, the SBA will consider such sources of revenue for 
purposes of determining whether an applicant meets the requirement that no more than 10% of its 

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2019 gross revenue came from the Federal government (excluding disaster assistance) or 
determining whether it can demonstrate sufficient gross revenue loss to qualify for one of the priority 
periods. 
 
7. What will be the timeline of distribution for the funds the SBA reserves for the small employer 
set-aside? Will the SBA fund small employer awards only during the non-priority period of the 
Initial Award Phase? 
To ensure the SBA can carry out Congress’ intent that at least $2 billion worth of SVOGs go to small 
employers, the SBA will draw upon the small employer set-aside funds throughout all stages of the 
Initial Award Phase. For example, where an eligible entity qualifies for the First Priority Period also 
qualifies as a small employer, the SBA will fund that grant using monies drawn from the small 
employer set-aside. To better facilitate the SVOG funding to small employers throughout all stages of 
the Initial Award Phase, the SBA is considering using its authority under the Economic Aid Act to set-
aside more than the $2 billion minimum that must be reserved for such purposes. 
 
8. If ownership of an eligible entity was transferred prior to Feb. 29, 2020, could the new owners 
apply for an SVOG and use the revenues reported by the former owner? What about ownership 
transfers that occurred AFTER Feb. 29, 2020 if the entity had been operational on Feb. 29, 2020? 
Yes. Except where the new owner has any of the disqualifying characteristics specifically enumerated 
in the Economic Aid Act (either being itself or being majority owned and controlled by a firm listed on 
the stock market, that had more than 10% of its 2019 gross revenue come from Federal funding, that 
owns or operates eligible entities in more than 1 country and more than 10 states and that employs 
more than 500 people, or which presents sexually prurient live performances or derives more than de 
minimis gross revenue from the sale of sexually prurient material), the SBA will consider the new 
owner of an eligible entity to have stepped into the shoes of the prior owner for purposes of 
qualifying for the SVOG program. In the event of such a transfer, SBA will permit the new owner to use 
the prior owner’s revenues as its own if the transferred entity was operational on Feb. 29, 2020, 
regardless of the date of the sale. 
 
9. How did the SBA determine what “revenue” to consider for establishing priority period 
eligibility? 
Congress simply referenced “revenue” for the SVOG priority periods in the Economic Aid Act. General 
rules of statutory interpretation require an agency to give meaning to every word where possible and 
apply the word’s ordinary meaning. In the legislation, Congress used “revenue” in setting forth the 
priority periods, not “earned revenue” and specifically used the term “earned revenue” in other 
areas, illustrating its understanding of a distinction between the two terms and the ability to use the 
limitation where Congress deemed it appropriate. 
 
10. For determining applicant eligibility for priority periods, how is “revenue” being defined? 
The SBA will use gross revenues to determine how an entity qualifies for one of the priority periods.   
 
11. If the entity’s SVOG application is declined, will an SVOG applicant be able to appeal or request 
a reconsideration of the decision? 
No. Given SBA’s history of never offering appeals for denied grant applicants in any other program 
and the volume of expected SVOG applicants, the SBA will not institute an appeal process for denied 
SVOG applicants. Furthermore, given the potential for demand for SVOG funding to outpace supply, 
establishing an appeal process for denied applicants might further run the risk of tying up funding 
that could instead go to eligible applicants in dire need of timely assistance. 

18 | P a g e  
 
12. Can affiliated entities use the same SAM registration to apply for up to five SVOGs or should 
each affiliated entity that desires to receive a SVOG individually obtain its own SAM 
registration? 
With the exception of tribal, state or local government-owned eligible entities, each entity applying 
for an SVOG must use its own SAM registration. 
 
13. If an entity is disregarded for tax purposes and doesn’t file its own tax returns, should the 
disregarded entity apply for an SVOG or should the entity that files tax returns apply for the 
SVOG? 
Assuming both entities have their own separate legal existence and each meets the eligibility 
requirements under the Economic Aid Act, either could apply for an SVOG. 
 
14. Would an individual or business face any penalties for applying for an SVOG if it is later deemed 
to be ineligible for the program? 
If an entity submits an honest, good faith application for an SVOG but is denied funding for failure to 
meet one or more eligibility requirements, there would be no penalty and it would be free to apply 
for other programs they may qualify for. If, however, an entity makes material misrepresentations on 
its application as part of a fraudulent effort to obtain SVOG funding, it will have committed an act of 
perjury and be subject to various civil and criminal penalties, as well as potentially being debarred 
from doing business with the Federal government. 
 
15. What are the reasons for which an entity’s SVOG application might be denied? 
The SBA will reject an SVOG application where an entity: (i) submits an incomplete application; (ii) is 
attempting to commit fraud against the Federal government; (iii) fails to meet the definition of an 
eligible entity; (iv) lacks the required level of revenue loss; (v) possesses one or more of the 
disqualifying conditions identified in the Economic Aid Act; is part of a group of affiliated entities that 
currently has 5 active SVOG applications still pending; or (vi) all available SVOG funding has been 
exhausted. 
 
16. How will the SBA determine the amount of SVOG funding to award an eligible entity that started 
business operations in January or February 2020 and has no 2019 revenues? 
Like the manner in which a grant is determined for a firm that did not start in business until partway 
through 2019, the SBA will award an SVOG applicant that began business operations in January or 
February 2020 the lesser of the average monthly earned revenue for each full month it was in 
business in 2020 multiplied by 6 up to a maximum of $10 million.  
 
17. Will the SBA require audited financial statements as part of an SVOG application? 
No, an audited financial statement is not required to apply for an SVOG award. However, where a for-
profit SVOG grantee expends more than $750,000 in Federal funding in one fiscal year it will have the 
option of either providing a Single Audit Act audit or submitting an audited financial statement for 
that fiscal year. The SBA will direct grantees that expend more than $750,000 in federal financial 
assistance in one fiscal year to submit their Single Audit or audited financial statement during the 
post-award oversight, monitoring, and audit phase that SBA will conduct after SVOG awards have 
been issued. 
 
18. Will applicants be able to save their applications while in progress and then return to finish and 
submit them later? 

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Yes. Applicants will be able to save their application at any point prior to submission and then resume 
where they left off.  
 
19. If someone submits an incomplete application will they have an opportunity to complete it? 
There will not be an opportunity to submit an incomplete application, as the online application 
system the SBA is developing will only allow complete applications to be submitted.  
 
20. If a grant award is disbursed in installments, will the SBA obligate the funds for the award all at 
once or will the obligation also be done in installments? 
The full amount of each SVOG will be obligated when an award is issued, regardless of whether it will 
be disbursed in installments. This will ensure that each SVOG is fully funded. 
 
21. How will the SBA prioritize applications within each priority period? Will it be on a first-come, 
first-served basis or will it be based on the size of the percentage of revenue loss suffered? 
Within each priority period and the non-priority period, the SBA will process applications in the order 
in which they were received. 
  
22. What entity information submitted as part of the SVOG application will be disclosed to the 
public? 
The SBA will exclude any personally identifiable information (such as a Social Security Number) or 
confidential business information about the entity (such as financial data) from disclosure under the 
Freedom of Information Act, though such information may be shared with SBA’s Office of Inspector 
General, the Government Accountability Office, and/or members of Congress in response to a proper 
and official request. However, if an entity is awarded an SVOG, the SBA must report the amount and 
the name and address of the entity (or person’s name and address if applied as an individual), in the 
publicly searchable database USASpending.gov. To help ensure all confidential business information 
is properly excluded, the SBA recommends marking any documents submitted that contain such 
information with the phrase “Confidential Business Information.” As an alternative to marking the 
document itself, the annotation “Contains Confidential Business Information” can be included in the 
file name. 
 
23. Will an SVOG recipient have to report the grant to the IRS as taxable income? 
No. The Economic Aid Act specifies that SVOGs “shall not be included in the gross income of the 
person that receives such grant.” 
 
24. Will an SVOG recipient also be eligible for a grant under the Restaurant Revitalization Fund? 
No. The American Rescue Plan Act details SVOG recipients are ineligible to apply for assistance under 
the Restaurant Revitalization Fund. 
 
