The new regulations extending the CTRS to 28 March 2021 have now been published and gazetted.
A copy of the new regulations is available here.
The Gazette entry is available here.
The new regulations appear to simply amend the end date of the existing regulations from 31 December 2020 to 28 March 2020.
It might take a few days to work through any kinks that arise as a result of the amendments and I will post anything as and when it comes to hand.
For now, I think it would be prudent for tenants who are still tenants of eligible leases to make a fresh request for rent relief from their landlords for the period 1 January 2021 to 28 March 2021 before the year end, bearing in mind that:
1. the tenant’s previous request probably only applies to the period ending 31 December 2020; and
2. applications under the current version of the regulations only operate from the date the request is made.
Another issue is whether the tenant’s application for rent relief for the period 1 January 2021 to 28 March 2021 needs to be based on its financials for the quarter ending 31 December 2020 or whether the tenant can rely on the previous quarter’s financials. The amendments have only just been published, so I haven’t had a chance to work through that yet – and the kids need dinner! I will post something about this as soon as I get a chance to work through the amendments more fully.
In the meantime, given the proximity to Christmas, it might be worthwhile for tenants of eligible leases to contact their accountants tomorrow and request an expedited set of December 2020 quarter financials, just in case…
Thanks to Mark Schramm for alerting me to the Regs being passed.
This post originally appeared on Sam Hopper's Blog