The basic provisions of the $1.09-trillion American Rescue Plan Act signed into law by President Biden appear to provide “pockets of stimulus that should be helpful to the commercial real estate industry,” the Mortgage Bankers Association’s Mike Flood points out in an article for Trepp. However, there’s the stimulus package on paper and then there’s the question of actually implementing it.

SVP of commercial/multifamily and member engagement at MBA, Flood identifies five governmental entities that will make the Rescue Act happen for the industry, or not, as the case may be. They include four federal agencies and state-level government.

• The Small Business Administration, which will be in charge of administering the $25- billion restaurant grant program. “While the SBA has years of experience in administering grants to small businesses, the restaurant grant program is a new program,” Flood writes.

It’s also a program with limitations that the SBA will need to work through. “Roughly 20% of the fund is earmarked for smaller restaurants with sales below $500,000,” writes Flood. “Also, the SBA must prioritize grants to small businesses owned by women, veterans, or socially and economically disadvantaged small business concerns.”

• Department of Treasury, which will be responsible for administering emergency rental assistance to the states. “Treasury has a process in place that was used during the last stimulus bill in December,” Flood writes. “The question will be how long it takes to administer the monies to the states, and then how long it takes the states to get it into the hands of eligible renters.

• The Centers for Disease Control, administrator of the federal eviction moratorium  currently set to expire on March 31. Writes Flood, “In all likelihood, the CDC – or other federal body – will extend and modify the eviction moratorium. We assume that the current administration would like to see renters receive the rental assistance before letting an eviction moratorium expire. The question will be, how long will it be extended, and how will it be changed?”

• The Consumer Financial Protection Bureau, which recently released a report discussing the apartment market, eviction moratoria, and the ability of renters to make their monthly rental payments. “Such a report suggests that the CFPB will be keeping a keen eye on renters and the multifamily rental marketplace,” Flood writes. “The question is, how far does the CFPB’s jurisdiction extend?”

• Last but not least, there are the state governments, which are set to receive a $220-billion influx of cash from the federal government. “How will they use the funds?” asks Flood. “Will they use the funds to repair deficits? Help the renters and the hospitality industry? Fix power grids? Such decisions will be important to our industry, and we will be pressing state governments to use the funds as intended and help renters, small businesses and the hospitality industry.”