25. Will venues that lack box office reports to submit with their applications (whether because they 
are used by outside promoters or because they are smaller operations that retain fewer 
records) be allowed to present other types of evidence that they host shows regularly, such as 
the agreements with outside promoters? 
Yes, other types of evidence such as those described should suffice.  
 
26. Many venues have permanent infrastructure for hanging sound and lights as opposed to owning 
in-house systems because some artists have their own equipment hung for every show. For acts 
without their own gear, the venues rent equipment. Also, some venues may have sound 

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systems permanently installed but do not have the receipts or the itemized insurance 
statements showing insurance coverage. Can such venues satisfy the “proof of a sound system” 
requirement through other types of evidence such as rental receipts, photographs, tech 
specification sheets, production reimbursement receipts, etc.? 
The SBA agrees that the suggested alternate types of evidence would be adequate proof that a venue 
possesses the required equipment.  
 
27. What documentation must a talent representative provide to verify they meet SVOG eligibility 
requirements? 
A talent representative applicant must provide a list of performing artists they booked or managed in 
2019 that includes the venues for which they were contracted to perform, the city and state of the 
venues and the performance dates. They must also submit a current roster of performing artists 
which they book or manage that primarily work in live venues or festivals. This roster must also either 
appear on the applicant's website or be published in print or online in an industry-recognized trade 
publication registry. A talent representative applicant must provide fully executed contractual service 
agreements (excluding rider provisions) between the talent representative and two artists, or signed 
statements from two artists certifying the applicant represented them for live performances in 2019 
and 2020. A talent representative must also provide fully executed contracts for live performances 
that took place in a venue or at a festival in 2019 and 2020 for two artists the applicant managed or 
booked.  
 
28. For the list of current employees required on the applicant checklist, is “current” defined as 
“the date of grant application submission”?  
 Yes. However, if the applicant furloughed everyone because they are shuttered, then the most recent 
employee list prior to the venue being shuttered will be adequate. 
 
29. Should a non-profit provide the ID of its president/CEO to meet the applicant checklist 
requirement of a photocopy of the applicant’s ID?   
A non-profit should provide the ID of the principal officer of the entity submitting the application, as 
the photocopy of the applicant’s ID is a requirement that applies to all applicants. 
 
30. If applying under one Employer Identification Number for multiple theatre locations, should 
documentation required in the application checklist (pictures of the layout, projection booth, 
box office reports, marketing media, etc.) be provided for each location?    
Yes. The required information must be provided for each location covered by an SVOG application. 
 
31. Does the applicant need to submit state tax returns for application or just federal tax returns? 
Do the tax returns need to be signed and dated by the applicant?  
Only Federal tax returns are required; they must be signed and dated copies of returns submitted to 
the IRS. 
 
32. If an entity has submitted its SAM.gov registration, but the registration is not yet officially 
activated, can the entity still apply? 
Yes. The requirement is that an entity must be registered in SAM.gov. In the SVOG application, the 
entity will have to attest that it has submitted its SAM.gov registration to apply. 
 
33. How can an entity check the status of its SAM.gov registration? 
1. Go to https://www.sam.gov 

21 | P a g e  
2. Select Log In 
3. Select the Check Status tab in the main navigation 
4. Enter its DUNS Number 
5. Select Search to view status 
 
34. If an entity received PPP loans in 2020 and 2021, does it only need to deduct the 2021 PPP 
amount from the budget prepared for the SVOG application?  
Yes. Any PPP loan received prior to Dec. 27, 2020 does not need to be deducted from an SVOG award, 
even if the organization also received additional PPP loans after that deadline. To note, if a 2021 PPP 
loan applicant is approved for an SVOG before the SBA issues a loan number for the PPP loan, the 
applicant is ineligible for the PPP loan and acceptance of any PPP loan proceeds will be considered 
an unauthorized use. 
 
35. If an entity applied for a PPP loan after the American Rescue Plan Act became law but before the 
PPP application form was updated, is it still eligible for an SVOG even though the PPP 
application included a certification saying the entity would not apply for an SVOG? 
Yes. All recipients of PPP loans are eligible to apply for SVOGs regardless of which PPP form they 
used. 
 
36. Is an entity required to fully fill out the budget section on the application form? 
Yes, each part of the budget section must be complete when preparing the SVOG application or the 
system will not let you advance to the next step. It is understood it may be hard to predict exactly 
what how grant funds will be spent in the future and some variations from the proposed budget can 
be approved post-award. 
 
37. Apart from the Certification of Need, are there other certifications an entity must make to 
receive an SVOG? 
Yes. An entity will be required to submit several certifications and assurances, such as those 
regarding lobbying, suspension and debarment, and drug-free workplaces, as part of its SVOG 
application. Also, the Economic Aid Act requires that if an entity has between 500 and 10,000 
employees and is awarded an SVOG, it must certify it will not break any existing collective bargaining 
agreements during the grant term and for two years thereafter. Such an applicant also must certify it 
will remain neutral in any union organizing efforts throughout the term of the SVOG.  
 
38. For nonprofits that use a fiscal year to file annual Form 990 tax returns, the extended due date 
for 2019 returns may not have yet transpired and 2019 and 2020 tax returns may not have been 
filed; will the SBA accept a 2018 return? 
Yes. Under these circumstances an eligible nonprofit entity may use its 2018 and 2019 tax returns. 
 
39. Will the additional $1.25 billion the SVOG program received under the American Rescue Plan Act 
be administered using the 80/20% allocation between priority and non-periods set by the 
original program legislation, or will all new funding instead be added only to the ‘general 
admission’ phase? 
The additional SVOG funding Congress provided is added to the existing appropriation and the total 
combined amount will be apportioned in accordance with the statutory scheme: 80% will be 
allocated to the first and second priority periods with the remainder reserved for the non-priority 
period. In addition, the SBA will set aside at least $2 billion for SVOGs to small employers.  
 

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40. What practical tips can the SBA share with eligible entities if there are technical issues with the 
portal on April 8?  
Entities should make sure to save frequently, have the SVOG dedicated website – 
www.sba.gov/svogrant - at the ready to refer to the application user guide, the most up-to-date FAQs, 
technical support guidance and the March 30, 2021, application information session (under video 
tutorials) as they go through the application process. 
 
41. What file types will be accepted in the application system? 
The application system will accept files that end in .pdf, .jpg, .jpeg, .doc, docx, .xls, and .xlsx with a 
maximum file size of 35 MB per file.  
 
42. Does an entity need to fill out a separate SF-424B or can it use the Financial Assistance 
Certifications from its SAM.gov registration? 
No. An entity does not need to fill out a separate SF-424B. To reduce burden on grant recipients, 
SAM.gov centrally collects the standard financial assistance certifications and representations during 
registration.  
  
To view or download a copy of your entity's Financial Assistance Certifications, follow these steps: 
• 
Enter https://www.sam.gov in your internet browser’s address bar. 
• 
Select the Search Records tab on the main navigation bar. 
• 
Under Quick Search, enter the unique entity identifier (currently the DUNS Number). 
• 
Select the View Details button on the returned result. 
• 
Select the Reps & Certs link under Entity Registration on the left navigation bar. 
• 
Select the Financial Assistance Certifications Report link to download the grants 
certifications. 
 
43. Re: the need to submit February 2020 ticket reports; many ticket reports list only the dollar 
amount of tickets sold for a performer rather than the actual ticket price because there can be a 
range of ticket prices based on seating area and other criteria, so could an entity submit a 
spreadsheet with a ticket report to outlines the different ticket prices for a show? 
Yes. This would be an excellent option for demonstrating ticket prices and sales. 
 
44. If local orders do not allow an entity to be open to the public, does being “open” or “in 
operation” mean an entity is continuing what business operations it can (e.g. maintaining its 
facilities and preparing to eventually reopen) despite not being able currently to host live 
events?   
Yes. This question is intended to establish whether an applicant entity is either currently in operation 
to the extent that it can be, or that it plans to reopen or be in operation going forward and may thus 
be eligible for SVOG funding. 
 
