Independent Schools and PPP Loans: Are You In Compliance With Title IX?


In the wake of the COVID-19 outbreak, many independent schools applied for and received funds from the Paycheck Protection Program (PPP) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The Small Business Association (SBA) has confirmed that recipients of PPP loans will be considered recipients of federal financial assistance, imposing obligations under numerous federal laws and corresponding regulations, including Title IX, Title IV, the Age Discrimination Act, and Section 504 of the Rehabilitation Act of 1973. All independent schools already have nondiscrimination policies and procedures, but those practices do not necessarily comply with the specific requirements under these laws. In particular, independent schools will want to ensure their policies and procedures comply with the Title IX regulations that went into effect on August 14, 2020.

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