U.S. Treasury, Q&A: Payroll Support Program Compliance Obligations, data collection template (updated July 19, 2020)

Summary

Q&A: Payroll Support Program Compliance Obligations, updated July 19, 2020, a Treasury document on the quarterly compliance reports required under the PSP Agreement. It states that recipients with a PSP Agreement dated June 30, 2020 or earlier must file their first quarterly report by August 14, 2020, through Treasury's CARES Administration Hub. It describes four mandatory sections of the report: Headcount and Compensation Information; High-Income Employees and Corporate Officers of the Recipient and Its Affiliates; Upload Documents; and Certification. It states that failure to provide timely and accurate information may result in Treasury finding a Recipient to be in violation of the PSP Agreement.

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   Q&A: Payroll Support Program Compliance Obligations Updated July 19, 2020

GENERAL DATA COLLECTION QUESTIONS

1. When is the first PSP quarterly report due, and how do I submit it?
   Under the PSP Agreement entered into by every Payroll Support Program participant, the
   recipient must file compliance reports with Treasury on a quarterly basis. Recipients with
   a PSP Agreement dated June 30, 2020 or earlier must file their first quarterly report by
   August 14, 2020. Recipients must submit their report through Treasury’s CARES
   Administration Hub (CARES Hub).               The CARES Hub can be accessed at
   https://portal.treasury.gov/cares. Access to the CARES Hub will become available on July
   19, 2020. For further information about reporting deadlines, see “Q&A: Payroll Support
   Program Compliance Obligations Updated June 30, 2020,” available at
   https://home.treasury.gov/system/files/136/4112-Compliance-FAQs.pdf.

2. What information do I need to provide in the quarterly PSP report?
   The PSP Agreement details the types of information recipients must provide in their
   quarterly reports to Treasury. The CARES Hub covers the reporting requirements in four
   mandatory sections: (1) Headcount and Compensation Information; (2) High-Income
   Employees and Corporate Officers of the Recipient and Its Affiliates; (3) Upload
   Documents; and (4) Certification. Each of these sections is described below. The CARES
   Hub also contains an optional section that allows a recipient to upload additional documents
   or information.

   Failure to provide timely and accurate information may result in Treasury finding a
   Recipient to be in violation of the PSP Agreement.

   The CARES Hub allows a user to save data as the user adds information to the quarterly
   report. The sections do not need to be completed in sequential order. When the report is
   complete and accurate, the user can submit it to Treasury.

   A. Headcount and Compensation Information

      This section primarily enables data entry, with a document upload feature for Recipients
      to provide additional information. Recipients will manually enter data related to
      changes in Employee headcount, Salaries, Wages, and Benefits paid; use of PSP fund;
      and reductions to Salaries, Wages, and Benefits. If a Recipient reports changes to
      Employee headcount, Salaries, Wages, or Benefits paid, the Recipient is required to
      also upload a document providing a more detailed explanation and reasons for the
      change.

   B. High-Income Employees and Corporate Officers of the Recipient and Its Affiliates

      This section requires the Recipient to enter the number of Employees whose total
      compensation is subject to restriction under the PSP Agreement. Recipients must also,
      on an annual basis, provide the number of employees that received either Total
      Compensation or Severance Pay and Other Benefits in excess of the restrictions
      imposed by the PSP Agreement.
    Q&A: Payroll Support Program Compliance Obligations Updated July 19, 2020

   C. Upload Documents

       Pursuant to the PSP Agreement, recipients must provide Treasury with documents
       including financial statements and IRS Form 941. Recipients can upload these
       documents or provide a link to financial reports that are filed in the SEC’s Electronic
       Data Gathering, Analysis, and Retrieval system (EDGAR).

   D. Certification

       In this section, recipients certify their ongoing compliance with the terms and
       conditions of the PSP Agreement, maintenance of effective internal controls related to
       compliance with PSP Agreement, and the veracity and accuracy of any data,
       documents, or information provided to Treasury. The certification must be signed by
       an authorized representative of the signatory entity (the air carrier or contractor that
       executed the PSP Agreement). The certifications can be signed online by an authorized
       representative, or a signed copy can be uploaded.

Important Information: If the Recipient provides any information in its compliance report
that it customarily keeps private or closely held, please identify the information on a PDF and
upload in the CARES Hub.


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