45. What is required in the Statement of Need certification? 
There is no set format for a Statement of Need certification because every eligible entity’s 
circumstances are different. However, at a minimum the Statement of Need must include a good 
faith certification that the uncertainty of current economic conditions makes a grant necessary to 
support the ongoing operations of the eligible person or entity. In addition, if the entity is currently in 
operation its certification must state that it intends to remain in operation after it receives the grant. 
If the entity is currently shuttered, its certification must include a statement that it intends to reopen, 
along with its estimated reopening date. Finally, all Statements of Need must indicate that the entity 

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was conducting business operations as of Feb. 29, 2020. The following example is provided for 
illustrative purposes: 
“Due to the uncertainty of current economic conditions, a grant is necessary to support the ongoing 
operations of SVOG, Inc., SVOG, Inc. started in business on Jan. 30, 1985, but was forced to close its 
doors on March 15, 2020 due to the pandemic. If it receives a grant, SVOG, Inc. intends to reopen on 
April 26, 2021 or sooner, as conditions and restrictions permit.” 
 
46. If an entity contracts with another entity for the operation of its venue and that contractor 
supplies all the necessary staff, should it list zero dollars in the SVOG application (Form 3515) 
column for personnel costs? 
Yes. Entities should only include costs actually incurred by the entity.  
 
47. Does the $10 million cap on the combined value of awards received by a group of affiliated firms 
only apply to applications from groups of museums? 
Yes. A museum and up to four museums it owns at least 51% of may all receive SVOG awards, but the 
total amount of funding issued to such a group cannot exceed $10 million. No other type of eligible 
entity is subject to such a dollar limit cap. 
 
48. Does an entity have to submit all its marketing materials – which can be voluminous - with its 
application?    
Eligible entities subject to the regular programming requirement (i.e., museums and movie theatres), 
can upload materials that demonstrate they have presented an average of at least 4 events per 
month per year (see #5 under Definitions in this FAQ). In addition, all applicants may submit a 
document, such as a spreadsheet, that contains URLs linking to online copies of marketing materials 
rather than submitting such materials as attachments.  
 
49. Form 3515’s proposed budget template has “Fiscal” headers; should this be the entity’s fiscal 
year or the federal fiscal year?  
The word “fiscal” should not appear in the budget template column headings. Instead, those column 
headings should just read “2019” and “2020.” The SBA is working to correct this portion of the 3515. 
This format may be updated and additional instructions will be in the Applicant User Guide, posted at 
www.sba.gov/svogrant. 
 
50. How does an entity get a Data Universal Numbering System (DUNS) Number from Dun & 
Bradstreet (D&B)? 
1. Go to the Dun & Bradstreet site: https://fedgov.dnb.com/webform/  
2. Select the link to request your DUNS Number via the web  
3. Follow the on-screen instructions to check whether your business or organization already has a 
DUNS number 
4. Enter your business name and state and the validation text, then select Submit 
5. If your business is listed, you can request the existing DUNS number 
6. If it is not, you can request a new one 
Note: there is no fee for getting a DUNS number to do business with the U.S. Government 
 
51. What do I need to know to register at SAM.gov? 
Review this overview presentation. New SAM.gov registrations normally take an average of 7–10 
business days to process, but can take up to 30 business days during periods of peak volume. An 

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entity can log into SAM.gov and use the SAM Status Tracker (under the Check Status tab) to quickly 
check its status. 
 
52. Is there guidance an entity can use to help it ensure it is properly filling out the Form 4506-T 
(Request for Transcript of Tax Return) correctly? 
Yes. The second page of the PDF version of Form 4506-T published on the IRS website includes line by 
line instructions for filling it out. NOTE: SVOG applicants should use the unique 4506-T document 
that will be posted at www.sba.gov/svogrant and reference the Applicant User Guide for additional 
direction. Though an entity must fill in its own entity information, the SVOG specific document 
includes certain pre-filled boxes required by the program and IRS.  
 
53. Why do questions 18-27 on the application (Form 3515) read as though they only apply to venue 
owners, but are addressed to live venue operators, theatrical producers, promoters, and live 
performing arts organization operators?  
The SBA apologizes for any confusion or misunderstanding created by the wording of these 
questions. Because the process for amending approved forms can take some time, the SBA will likely 
not be able to clarify Form 3515’s language before the application portal opens. However, we want to 
emphasize these questions should be read as broadly referencing those venues used by an applicant 
rather than more narrowly applying only to those venues owned by an applicant. Live venue 
operators, producers, promoters, and live performing arts organization operators should all answer 
these questions.  
 
54. *What impact will it have if an entity applied for other assistance, such as a state grant, but it 
won’t know the outcome of that before applying for a SVOG? 
It should have no impact. Even if it did receive such assistance, no gross revenues received after Dec. 
31, 2020 are relevant for purposes of the initial award phase of the SVOG program. 
 
55. *Where will a non-profit entity fit into the application periods, as they don’t have a revenue loss 
per se?  
Qualification for the first and second priority periods is based upon the extent of the reduction in an 
entity’s gross revenues between Apr. 1 - Dec. 31 of 2019 and 2020. Because gross revenue includes all 
funds taken in by an entity other than federal disaster assistance, SBA is not aware of any reason why 
a nonprofit entity could not demonstrate a reduction in gross revenue over this time frame. 
 
56. *Should all eligible entities apply at once or should we wait until our designated priority 
period/time to apply? 
Awards will be made on a first come, first served basis and the SBA invites all eligible entities to apply 
as soon as they can to establish their position in the queue. During each period of the initial award 
phase, the SBA will start with the first application submitted that qualifies for funding under that 
period and work its way through the queue chronologically. 
 
57. *What is the difference between a Form 424 and a Form 424B? 
A Form 424 is an Application for Federal Assistance used to apply for many federal grant programs. 
However, this form is not used for the SVOG program. Instead, the SBA is using the specially designed 
Form 3515 to accept applications for SVOG awards. A Form 424B is a set of assurances that a grant 
recipient makes in advance of receiving its award affirming that it will comply with various policies, 
laws, and regulations of the federal government. This form is required for SVOG applications. 
 

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58. *What time frame should the proposed budget cover? 
An applicant’s proposed budget should cover a 12-month period that will begin on the date of their 
award. 
 
59. *Is an entity’s NAICS code relevant for purposes of its SVOG application? 
While the NAICS code an applicant operates in is not a determining factor for SVOG eligibility, it is one 
of many pieces of information the SBA may draw upon when conducting a broad-based examination 
of an applicant’s principal business activity. 
 
60. *Can several people fill out one application and access it from different locations?  
Only one person may have access to an entity’s SVOG application at a time, but it is possible that 
multiple parties could collaborate on a single application if they did so sequentially rather than 
concurrently. 
  
61. *Can an entity have its accountant or adviser fill out its SVOG application? 
While SBA’s goal when designing the SVOG program application was to create a form that could be 
completed without the need for professional assistance or expertise, the issue of who fills out an 
eligible entity’s SVOG application is a decision for the organization’s management and ownership.  
  
62. *The application (Form 3515) asks if an applicant is wholly or partly owned by a firm that 
possesses various disqualifying factors (i.e., listed on the stock exchange, operates in more 
than 1 country and 10 states and has more than 500 employees). However, the Economic Aid Act 
says that these disqualifying factors only apply in the case of majority ownership. Can you 
clarify this matter? 
SBA apologizes for the confusion caused by the wording of this portion of the Form 3515. We will 
work to correct the phrasing as soon as possible. In the interim, applicants should read the term 
"partly owned" in this context as meaning "majority owned." 
 
63. *Will the SBA apply the governmentwide grant rules of 2 C.F.R. Part 200 to the SVOG program? 
Yes, the SBA will apply the requirements of 2 C.F.R. Part 200 to all SVOG recipients, including 
nonprofit organizations, for-profit companies, and tribal, state, and local government-owned 
entities.  
 
64. *Two different SVOG application questions ask us to upload floor plans. Do we really need to 
upload the same file twice? 
Yes. While we realize this may cause some inconvenience, there is not sufficient time to address this 
issue in the infrastructure of the application portal. Where the SVOG application process may require 
multiple uploads of the same documentation, please do so to ensure your application is complete. 
 
