July 23, 2020
If we have a project that temporarily bumps the FTE count above the baseline period for more than one pay period, does that qualify for restoring the FTEs before December 31?
Posted by Armanino Financial Advisory Team
No. Current rules are that the restoration will be determined based on your FTE count as of either the date you file for forgiveness or December 31, 2020, whichever is earlier. It does not matter if you restored before either of these dates, only if you have restored at the earlier of these two specific dates. Nothing yet has been issued that indicates there is any minimum amount of time required to have restored FTE levels in order to get Safe Harbor.