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New Treasury Guidance Provides Relief from Financial Instrument Offering under Payroll Support Program for Small and Mid-Sized Aviation Businesses

Client Alert | 1 min read | 04.14.20

Treasury recently announced additional guidance regarding the Payroll Support Program under Title IV of the CARES Act, which provides payroll support for American workers employed by passenger air carriers, cargo air carriers, and certain contractors to Part 121 air carriers. This guidance modifies Treasury's earlier requirement that applicants offer warrants, options, preferred stock, debt securities, notes, or other financial instruments as compensation for the provision of payroll support. 

Recognizing the difficulty that small and mid-sized aviation businesses face in making such an offer, Treasury decided that it will not require passenger air carriers that receive $100 million or less in payroll assistance to provide financial instruments as appropriate compensation. Because Treasury will not need to evaluate financial instruments proposed by passenger air carriers qualifying for this exception, funds will be available to those air carriers promptly upon approval of their applications.

This exception does not apply to passenger air carriers whose allocated payments would exceed $100 million, or to cargo carriers or contractors. Treasury is expected to provide further guidance for those applicants in the near future. Additional guidance about this program can be found in our previous client alert.

Insights

Client Alert | 4 min read | 05.13.24

Harmonizing AI with EEO Requirements: OFCCP’s Blueprint for Federal Contractors

Now more than ever, federal contractors find themselves at the intersection of innovation and regulation, particularly in the realm of Artificial Intelligence (AI).  AI is now incorporated into a broad range of business systems, including those with the potential to inform contractor employment decisions.  For that reason, the Office of Federal Contract Compliance Programs (OFCCP) has issued new guidance entitled “Artificial Intelligence and Equal Employment Opportunity for Federal Contractors” (the “AI Guide”).  OFCCP issued the AI Guide in accordance with President Biden’s Executive Order 14110 (regarding the “Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence”), which we reported on here.  The AI Guide provides answers to commonly asked questions about the use of AI in the Equal Employment Opportunity (EEO) context.  The AI Guide also offers “Promising Practices,” which highlight a number of important considerations for federal contractors.  Focusing on federal contractors’ obligations and attendant risks when utilizing AI to assist in employment-related decisions, the AI Guide also provides recommendations for ensuring compliance with EEO requirements while harnessing the efficiencies of AI....