65. *What is my Electronic Funds Transfer (EFT) Indicator (formerly known as the DUNS+4) if I only 
have one bank account in my SAM.gov registration?  
Most entities do not have multiple bank accounts and do not need to create a separate EFT Indicator. 
If you have just one bank account associated with your SAM.gov entity registration, your EFT 
Indicator is just 0000. 
 
66. *What does the “date of operation” mean on the SVOG application? 
In response to this application question, an entity should enter the date the entity began in business.  
 

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67. *What is the difference between “applicant information” and “authorized representative 
information?” The SVOG application asks me to provide both. 
Applicant information refers to the eligible entity applying for an SVOG. Authorized representative 
information refers to the actual person submitting an SVOG application on behalf of an eligible entity. 
 
68. *The SVOG application appears to indicate that award amounts will be based on earned revenue 
rather than gross revenue as is required by the Economic Aid Act. Can SBA clarify this? 
We can confirm that SVOG award amounts will be based gross revenue, not earned revenue. The SBA 
is updating the program guidance to make this point clearer. 
 
69. *The SVOG application requires us to obtain and enter DUNS numbers for all our affiliates, even 
if they aren’t covered by an SVOG application. Is it true that entities are not required to obtain 
DUNS numbers for affiliates unrelated to our SVOG application? 
Yes. Entities only need to list those affiliated firms, along with their DUNS numbers, that will be 
covered by an SVOG application. Affiliates not related to any SVOG application (either submitting 
their own application or included in a parent entity’s application) do not have to be identified. 
 
70. *In the SVOG application question regarding whether a business was in operation as of Feb. 29, 
2020 it says we should provide quarterly tax filings, financial statements, payroll documents, or 
other supporting documentation. What constitutes “other supporting documentation”? 
This is intended to be a catch-all category to invite applicants to provide any other type of 
documentation they possess which they feel helps them to establish when the applicant entity began 
business operations. 
 
71. *The SVOG application says a venue floor plan, venue layout, or other evidence of a projector 
and fixed audience seating must be attached to meet the eligibility requirement for at least one 
auditorium with a motion picture screen and fixed audience seating. Is this needed for every 
screen with fixed seating (if multiple) in each location or will one example per location suffice?  
To document compliance with this eligibility requirement an applicant may attach a floor plan of a 
venue, venue layout, or other evidence of a projector and fixed audience seating for ONE of the 
screens with fixed seating at each covered location. 
 
72. *The SVOG application refers to “payments to independent contractors not to exceed $100,000 
in annual compensation for an individual employee.” However, independent contractors are 
NOT employees. Can SBA clarify this? 
The individual employees referenced in this item are the individual employees of an independent 
contractor, as stipulated in the Economic Aid Act. The SBA did not mean to cause confusion in this 
area and is updating its guidance to reflect this clarification. 
 
73. *The SVOG application includes the Form 1386 in the list of required documents, but it appears 
that form relates only to the EIDL program. Are SVOG applicants required to submit this form? 
No. This item was erroneously included in the application and guidance documents. The SBA is not 
requiring SVOG applicants to submit a Form 1386.  
 
74. *The SVOG-specific Form 4506-T used for requesting tax return transcripts does not appear to 
accommodate organizations whose 2019 fiscal year did not end on December 31, 2019. In the 
FAQ update, SBA indicates that 2018 and 2019 nonprofit tax returns may be used in place of 
2019 and 2020. Can you confirm this is the case? 

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The pre-filled portions of the SVOG-specific Form 4506-T were required by the IRS and the SBA has no 
ability to alter them. However, it is SBA’s understanding the pre-filled values will not prevent 
applicants from being able to use their 2018 and 2019 tax returns to support their SVOG application 
under these circumstances. 
 
75. *The SVOG application requires me to upload a copy of my business license, however my 
tribal/state/local government does not require me to have a business license. How should I 
respond to this application entry? 
If you are not required to have a business license under local law you may upload a document stating 
“Business licenses are not required under local law” instead of providing a copy of a business license. 
 
76. *How many performing arts events must a venue operator, promoter, producer, live 
performing arts organization operator, or talent representative document in terms of 
marketing materials, show listings, etc. as part of its application? 
As part of their SVOG application, the types of eligible entities noted above must submit a sample size 
of a dozen (12) show/event listings and marketing materials for performances they staged or 
promoted over the course of 2019-2020. 
Use of Funds 
1. Can SVOG funds be used to refund customers still holding tickets for cancelled performances? 
Yes, it appears this type of cost would qualify under the Economic Aid Act as a necessary and ordinary 
business expense. As such, it should be an allowable use of grant funds to make refund payments to 
patrons for cancelled shows. 
 
2. Can SVOG funds be used to reimburse an owner who put their own money into the entity to 
keep employees and operating expenses paid?   
Yes. Owners of eligible entities may be fully reimbursed for personal funds they contribute(d) to an 
entity to keep it in operation between March 1, 2020, and Dec. 31, 2021 (or June 30, 2022, if the entity 
receives a supplemental phase award), provided sufficient documentation of the transfer and 
expenditure of such funds exists. Without such documentation, claimed owner reimbursements will 
be treated as compensation or distributions of profits and subject to the cap on such payments noted 
in question 3 in this section. 
 
3. How is owner compensation treated under the program?  
Owner compensation, including distributions and dividends, will be treated as an ordinary business 
expense by the SBA and thus payable using SVOG funds to the extent that the total amounts involved 
do not exceed what an owner received in compensation in 2019. 
 
4. Can grantees use SVOG funds to reimburse themselves for allowable expenses they already paid 
going back as far as March 1, 2020?  
Yes. The SBA believes this would be permissible under the Economic Aid Act. 
 
5. Is debt refinanced or consolidated under a new lender, but existed prior to Feb. 15, 2020 
considered an eligible expense? What about a line of credit or revolving loan that existed prior 
to Feb. 15, 2020, but was drawn down after that date?  
Yes. Payments toward debts recorded prior to Feb. 15, 2020, represent an allowable expense even if 
the debt was refinanced or consolidated with other debts that existed prior to that cutoff date. Any 
otherwise allowable debt consolidated with a debt that was not recorded prior to Feb. 15, 2020, 

28 | P a g e  
would continue to be an allowable expense only to the extent of the original qualifying debt. Any 
additional amount of indebtedness following the consolidation that is attributable to the 
nonqualifying loan would not be an allowable expense. Additionally, payments on lines of credit or 
revolving loan funds recorded prior to Feb. 15, 2020, but not drawn down until after that date would 
also be an allowable expense. Where an existing line of credit or revolving loan fund was increased 
after Feb. 15, 2020, only the pre-Feb. 15, 2020, amount would represent an allowable expense. SVOG 
funds could not be used to make payments on any increase in the indebtedness. 
 
6. Do ‘state and local taxes’ identified as allowable expenses include real estate taxes and 
personal property taxes on buildings and equipment?  
Yes. Where real estate taxes and personal property taxes are levied on buildings and equipment 
directly related to eligible SVOG program operations they may be paid using grant funds. Taxes on 
property and equipment owned by an eligible entity not directly related to its SVOG program 
operations are not an allowable expense. 
 
7. Do interest-bearing bank accounts fall into the category of investing funds?  
No. Use of an interest-bearing bank account to hold SVOG funds would not constitute an 
impermissible investment. 
 
8. Can a grantee include the uncredited portion of an individual’s salary for whom it has received 
an employee retention tax credit (ERTC) as an allowable expense under an SVOG? 
Yes. Where an eligible entity receives an ERTC for one of its employees and that credit does not fully 
cover the employee’s salary, SVOG funds may be used to pay the uncredited portion of the 
employee’s salary. SVOG funds cannot be used to pay any portion of an employee’s salary covered by 
an ERTC. 
 
9. Will SVOG awards count toward the Single Audit Act threshold?  
Yes. As a Federal grant program, all funds awarded under the SVOG will count toward an entity’s 
requirement to comply with the Single Audit Act if it receives $750,000 or more in Federal grant 
funding during a single fiscal year. 
 
 
10. Will SBA consider audit costs to be an allowable expense?   
Yes and no, depending on the audit threshold. Where an SVOG recipient is covered by the Single Audit 
Act, it may charge a reasonably proportionate share of the costs of audits required by, and performed 
in accordance with, the Single Audit Act to its SVOG. For SVOG recipients not covered by the Single 
Audit Act, audit expenses will not generally be considered an allowable grant expense. 
 
