Currently, the PPP Loan Forgiveness program only allows for 3 period by which to determine your eligibility when factoring a reduction of 25% in your workforce. If you are a seasonal employer, such as a theatre or festival, who would normally not be in full operation during the PPP Period, but are comparing to a period in which you would be in full production, you will almost certainly be unable to meet the 25% reduction threshold. Seasonal employers should be allowed to compare to a similar period in the previous year that most closely reflects the normal operations of the company. Theatres and many cultural institutions do not operate on a quarterly basis with consistent income and a consistent workforce. We need the flexibility to prove that we have retained our normal staff without comparing ourselves to temporary staff that bears no reflection on our current period.
Idea No. 3057