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Can a seasonal employer using an alternative time period for the purposes of calculating their loan make all the required certifications on the Borrower Application Form?
Yes. On April 27, 2020, Treasury issued an interim final rule allowing seasonal borrowers to use an alternative base period for purposes of calculating the loan amount for which they are eligible under the PPP. Instead of following instructions on page 3 of the Borrower Application Form for the time period for calculating average monthly payroll for seasonal businesses, an applicant may elect to use the time period in Treasury’s interim final rule on seasonal workers (between May 1 2019 and September 15, 2019).
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