11. Is depreciation an allowable expense under SVOG? 
Yes. The SBA will allow SVOG recipients to use grant funds to cover the cost of depreciation in 
accordance with the principles outlined in 2 C.F.R. § 200.436. 
 
12. How are “ordinary and necessary expenses” being defined? 
Ordinary and necessary expenses will be defined using the IRS definition, as the Economic Aid Act 
does not define ordinary and necessary expenses. Per the IRS, “an ordinary expense is one that is 
common and accepted in your trade or business. A necessary expense is one that is helpful and 
appropriate for your trade or business. An expense does not have to be indispensable to be 
considered necessary.” 
 

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13. How long will SVOG recipients have to use their grant funds?  
Recipients who receive an SVOG in the initial phase will have one year from the date their awards are 
disbursed by the SBA to use grant funds. If an eligible entity receives a Supplemental Phase SVOG, 
they will instead have 18 months from the date their Initial Phase award was disbursed by the SBA to 
expend all their combined grant funds (both Initial and Supplemental Phase awards). At the end of 
the applicable deadline, SVOG grantees must return all unexpended SVOG funds to the SBA. 
 
14. May SVOG funds be used to pay artist deposits and guarantees? 
Yes. Understanding that artists are typically independent contractors paid out of ticket proceeds and 
in many cases the proceeds are not available prior to the show closing so entities often use deposits 
and/or guarantees to provide prior payments to artists, the SBA believes this use of SVOG funds is 
authorized as an ordinary and necessary business expense. 
 
15. Will an SVOG be disbursed in one lump sum or in multiple payments? If multiple payments are 
used, what will the time frame be for payout? 
Depending on the size of the award and other risk factors, some SVOGs will be disbursed in the form 
of a single lump sum while others will be spread out over multiple payments. In general, most SVOGs 
under $1 million are deemed to pose a low risk and will be disbursed in one or two installments. 
Awards for larger amounts are deemed to be a higher risk and will be disbursed in two to four 
installments. Where payment is made via installments, the schedule of payments will depend upon 
the grantee’s submission of documentation of an SVOG recipient’s use of the initial fund 
disbursement and their 2020 federal tax return. The SBA understands not all entities will file a 2020 
federal tax return at the same time and will collect documents accordingly. In every case, installment 
payments will not be made according to a specified calendar or a set amount of time. A grantee’s 
disbursement will depend on how quickly it can provide the required documentation.    
 
16. Is there a difference between the amount of time an SVOG recipient has to expend award funds 
and the period of time during which they may incur allowable costs?  
Yes. While a recipient of an Initial Phase SVOG has one year from the date of its award to expend its 
grant funds, it can only use those funds to pay allowable items of cost incurred between March 1, 
2020, and Dec. 31, 2021. Where an entity receives a Supplemental Phase SVOG, it will have 18 months 
from the date of its Initial Phase Award to expend its grant funds, but it can only use those funds to 
pay allowable costs incurred between March 1, 2020 and June 30, 2022.  
 
17. Can SVOG funds be used to make payments on SBA-backed loans? 
Yes. The Economic Aid Act states SVOG funds may be used for “scheduled payments of interest or 
principal on any indebtedness or debt instrument.” Given the broad language used by Congress, the 
SBA will treat payments on SBA-backed loans as an allowable expense under the SVOG program. 
 
18. Can SVOG funds be used to make employees whole for temporary reductions in pay an 
employer had to impose due to economic circumstances under the pandemic? 
Yes. After further reflection, the SBA will apply a similar approach to that taken by the PPP. Where 
employee salaries and wages were reduced for some or all of the period between March 1, 2020 and 
Dec. 31, 2021 (or June 30, 2022 in the case of supplemental award recipients) due to economic 
circumstances caused by the COVID-19 pandemic, an SVOG recipient may use grant funds to restore 
the lost wages of its employees in whole or in part. 
 
19. If SVOG is disbursed in several payments, does the grantee have one year from the date of each 

30 | P a g e  
disbursement to use the funds? 
No. Grantees will have one year from the date their SVOG award is issued to spend their funds, unless 
they receive an extension following the issuance of a supplemental award.  
 
20. If an entity receives a $1 million SVOG but also has a $300,000 PPP loan that gets deducted, will 
it be deemed to have received more than $750,000 in federal financial assistance and be subject 
to the Single Audit Act? 
The SBA has previously stated PPP loan funds are not considered federal financial assistance as 
delegated lenders disburse them and the government does not directly provide them (the 
government provides the guaranty). As such, any PPP loan deduction taken from an SVOG award 
would not be counted for purposes of determining if an organization has exceeded the Single Audit 
Act threshold. However, Economic Injury Disaster Loan funds are considered federal financial 
assistance, so an organization that received an EIDL or EIDL Advance, Targeted EIDL Advance and the 
like, would have to add those funds to its SVOG award amount when determining if it had expended 
more than $750,000 in federal financial assistance in one fiscal year. 
 
21. Will making improvements/changes to bathrooms, HVAC etc. in response to COVID-19 be 
eligible uses of SVOG funds?  
Yes. These types of COVID-19 related expenses would be allowable as worker protection 
expenditures. 
 
22. Will applicants be required to stay within the limits of how they propose to spend the grant 
funding, and will it matter if the final expenses comply closely with the budget provided or not? 
Under current SBA grant policies, any changes from the budget that shift funds among approved cost 
categories more than 10%, or which shift costs to a category not included in the approved budget, 
require prior approval. Thus, while actual expenditures can vary from budget projections, depending 
on the variance amount, grantees may have to request permission (and possibly submit a revised 
budget) in advance. Given the unique nature and circumstances of the SVOG program, the SBA is 
committed to exploring ways to potentially liberalize this policy as it applies to SVOG recipients.  
 
23. Will artist deposits/guarantees from promoters who hold then disburse the money to multiple 
artist clients, count as contractors for booking agencies and, if so, will it be limited to the 
$100,000 payment for an independent contractor? 
No. Talent representatives or other entities acting as fiscal transfer agents on behalf of individual 
artists will not be considered independent contractors for purposes of the $100,000 payment limit. 
Instead, the SBA will consider the relevant independent contractor in such cases to be the individual 
artist represented by the talent agent or manager. 
 
24. Will credit card payments be considered scheduled debt payments that can be paid from SVOG 
funds? 
No. However, individual credit card charges that relate to allowable expenses such as utility 
payments, worker protection expenditures, or other ordinary and necessary business expenses and 
which were incurred between March 1, 2020 and Dec. 21, 2021 (or Jun. 30, 2022 if the entity receives a 
supplemental SVOG award) are payable or reimbursable from grant funds. 
 
25. Are all customer refunds from 2020 due to cancellations a valid use of funds? If so, what 
category will that fall under? 
Yes. Such expenses should be listed under the “Other” category. 
 

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26. Are all owners' distributions and wages from 2019 a valid use of funds? If so, what category will 
that fall under? 
No. Only costs incurred after March 1, 2020 are allowable.  
 
27. How will the SVOG award funds be delivered to the recipients? 
Entities will submit their bank information as part of the SAM.gov registration process, and, upon 
confirming the grant award, the SBA will process the funds (in whole or in part, depending on the 
circumstance) through its internal accounting system and deliver them via ACH to the entity’s bank. 
 
28. *Can funds be used to pay for construction projects such as a new roof and the like?  
Only those construction costs that relate to worker protection expenditures (see the question and 
answer on this topic in the Definitions section above) are payable using SVOG funds. 
 
Business Size/Employees 
1. How should an entity determine its employee count?  
For employee count, the SBA is drawing on the Economic Aid Act’s specific provisions re: the 
calculation of employees and decades of agency experience in counting employees under the SBA 
size regulations (13 C.F.R. § 121.106). Employees that work at least 30 hours per week are considered 
full-time. Employees that work between 10-29 hours per week are considered one-half of a full-time 
employee. Employees that work less than 10 hours per week are not considered an employee. Once 
the qualifying employees are determined, an entity must then calculate the average number of 
employees it had over the prior year by adding up the number of qualifying employees in each 
individual pay period and dividing that amount by the number of pay periods over the 12-month 
period from Mar. 1, 2019 to Feb. 29, 2020. 
 
