July 23, 2020
I have three questions about qualifying to use the EZ loan forgiveness application using the second certification criterion. First, this requires that we “did not reduce number of employees or the average paid hours”. Does “number of employees” refer to FTEs or actual headcount? Second, does use of the word “or” mean the borrower can qualify with either of these or does he have to quality with both? Third, this certification also puts the time period as “… between January 1, 2020 and the end of the Covered Period”. When is the end of the Covered Period?
Posted by Armanino Financial Advisory Team
To the first question, the answer is number of employees equals actual headcount. It is not “FTEs”. For your second question, we will need additional SBA guidance. Use of the word “or” can be construed in either way you mention; preliminary interpretation suggests that “both” are required, but this is by no means a definitive interpretation. Finally, the end of the Covered Period is the date either 56 days or 168 days from the date the PPP loan was funded.