OTA Dispatch Issue 3, 2020

20 Oregon Truck Dispatch Oregon Trucking Associations, Inc. Kirk Faris has been in public accounting since 2006. He specializes in tax compliance and transaction planning for business entities, with an emphasis on flow-through entity structures. He also supports clients with PPP loan forgiveness. He can be reached at 707.535.4186 or kirk.faris@mossadams.com. Biagio Genualdi has worked as an assurance professional since 2014, primarily focused on the apparel industry. He specializes in leading ASC 606 and ASC 842 implementations as well as providing support for clients that have secured PPP loans. He can be reached at 949.623.4163 or biagio.genualdi@mossadams.com. Spike Welton has worked in valuations since 2016. He provides valuations, financial modeling, and contract analysis for clients in a variety of industries and also assists clients with PPP loan forgiveness calculations. He can be reached at 971.313.5052 or spike.welton@mossadams.com . This implies that if an employee’s wages don’t meet safe harbors, the borrower should reduce forgiveness for the full covered period. For example: If a borrower applies for forgiveness at 20 weeks into their 24-week covered period and has wage reductions of 40%, they must multiply 15% (40% wage reduction less 25% threshold) by the full 24 weeks instead of 20 weeks. Average FTE End Date Isn’t Defined It isn’t yet clear how average FTEs are calculated for borrowers applying for forgiveness earlier than 24 weeks because the SBA hasn’t provided an end date for average FTEs. Borrowers that need to make operational decisions regarding FTEs should consider that the SBA may require an alternative calculation or estimate. Some borrowers may find relief from this uncertainty because the FTE reduction safe harbor end date is the earlier of December 31 or the forgiveness application date.  PPP Loan Borrowers, cont.