For example, assume a firm paid its employees monthly and had the following number of qualifying 
employees each pay period: 
 
Mar 2019 – 9.5 full-time employees 
Apr 2019 – 8 full-time employees 
May 2019 – 9.5 full-time employees 
Jun 2019 – 8.5 full-time employees 
Jul 2019 – 10 full-time employees 
Aug 2019 – 10 full-time employees 
Sep 2019 – 7 full-time employees 
Oct 2019 – 8.5 full-time employees  
Nov 2019 – 7 full-time employees 
Dec 2019 – 6 full-time employees  
Jan 2020 – 7.5 full-time employees 
Feb 2020 – 6 full-time employees 
 
The sum of the firm’s full-time employees is 97.5. The firm would then divide 97.5 by 12 (the number 
of pay periods) to determine its average number of full-time employees was eight. 
 
2. Which priority or phase is number of employees considered? 
There is no priority based on number of employees in the application process. Per the Economic Aid 
Act, the $2 billion small employer set-aside for those with 50 employees or less is a separate aspect of 

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the awarding process from the priority periods.  
 
3. Are institutions of more than 500 employees eligible to apply for an SVOG if they meet other 
eligibility criteria? 
Yes, if they do not operate in either more than 10 states or another country. 
 
4. For determining employee counts and the average number of employees, what should an entity 
do if the date range doesn’t match neatly with the payroll schedule (e.g. biweekly)? 
An entity’s average number of full-time employees will be determined with reference to each pay 
period that falls, either in whole or in part, within the 12-month timeframe stipulated by the 
Economic Aid Act. For example, if an entity’s biweekly pay period ran from Feb. 18, 2019, to March 3, 
2019, that pay period would have to be considered when determining the entity’s number of full-time 
employees, even though only three days of that pay period fell within the 12-month timeframe. In 
this case, the entity would average the employee’s weekly hours for that pay period (considering the 
days that fell outside the 12-month timeframe) to determine if they were a full-time employee in the 
first covered pay period. If the employee worked 40 hours from Feb. 18-24, 2019 and 30 hours from 
Feb. 25-March 3, 2019, their weekly average for that pay period would be 35 hours and they would be 
counted as a full-time employee for the first pay period. Similarly, where the final covered pay period 
falls in part outside the 12-month timeframe, the entity will look to the weekly average for the entire 
pay period when determining whether individuals were full-time employees for that final pay period. 
 
5. If an entity has a biweekly payroll schedule it will likely have some staff who work less than 10 
hours for the first week of a pay period and more than 10 hours for the second week of a pay 
period. Would the entity average their total hours over those two weeks to determine if they 
were a full-time employee for purposes of that pay period? 
Yes, when calculating their number of full-time employees, entities will use a weekly average of the 
employees’ total hours over that pay period. For example, if an entity has a biweekly pay period and 
an employee worked 10 hours the first week and 30 hours the second week, the employee would 
have worked an average of 20 hours per week during that pay period and would be considered half a 
full-time employee for that pay period. While the Economic Aid Act defines full-time employees in 
terms of how many hours they work per week, for the small employer set-aside, the SBA will look to 
the average number of full-time employees an entity has per pay period over the course of a set 12-
month period. 
 
6. What is the full-time employee calculation used for?  
The SBA will look to the number of full-time employees retained by an entity for three purposes: 1) to 
determine whether the entity has more than 500 employees and thus may be ineligible for the SVOG 
if it also meets other criteria; 2) to determine whether the entity has between 500 and 10,000 
employees and is thus subject to the certification regarding labor rights; and 3) to see if the entity is 
eligible for the small employer set-aside.  
 
7. Do independent contractors count as employees for purposes of the small employer set-aside? 
The SBA will consider the totality of the circumstances, including criteria used by the IRS for Federal 
income tax purposes, in determining whether individuals are employees of a concern. Where the IRS 
considers an individual to be an independent contractor rather than an employee, the SBA will do the 
same and that individual will not be counted as an employee of the eligible entity for any purposes. 
 
8. If an eligible entity is run by a management company does the owner report that it doesn’t have 

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any employees, or is it required to include the number of individuals working for the 
management company in its application? 
As is the case with listing personnel costs, an eligible entity must only list its own full-time employees 
on its application, if any.  
 
9. Can a tribal, state or local government-owned eligible entity qualify for the small employer set-
aside? 
Only if the tribal, state or local government as a whole employs 50 or fewer individuals. In making this 
determination, the SBA will not restrict its consideration to only those individuals employed by the 
government-owned eligible entity itself, even if it has its own EIN. Rather, the SBA will look to the 
total number of all individuals employed by the tribal, state or local government owner. 
Revenue 
1. How are “earned revenue” and “gross earned revenue” being defined by the SBA? 
As required by the Economic Aid Act, the SBA is defining earned revenue and gross earned revenue 
(the two terms in the law) in accordance with common principals of the accrual method of 
accounting. Using this, only monies organizations receive from the sale of goods or services are 
counted as earned revenue. This commonly accepted definition of earned revenue does not include 
other sources of funds that an organization may receive, such as donations, sponsorships, 
governmental assistance, or returns on investments. Gross earned revenue is the total of earned 
revenue from various sales of goods or services, such as admission tickets, merchandise, food and 
beverages, advertising sales and contracted presentation income. 
 
2. How is “gross revenue” being defined by the SBA? 
Gross revenue is functionally equivalent to ‘receipts,’ which the SBA has defined under 13 C.F.R. § 
121.104 as meaning “all revenue in whatever form received or accrued from whatever source.” This 
will include contributions, donations, and grants from any and all sources (excluding any disaster 
assistance funding).  
 
3. Are donations / contributions included in gross earned revenue?  
No. Only earned revenue should be included in calculations of gross earned revenue. Unearned 
revenue, including donations and other gratuitous contributions, such as foundation grants and 
individual gifts, should not be included.  
 
4. Are fundraising event receipts considered gross earned revenue? 
In dealing with fundraising events, the SBA will follow the same general principles applied to tax 
deductions for donations to charities. This means that the portion of the amount an individual pays 
in connection with a fundraising event which represents the estimated value of the good or service 
they receive in exchange must be included in gross earned revenue. However, that portion of the 
amount such an individual pays that exceeds the estimated value of the good or service they receive 
will be considered a donation and is not included in gross earned revenue.  
 
For example, if a ticket to a fundraising dinner costs $100 per person and the estimated value of the 
dinner provided is $50, then $50 of the funds generated from the fundraising ticket would be 
considered gross earned revenue and the other $50 would be considered a donation and would be 
excluded from gross earned revenue. 
 
5. Does a non-profit count contributions and grants revenue? 

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No. Both contributions and grants revenue would be excluded from an organization’s earned 
revenue. However, the SBA will take into account an organization’s Federal grants revenue to 
determine whether it meets the eligibility limit of having no more than 10% of its gross revenue from 
Federal sources, not including disaster assistance. 
 
6. Does a non-profit count membership revenue? 
Yes and no; like fundraising, the portion of membership cost that represents the estimated value of 
the goods or services provided as a condition of membership should be included in gross earned 
revenue. The portion of a membership cost that exceeds the estimated value of the goods or services 
provided as a condition of membership is considered a contribution and excluded from gross earned 
revenue. 
 
7. If a business provides talent representation and financial services for athletes and entertainers, 
would it use total revenue or just the portion of sales from talent representation services? 
The business would use gross earned revenue from all sources. It would also need to satisfy the 
requirement that the principal line of business is talent representation versus financial services. 
 
8. What is included in the 10% maximum for federal grants/funding? 
The 10% maximum for federal grants/funding covers everything regardless of the use of the 
grant/funding except disaster assistance.  
 
9. Is rental income from tenants and income from renting the venue for private events counted as 
earned revenue? 
Yes, rental income from longer-term tenants and from short-term rentals for event hosting should be 
included in earned revenue because they derive from standard commercial transactions for the paid 
use of facilities. 
 
