No. To ensure that borrowers are not doubly penalized, the salary/wage reduction applies only to the portion of the decline in employee salary and wages that is not attributable to the FTE reduction.
- Example: An hourly wage employee had been working 40 hours per week during the borrower selected reference period (FTE employee of 1.0) and the borrower reduced the employee’s hours to 20 hours per week during the covered period (FTE employee of 0.5). There was no change to the employee’s hourly wage during the covered period. Because the hourly wage did not change, the reduction in the employee’s total wages is entirely attributable to the FTE employee reduction and the borrower is not required to conduct a salary/wage reduction calculation for that employee.
Note: borrowers with loans $50,000 and under do not need to incorporate FTE or salary/hourly wage reductions into their overall requested loan forgiveness amount, unless they - together with affiliates, if applicable - received First Draw PPP Loans of $2 million or more or Second Draw PPP Loans of $2 million or more.