SBA / Treasury FAQ on Loan Forgiveness / Reductions – 3. When calculating the FTE Reduction Exceptions …do borrowers include employees who made more than $100,000 in 2019 (…Table 2 of the PPP Schedule A Worksheet)?

Compliance > CARES Act
Q:   When calculating the FTE Reduction Exceptions in Table 1 of the PPP Schedule A Worksheet on the Loan Forgiveness Application (SBA Form 3508 or lender equivalent), do borrowers include employees who made more than $100,000 in 2019 (those listed in Table 2 of the PPP Schedule A Worksheet)?
 
A:   Yes. The FTE Reduction Exceptions apply to all employees, not just those who would be listed in Table 1 of the Loan Forgiveness Application (SBA Form 3508 or lender equivalent). Borrowers should therefore include employees who made more than $100,000 in the FTE Reduction Exception line in Table 1 of the PPP Schedule A Worksheet.
 
 
This Q&A was based on information contained in the Treasury Department’s October 13, 2020, version of “Paycheck Protection Program Loans, Frequently Asked Questions on PPP Loan Forgiveness,” which may be updated from time to time.  This CARES Act / SBA / PPP Loan Forgiveness-related issuance may be found here:  https://home.treasury.gov/system/files/136/PPP--Loan-Forgiveness-FAQs.pdf
 

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