Local Churches and the CARES Act – Information from GCFA

In response to inquiries that GCFA staff members have received, we offer the following informational content as you navigate how to proceed with the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

To the extent that a United Methodist local church may need to provide evidence of its 501(c)(3) status as part of the application process for a Paycheck Protection Program loan made available by the CARES Act, or in relation to any other financial assistance that is available pursuant to the CARES Act or any future economic stimulus legislation, it can provide a letter from GCFA stating the local church is included in the denomination’s group exemption ruling. If a local church does not have such an inclusion letter from GCFA, the local church can quickly obtain one via the group ruling website, which is available here:


If all of the information generated through the site is accurate, a local church can obtain a letter in about 5 minutes. If some information is incorrect, a local church can submit a comment to have that information corrected. (Unless a change is needed, a local church should leave the comment field blank, so as to not delay receiving a letter.) We are aware that local churches may need inclusion letters quickly, so we will be closely monitoring the need for any changes and will respond as quickly as possible.

Unfortunately, while an inclusion letter from GCFA does verify that a local church is a 501(c)(3) organization, it does not preclude the possibility that some banks will ask for different supporting documentation or may not understand the significance of the documentation they are being provided by the local church. IRS Publication 4573 provides important information about the meaning of an organization being included in a group exemption ruling. If a local church runs into a problem, providing a copy of Publication 4573 may be helpful in educating the bank, or other relevant entity. That publication is available here:



Payroll Protection Program – Information from GCFA

The GCFA website has resources for churches related to the Payroll Protection Program as offered by the Small Business Administration.  April 3rd was the first day churches could apply and there is a process to follow.  Resources that answer frequently asked questions found on the GCFA site, which are updated constantly, will be the first place to answer general questions about the program: https://www.gcfa.org/about-us/resources-during-covid-19/.  In addition, this video from Moses Kumar shares other resources loaded to the website and how to proceed with applying.  https://youtu.be/ktt1QvrbKio.

Social Media and Pictures of Your Parishioners

How often do you think of the consequences of posting photos of church activities on your church’s web page, Facebook page, Instagram feed, or other social media sites? Probably not often enough to ensure that your actions are protecting the persons in the pictures while publicizing activities and events in the life of your church.

A recent discussion on a moderated listserv centered on this very issue. The original question asked if any church that listserv members were affiliated with had any kind of release statement or form that church members had to sign in order for the church to use their pictures on any social media site, including the church’s web page. Many comments and suggestions were offered by members of this listserv. Several responded that a statement was included in the newsletter and bulletin giving adult members the opportunity to “opt out” of having their picture included. Such statements as, “If you do not wish for any pictures of you to be a part of the XXXXX website, please contact the church office immediately by calling xxxxxxxx, ext10.  Thank you” or “I do not give permission to XXXX Church to include my photo on any social media outlet and in any print publications from the church.” You should always have permission from parents before posting pictures of children and youth on your social media sites, whether or not you use names.

The best answer to this question was posted by Bryan L. Mills Associate General Counsel GCFA:

“Generally, we are not aware of anything that would require your church to receive the permission of the adults featured in photos to be used in such manners. However, we do know that many churches make available a statement or policy regarding such uses of photos, either in a bulletin or on the church’s website. Here are several examples of such statements/policies:






The above examples vary in level of detail and incorporated procedures, but there are some general concepts that emerge:

· The church reserves the right to use photos of large groups without receiving specific permission, especially if no names are used.

· Pictures of smaller groups of adults may require receiving permission first, especially if names are used.

· Pictures of minors will only be used with permission, and often without naming them.

· Regardless of the church’s policies, an individual church member can specifically request to not be featured in any photos.

We are hopeful the above examples and concepts will provide a starting point for your church to develop its own guidelines. (Searching the Internet for “church photography policy” or something similar will produce lots of other useful examples.) Please let us know if there is any other way in which we can be helpful. Thank you.”

If this is a topic you and your church leaders have not discussed in the past, perhaps now is the time to add the use of photos on social media sites to the agenda for your next meeting. . Better to be prepared and be proactive than have to react at a later date.