10. If an eligible entity has multiple lines of business activity, including a line(s) not covered by the 
SVOG program, should it include earned revenue derived from those business lines?   
Yes. If an applicant’s primary business activity places them within one of the categories of an eligible 
entity under the Economic Aid Act, then they should use their gross earned revenue across all their 
business activities and not exclude any non-SVOG revenue streams. 
 
11. Is school tuition (e.g., charged by a dance school that operates a live venue) considered earned 
revenue?  
Yes. Tuition payments will be treated as earned revenue. 
 
12. Will the SBA treat funds raised via capital campaigns differently than other types of fundraising 
proceeds? 
Yes. Given the unique nature and objective of capital campaigns conducted by nonprofits, the SBA 
will exclude all funds raised via capital campaigns from calculations of earned revenue. 
 
13. Will the SBA look to calendar year 2019 or fiscal year 2019 earned revenues as the basis for 
calculating award amounts?  
The SBA will permit applicants to use either their fiscal year 2019 or calendar year 2019 earned 
revenues as the basis for determining the award amount for both Initial Phase and Supplemental 
Phase SVOGs. Whichever option an applicant selects will apply to both award phases. Applicants 
cannot use their fiscal year 2019 for one award phase and the calendar year for the other. 

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14. Will earned revenue be analyzed/reported net of sales tax, returns, and discounts? 
Yes. Amounts that represent the costs of taxes collected for and remitted to a taxing authority, or 
returns, and post-sale discounts may be deducted from earned revenues. 
 
15. Does the exclusion of disaster assistance funds only apply to funds received directly from the 
Federal government?  
No. Disaster assistance funds an eligible entity receives, whether directly from the Federal 
government or indirectly through a tribal, state or local government, will be excluded from the 
entity’s gross revenues. For example, if a state government received CARES Act funding from the 
Federal government in a lump sum and apportioned it to make grants to small businesses, those 
state-issued grants also would be excluded from an entity’s gross revenue. However, disaster 
assistance funding provided by tribal, state and local governments that does not originate from 
federal disaster assistance block grants, as well as disaster assistance provided by private entities, 
will not be excluded from an applicant’s gross revenues. 
 
16. Will the SBA treat funds derived from sponsorships as earned revenue or gross revenue? Will 
sponsorship revenue be treated the same for for-profit and non-profit entities?  
The treatment sponsorship revenue will receive will depend on whether an entity is a for-profit or 
non-profit entity. Because it represents payment made in exchange for a service (i.e., recognition or 
advertising), sponsorship payments (such as naming rights) received by for-profit entities will be 
considered earned revenue. Like the treatment afforded memberships and fundraising events, 
sponsorship payments received by non-profits will be considered part earned revenue and part gross 
revenue. In such cases, the sponsorship payment amount a non-profit receives that represents a fair 
market value for services in exchange (i.e. promotion, free admission, use of facilities) will be deemed 
earned revenue and the portion of the sponsorship payment that exceeds that amount will be 
deemed a contribution and thus gross revenue. For example, if a company gives $25,000 to a non-
profit and for that, gets its logo in a program, event admission and screen time on monitors at the 
venue, then the “market cost” of those items are earned revenue and the remaining is gross revenue. 
 
17. Will the SBA require entities to use the accrual method of accounting only when determining 
their qualification for a priority period, or must they also rely on the accrual method for 
establishing their award amount and/or non-priority period eligibility? 
The accrual method of accounting is only required when determining whether an entity qualifies for 
one of the priority periods under the Economic Aid Act. For all other purposes, an entity may rely 
upon either the accrual or cash method of accounting. 
 
18. How will the SBA categorize a partner’s standard, non-passive revenue (such as that reported 
on an IRS schedule K-1)? 
The SBA will include this type of revenue in the definitions of both gross revenue and earned revenue. 
 
19. How will the SBA treat cases where all the revenue of an applicant that commenced business 
operations and incurred costs in 2020 was refunded due to closures and cancellations brought 
on by the COVID-19 pandemic? 
In such cases, an applicant may include these refunded amounts in both its gross revenue and 
earned revenue. 
 
20. If an entity operates two separate sites, which in 2019 were operated by two separate entities 

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but merged in January 2020, how should it treat its 2019 and 2020 revenues? 
In cases of merged entities under circumstances such as this, entities should combine the revenues 
from both organizations for 2019 and then use the revenues for the successor entity for 2020. 
 
21. Should in-kind gifts be included in gross revenue? 
Yes. Gifts or contributions of any type, whether cash or in-kind, must be included in gross revenue. 
 
22. If an entity receives production fees and reimbursements from outside entities that put on 
productions in its spaces and some of the events are business conferences, does the revenue 
from these programs have to be excluded from performance fees? 
No. This revenue should be included along with your other performance fees. 
 
23. If an entity holds fee-based educational events at its venue and presents fee-based programs 
offsite, is the revenue from the offsite programs excluded? 
No. The fees generated by these offsite programs should be included in the entity’s gross and earned 
revenues. 
 
24. If an entity does not sell food or beverages directly to consumers, but receives a commission 
from a concessions firm that is outsourced for this, would the commission funds received 
constitute food and beverage sales?  
Yes. A commission on food and beverage sales by a third party operating at a venue is considered 
income from food and beverage sales. 
 
25. Can music recordings produced via a record label in an entity’s spaces, on tour and online count 
as merchandise sales? 
Yes. Income derived from these sales should be considered proceeds from sales of merchandise. 
 
26. For an entity that only operates some facilities and the facility owner remains responsible for 
profits and losses (i.e., revenue and expenses are reported on operator tax return attributable 
to owner), how should the operator handle reporting? Should the revenue from the operated-
only facilities be removed in this section since the owner will use those revenues on owner’s 
SVOG application? 
While it is possible that the same venue may be associated with multiple applications, such as where 
a venue owner, promoter, and talent representative all reference the same venue for purposes of 
documenting that they each individually meet the facility and event related eligibility requirements 
of the SVOG program, no SVOG application should include revenues that are also included on another 
SVOG application. 
 
27. Where a venue, movie theatre, or museum owned by a private university does not have its own 
EIN, should its application use the revenue figures for the university department which 
operates the entity, or must the requested revenue figures be those of the entire university 
system given it is the legal entity for purposes of the application? 
With the exception of government-owned eligible entities, including those owned by public 
universities, the SBA will look to the legal entity that is the holder of the EIN associated with the 
application to determine whether that application meets the SVOG program criteria, including the 
10% federal contribution to gross revenue restriction, the principal business activity requirement, 
and all revenue loss thresholds.  
 

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28. *Will a recipient’s grant amount be based on their earned or gross revenue?  
The amount of funding an eligible entity receives under the SVOG program will be based on the 
product of a formula applied to their 2019 earned revenue (minus the amount of any PPP loan 
received after Dec. 27, 2020) or $10 million, whichever is less. 
 
29. *Is an entity’s eligibility for the priority periods based on its gross revenue or earned revenues?  
Eligibility for the first and second priority periods is based upon reductions in an entity’s gross 
revenues between comparable dates in 2019 and 2020. 
Subsidiaries & Affiliates 
1. For entities with subsidiaries, does each entity need to meet the eligibility criteria 
independently? 
No. Subsidiaries only need to meet the eligibility criteria independently if they are applying for SVOG 
awards on their own. If subsidiaries are included in a parent entity’s SVOG application, only the 
parent entity needs to establish its eligibility. Additionally, per the Economic Aid Act, subsidiary 
entities that qualify for an SVOG will not be treated as affiliates of their parent entity or one another. 
 
2. How are shared expenses across affiliated organizations treated?  
Assuming an entity with subsidiaries (parent) shares costs with its subsidiaries, the parent’s shared 
costs (or allocated costs to subsidiaries) remain as such, and the parent should keep records to show 
that all expenses claimed under the grant served grant purposes. If a subsidiary is eligible to apply for 
and applies for its own grant, only the portion of the shared cost that the subsidiary pays can be paid 
for by the SVOG should it be received.  
 
3. Are there limits on the number of affiliates that can receive an SVOG or the total between them? 
Yes, a maximum of five business entities related via affiliation (for example, one parent firm and four 
subsidiaries) can receive an SVOG. In addition, an eligible museum, and all other museums it 
operates as subsidiaries may receive no more than $10 million combined under the program. 
 
4. If a parent company is ineligible for an SVOG, can one of its subsidiaries still be eligible? 
In general, yes. The Economic Aid Act specifically allows up to five firms with a subsidiary/parent 
relationship to apply for an SVOG providing they can meet the eligibility requirements in their own 
right, and the fact that one of them is ineligible generally should not preclude the others eligibility. 
However, a subsidiary would not be eligible where it is majority owned and controlled by a parent 
entity that is either listed on the stock market or owns or operates eligible entities in more than 1 
country and more than 10 states and has more than 500 employees. In either of those cases, the 
Economic Aid Act mandates that a subsidiary entity is ineligible for an SVOG even if it meets all the 
other requirements. 
 
5. May a parent company include its subsidiaries in an SVOG application, or do separate 
applications need to be submitted for a parent and each subsidiary? 
Yes. While subsidiaries can apply for SVOGs on their own, they are not required to do so. A parent 
company can submit an application that includes some or all its subsidiaries if it wishes to. 
 
6. What does it mean for two or more entities to be affiliated? 
Affiliation occurs where one firm has the power to control another firm, or a single person or entity 
has the power to control both. Affiliation typically arises due to common ownership, management, or 
through contractual or other legal arrangements. The SBA uses the principle of affiliation to help it 

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determine if an entity is eligible for some government program or benefit reserved for small 
businesses. Where firms are found to be affiliated with one another, the SBA will combine their 
revenues and number of employees and compare those aggregated amounts to the relevant size 
limit for the program or benefit one of the firms is seeking. In this way, the SBA ensures that a firm 
which appears to be small but is actually controlled by a large corporation does not take a benefit 
meant only for small firms. The rules regarding affiliation in the context of SBA’s financial assistance 
programs may be found at 13 C.F.R. §121.301(f).  
 
7. How will the SBA apply the principle of affiliation to the SVOG program? 
In administering the SVOG program, the SBA will take into account the principle of affiliation in the 
following contexts: (1) In applying those provisions of the Economic Aid Act that specifically reference 
affiliation; and (2) In determining whether an applicant qualifies for the small employer set-aside. 
Given the SVOG program’s statutory design and the fact that it is not strictly a small business 
program, the SBA will not consider affiliation in any other context, including general eligibility. The 
Economic Aid Act mentions affiliation in two ways. First, it says affiliated firms (including subsidiaries) 
may apply for SVOGs on their own if they meet all the eligibility requirements. Second, it says that no 
more than five affiliated firms may receive SVOGs. In applying these two provisions, the SBA will rely 
upon the general principles of 13 C.F.R. § 121.301(f) to determine when firms are affiliated. Regarding 
the small employer set-aside, it requires the SBA to reserve no less than $2 billion in SVOG program 
funding for awards to eligible entities with no more than 50 full-time employees. The small employer 
set-aside is the only definitive size limit in the Economic Aid Act and the SBA will administer it in the 
same way it does other size limits. When calculating how many full-time employees an SVOG 
applicant has for purposes of determining whether it qualifies for the small employer set-aside, the 
SBA will look to the total number of full-time employees retained by the applicant and all of its 
affiliated entities. If this combined number is not more than 50, the applicant will qualify for the small 
employer set-aside. 
 
8. No longer relevant / deleted per the American Rescue Plan Act being signed into law.  
 
9. If a theater circuit has five theaters, each a separate legal entity, but filed with a consolidated 
tax return, are they considered five entities or one entity?  
Five entities. Consolidating tax returns does not strip subsidiary or affiliated entities of any separate 
legal existence they may possess. 
 
10. A motion picture theatre business is organized into two legal entities (the motion picture 
theater management company and the motion picture theater operating company) and never 
separately allocated revenues between the two because all income and expenses are 
consolidated. The management company and operating company each plan to apply for 
separate SVOGs. For purposes of determining the respective revenues of each separate affiliate, 
may the business apply a reasonable method of dividing revenue between the two entities? 
Yes. In allocating revenues and expenses to the separate entities the owner should consider the roles 
and responsibilities of each entity and the effort and other resources each contributed to the 
consolidated operations and ensure that any such division is reasonable and well documented. 
 
11. How is "subsidiary business" being defined? 
A subsidiary is an entity that is either wholly or majority-owned and controlled by another entity. 
 
12. If a company has 10 subsidiaries or affiliates that are independent legal entities could all 10 

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apply for an SVOG at once with the understanding that only five of them could receive grants? 
No, no more than five affiliated eligible entities may have active SVOG applications pending before 
the SBA at any one time to efficiently allocate resources and reduce the potential for erroneous SVOG 
awards which would need to be cancelled and possibly recouped. Any applications received above 
the five affiliated-entity limit will be rejected without being evaluated. Under this scenario, however, 
where an affiliated eligible entity’s application is evaluated and declined, another affiliated eligible 
entity could then apply. 
 
13. On March 22, this was moved to Supplemental Phase section 
 
14. Does the limit on a group of affiliated entities having no more than 5 active SVOG applications 
pending before the SBA (or receiving more than 5 SVOGs) also apply to entities owned by state 
or local governments? 
Yes. No more than five eligible entities owned by the same state or local government may 
simultaneously apply for or receive SVOGs.   
 
15. Can two affiliated eligible entities both use the employer identification number of their parent 
to apply for their own SVOG? For example, could a concert hall and a movie theatre owned by 
the same parent entity each use that parent entity’s EIN to apply? 
No. Only one SVOG application and award will be allowed per EIN. Additionally, where a parent 
entity’s EIN is used, it is the parent entity that must meet the statutory definition of an eligible entity 
rather than its subsidiaries or internal divisions. 
 
16. When will the SBA consider two entities with common ownership to be affiliated for purposes of 
the SVOG program? 
Consistent with the size regulations for disaster financial assistance programs (see 13 C.F.R. § 
121.301(f)) the SBA will only consider two firms to be affiliated for purposes of the SVOG program 
where one firm owns more than 50% of the other or a single person or entity owns more than 50% of 
both. 
 
17. Can 2 or more firms affiliated due to their common ownership by another firm apply jointly? 
While affiliates may apply for the SVOG program in their own name assuming they meet the eligibility 
requirements or may be included in an application submitted by their ultimate parent entity, they 
cannot team up together on an application unless one of the firms owns more than 50% of the other. 
For example, if Company A owns 100% of Company B, which owns 100% of Company C, then 
Company C could apply in its own name or be included in either A or B’s application. Conversely, if 
Companies B and C are both 100% owned by Company A then they could each apply in their own 
name or be included in A’s application, but B and C could not pair up together to submit an SVOG 
application. 
 
18. If an entity does not have DUNS numbers for affiliates that will be listed as part of its SVOG 
application, but the affiliates do not qualify for a SVOG (and won’t be applying), does it need to 
DUNS numbers for those affiliates?  
No. If an entity does not currently have DUNS numbers for non SVOG eligible affiliates it is not 
required to obtain such registrations to submit an SVOG application. 
 
19. Does the limit on having no more than five pending applications or receiving no more than five 
SVOG awards per group of affiliated entities apply to government-owned entities? 

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No, the SBA will not limit tribal, state or local governments to having no more than five pending SVOG 
applications or to receiving no more than five SVOGs. SBA’s affiliation principles do not apply to 
governments.   
Supplemental Phase 
1. For seasonally-operated entities, will an alternative earned revenue loss comparison of Q1 2021 
to Q1 2019 method be used for supplemental award eligibility?  
Yes, where an entity operates seasonally rather than year-round, the SBA will permit the seasonally-
operated entity to compare its Q2 2021 earned revenues to its Q2 2019 earned revenues to 
demonstrate whether it has experienced the 70% earned revenue loss required for supplemental 
grants. 
 
2. Can eligible entities include an application for a supplemental grant as part of the initial grant 
request, or will they be required to submit a separate supplemental application later? 
The SBA needs to finish the initial round of awards before proceeding to the supplemental phase and 
the criteria and calculations for issuing supplemental awards are dependent on the outcome of initial 
round. As such, supplemental grants will be awarded pursuant to a separate application process after 
the initial phase.

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