Commercial Leasing Bulletin: Update On Pandemic-Related Rent Subsidy Programs

In our October 2021 leasing bulletin on rent subsidy programs (which can be found here), we briefly summarized the announcement by the Federal Government (the "Government") of the Tourism and Hospitality Recovery Program ("THRP") and the Hardest-Hit Business Recovery Program ("HHBRP"). Since we published our bulletin, there have been further developments and clarifications on these programs. This bulletin will review the most important recent updates on the rent subsidy components of these programs.

Bill C-2, An Act to provide further support in response to COVID-19 ("Bill C-2") and the Canada Emergency Rent Subsidy ("CERS")

On December 17, 2021, Bill C-2 received Royal Assent, bringing the THRP and the HHBRP into law. It is now clear that these programs represent a continuation of CERS, but with substantial modifications to the parameters that will govern an entity's eligibility to receive rent subsidies under the programs and how the rent subsidies will be