How to prepare for the RESTAURANTS Act's financial assistance program

SBA officials hope for early April for the Restaurant Revitalization Fund rollout

With the Shuttered Venue Operators Grant (SVOG) slated to begin accepting applications on April 8—three months after the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act was passed—there is reasonable cause for concern that the Restaurant Revitalization Fund (i.e. that $28.6B set aside for relief in the RESTAURANTS Act) will not be ready soon enough for the ailing hospitality industry.

However, optimistic guidance was provided in last week’s Senate Small Business Committee hearing. During the questioning period, we were presented with a plan to: a) provide more information on next steps for the program over the next 7–10 days; and b) a rollout of the application portion over 30–45 days. In fast forwarding through the hearing, though, I did not pick up an estimate of when the funding would actually be made available to applicants.

What I did gather from the hearing, though, is that the Small Business Administration (SBA) would like for potential applicants, similar to those applying for SVOG, to ready themselves by registering for the federal government’s System for Award Management (SAM). The rationale for such being that the SBA is building a website to handle these applications and that the data set from SAM would help streamline the platform’s processes. In theory, it makes sense to pull information from a single data source that has been in use for quite some time (more on that later), but in actuality, navigating the process for a SAM.gov registration can be very confusing.

After handling a few of these registrations, I can see why The Independent Restaurant Coalition is advocating that the SBA remove the requirement of obtaining a duns number and the SAM registration. All things considered, though, you should probably take the time to register for SAM (and subsequently Data Universal Numbering System [DUNS]) if you’re a restaurant or bar, since it can take some time for a DUNS number to be issued if you don’t already have one.

So that you have some idea of what you’re filing for, I’ve put together a quick primer on DUNS and SAM registrations.

DUNS: Data Universal Numbering System

Developed by Dun & Bradstreet (D&B), DUNS is nine-digit unique ID, which is used as a way to identify businesses on a location-specific basis. The number is assigned for each physical location of a business, and is free for all businesses—commercial, non-profit or government entities, self-employed individuals, branches and divisions—who are registering with the U.S. federal government for contracts, loans, or grants.

If you’re confused about why you have to register for an identifier with a publicly traded company ($DNB) for federal purposes, don’t worry, I was too. The General Services Administration (GSA), which serves to support the basic functioning of federal agencies, uses a contractor to validate entities for federal contracts (since 1978) and those seeking federal financial assistance (since 2008). D&B has been the contractor of choice for the GSA for over the last three decades. However, three years ago, the GSA issued an RFP to explore new options for entity validation, subsequently awarding the contract to Ernst and Young. For the purposes of the Restaurant Revitalization Fund, I would not be concerned about DUNS vs. the new identifier called the SAM Managed Identifier (SAMMI), as the transition date shifted from December 2020 to April 2022.

In some cases, you might already have a DUNS number issued. The first step you should take is to run a quick search, which can be done here. If you find that a DUNS number has already been issued for your business (be sure to make sure your corporation name and address match your tax records), then you can click the button on the right that says “Email D-U-N-S Number”, which will land immediately in your inbox.

Otherwise, you will have to register for an account (be sure to opt for the free option) in order to get a DUNS number. After creating your account, you will see that you need to have a few pieces of information readily available:

  • Business name and contact/location info

  • Year business started

  • Number of employees

  • Business structure and relevant information

    • For instance, if you are a corporation, you will have to list names of all officers/shareholders and their ownership %

  • Two legal documents with business name and address clearly indicated for proof

The D&B website says it should take 1–2 business days to process the request, but I would probably give it a few more days given that a lot of small businesses may be filing for their numbers now.

“The public’s one account for government.”

Before you move on to SAM, you’ll need to first create an account with the government via login.gov. Yes, SAM uses your login.gov credentials, but you have to create your username and password at the main website. Once that’s done, you’ll be good to move onto the next step: registering with SAM.

SAM: System Award Management

SAM is a large database that includes every entity that is registered to do business with or receive financial assistance from the federal government. Launched in July 2012, SAM folded in several legacy systems into its portal, including Central Contractor Registry (CCR), to form one e-procurement system. And just like everything else thus far, there is no fee associated with registering with SAM.

When you log onto sam.gov for the first time with your login.gov credentials, you’ll be asked to create a username and provide details for the Entity Administrator’s individual user account (yes, it’s basically a user profile within the login.gov framework). Please note that whoever’s name and email is listed with the individual user account will be the one listed in the to-be notarized SAM registration letter for the Federal Service Desk.

After creating your SAM user account, you will see in the left rail that there is an option called “Entity Registrations”. Click on it and a sub-menu will unfurl where you will be able to select “Register New Entity”. When prompted for the reason for your application, select the option that says you are only applying for Federal financial assistance opportunities (as opposed to the other one that is for government contracts).

The requested information is pretty straightforward, but you will want to make sure you have the following information on-hand during this process:

  • DUNS number

    • Make sure that the address you input matches with what D&B has on record for you. I spent a good ten minutes getting frustrated that the DUNS number wasn’t being recognized before realizing that the matching is so sensitive that “Street” vs. “St.” are different values for DUNS numbers

  • Start date of your business

  • EIN and most recent filed tax year for the IRS TIN Match (validation of Taxpayer Identification Number and Taxpayer Name)

  • Commercial and Government Entity (CAGE) Code: you most likely will not have one. If you have one, put it in; otherwise, one will be assigned to you

  • Banking information for ACH deposits and remittance address in the event that a paper cheque is sent

After submitting your entity registration, over the next few days, you will receive emails that confirm your IRS TIN Match Validation and issue you your CAGE Code. The CAGE Code is yet another unique identifier within government agencies, but is issued by the DoD’s Defense Logistics Agency. The identifier represents your company’s physical address for mailings, payments, and administrative records within the GSA ecosystem.

Remember when I mentioned something about a notarized letter? You can use the template for a single entity or the template for multiple domestic entities, courtesy of the Federal Service Desk. When you’ve made the necessary edits, per the templates’ instructions, including putting this letter on company letterhead, you can go ahead and print out a copy to have it notarized and then scanned for you to submit digitally.

Head to fsd.gov and use your login.gov credentials—this universal login is pretty useful! What you will want to do next is to “Create an Incident” and then make the two key following selections:

  • System Name: SAM

  • Issue Type: Notarized Letter

When you’ve attached your scanned letter and hit the “Submit” button, you are good to go. At this point, I’d like to congratulate you: the registration for SAM is complete!

What’s next?

Well, now we wait.

Hopefully, over the next two weeks, we’ll have more guidance from the SBA.

In the event that the SBA waives the requirement for DUNS and SAM registration (although I highly doubt it), then you’ll have needlessly endured an extra level of angst with me. Otherwise, hopefully, this explanation of the many systems in place and my detailed walkthrough was helpful has readied you for the next step in applying for the Restaurant Revitalization Fund.

Further reading: