A housing association representing the richest zip code in America was approved to receive a $2 million emergency coronavirus relief loan from the Small Business Administration, despite suffering no layoffs and no apparent financial impact from the coronavirus pandemic.

The Fisher Island Community Association, which manages the members-only private island off the Miami coast that can only be reached by helicopter or boat and once counted Oprah Winfrey as a member, was approved for a Paycheck Protection Program loan intended to help small businesses who had shuttered, laid off workers, or furloughed staff due to the viral outbreak.

The association is responsible for maintaining the 216 acres of grounds and beaches, plus the common areas and swimming pools and 18 tennis courts for the island’s 800 families. Ana Tinsly, a spokesperson for public services union SEIU Florida, said earlier this week that she was not aware of any layoffs, according to The Miami Herald.

The $2 million loan comes as scrutiny mounts over the structure of the government’s emergency program, which allowed many companies with strong cash flow to receive millions of dollars in forgivable loans while small businesses desperate for cash were shut out.

The Potbelly chain of sandwich shops, which has more than 400 locations and reported $409.7 million in revenue last year, received $10 million in a forgivable relief loan. Hydrogen truck start-up Nikola Motors, recently valued at $3 billion, received a loan of $4 million.

After names of publicly traded companies which had received funds started making headlines, Secretary of the Treasury Steven Mnuchin warned there would be penalties unless they gave the money back.

Shake Shack recently said it would return its $10 million loan. Bowing to public pressure, other companies announced they intended to return their loan. Ruth’s Chris Steak House, a chain that has 150 locations, said it will return its $20 million loan. Sweetgreen, a fast casual salad restaurant, said this week it will return its $10 million loan.

Under the terms administered through the Small Business Administration, the loan is fully forgiven if 75 percent of the funds are used to cover payroll. Applicants must have fewer than 500 employees per location.

Treasury Secretary Steven Mnuchin and SBA Administrator Jovita Carranza have defended the program as complaints from small businesses mounted that they hadn’t been approved through the program. Mnuchin and Carranza said that “The vast majority of these loans — 74 percent of them — were for under $150,000, demonstrating the accessibility of this program to even the smallest of small businesses.”

The Treasury Department updated its guidance on Thursday, urging companies with “substantial market value and access to capital markets” to act in “good faith that their PPP loan request is necessary.” The agency said any company that gives the money back before May 7 will be deemed to have acted in good faith.

Fisher Island Community Association polled residents on whether to accept the $2 million payout, ahead of the board’s scheduled meeting on Friday evening.

FICA did not immediately respond to a request for comment from NBC News.

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