How Much Did Capital Plus Financial Make From Pandemic Relief?

I. About $930 million in, and two counts of what stayed

Capital Plus's parent, Crossroads Systems, reported that the group had "earned fees from the program totaling approximately $930.0 million" in the nine months to July 31, 2021 (Q3 FY2021 disclosure statement). Priced loan by loan under the published fee schedules, the 395,359 loans that the SBA's loan-level file books to Capital Plus come to $937.3 million, sixth among 4,688 originating lenders (Capital Plus lender page; PPP lenders by estimated fees). The series ranking of fee collectors adds agents and contractors and ranks each on its fees after payments to agents, taking Capital Plus's figure from its parent's books, where every PPP line sits in Capital Plus's column. There it is 23rd. Womply, which lent nothing and billed its lenders $1.8 billion to $2.6 billion for 2021, is first, ranked on its billings and covered in its own piece.

Crossroads' accounts later spread Capital Plus's fees over three fiscal years. Capital Plus recognized $868.4 million in the year to October 31, 2021, $50.8 million in 2022 and $10.0 million in 2023, and was still deferring $10.6 million at the end (FY2021 annual disclosure; FY2023 audited financials). The model and the books agree within 1 percent.

What Capital Plus was left with has two answers, from two kinds of document:

Question	Figure	Basis	Kind
What did the SBA pay Capital Plus?	$937.3 million	SBA loan-level file, priced loan by loan	modeled
	$929.2 million recognized in fiscal 2021–2023, plus $10.6 million deferred	Crossroads group audited accounts; all in Capital Plus's column of the consolidating schedules (fiscal 2021 schedule unaudited)	reported
What did Capital Plus book as paid or owed to its service partners?	$623.5 million	"PPP processing fees," fiscal 2021–2023, Capital Plus's column	reported
What was left on Capital Plus's books, before interest and taxes?	$305.7 million	the two reported lines above; the group's income tax is booked at Crossroads	reported, subtracted
What was left after the $386 million Blueacorn reported receiving from it?	$551.3 million	modeled fees less Blueacorn's receipts, as the House report gives them	modeled less reported
And after Womply's $76.7 million claim as well?	$474.6 million	the same, less Womply's claim; holds only if Capital Plus bore that fee separately (section IV)	modeled less claimed

Most of the difference between $305.7 million and $551.3 million is fee expense that Capital Plus booked without naming the payee: its $623.5 million is $237.5 million more than the $386 million Blueacorn reported receiving. The other $8.1 million is the model's fees running above the fees Capital Plus recognized ($937.3 million against $929.2 million). At October 31, 2021, the group carried $256.2 million of "Lender Service Provider Fees" as accrued and unpaid (FY2021 annual disclosure, note 8). Two years later the group still carried $80 million "in fees due to BlueAcorn," which it said it disputed (FY2023 audited financials, note 19). Crossroads' disclosures do not split the $623.5 million by payee.

The $305.7 million is the difference between two lines of Crossroads' audited group accounts. That both lines are Capital Plus's comes from the consolidating schedules, which were unaudited for fiscal 2021 and examined by the auditor for fiscal 2022 and 2023. The higher figures subtract from the model only what a document shows paid or claimed.

Whose books. Capital Plus Financial, LLC is the lender. Crossroads, a Delaware holding company, has owned its common equity since December 2017 and publishes one set of consolidated statements for the group, with a consolidating schedule that gives each company a column. Every PPP fee and every processing-fee expense in those schedules is in Capital Plus's column, so the fee figures above are Capital Plus's. Profit is different. In fiscal 2020, before its first PPP loan, Capital Plus's own net income was $6.2 million. In fiscal 2021 Capital Plus's column shows net income of $264,972,022, before any income tax, because the group's tax sits in Crossroads' column. The group's consolidated net income was $195,398,349, after $47,209,875 of tax and a $20,798,948 management bonus, both booked at Crossroads. Crossroads' own figure for the program, "Net Income from PPP," was $256,860,836. The fiscal 2021 schedule is unaudited; the auditor expressed no opinion on it (FY2021 annual disclosure, Schedules I and II, notes 6 and 8).

II. Who paid Capital Plus, and whom it paid

The SBA paid the processing fee to the lender and to no one else. For loans made on or after December 27, 2020, a loan of $50,000 or less earned its lender "the lesser of fifty (50) percent or $2,500." The SBA had to pay "not later than 5 days after the reported disbursement of the PPP loan" and could not ask for the fee back "unless the lender is found guilty of an act of fraud in connection with the PPP loan" (86 FR 3692; 86 FR 3712). In 2020 the same small loan had paid 5 percent (85 FR 20811).

The median Capital Plus loan was $19,332. Under the 2020 schedule it would have paid its lender $966.60. Under the 2021 schedule it paid $2,500.

Capital Plus did not find those borrowers. Blueacorn, founded in April 2020 by the House report's account (p. 21), did, through its subsidiary Fin Cap, Inc., under a lender service provider agreement with Capital Plus signed in January 2021. Crossroads was not a party. The agreement, as the House report quotes it, had Blueacorn provide "staff services" to Capital Plus "to carry out certain functions related to the PPP Loan Portfolio rather than hiring employees directly for those same staff functions" (House report, p. 22). Blueacorn's lawyers described the pay in a letter to the Subcommittee of January 12, 2022: "an initial 20% share of SBA fees received by Capital Plus for each loan (with 50% of this amount held back until the borrower applied for SBA forgiveness for the underlying loan)," then "41% of the remaining SBA fees (and 8% for two of Blueacorn's initial founders, who had since exited)" (Subcommittee's Blueacorn documents).

On a $2,500 fee, Blueacorn's share was $500 plus $820, or $1,320: 52.8 percent. The founders' 8 percent was not Blueacorn's. Under a settlement of April 12, 2021, the founders' companies allege, Capital Plus paid it to YXS Investments, Inc., and at YXS's request the money went to companies of Michael Cota and James Flores, whom the House report calls Blueacorn co-founders (YXS Investments, Inc. v. Capital Plus Financial, LLC, N.D. Tex. No. 4:24-cv-00664-P, complaint, paras. 20–24). It came to $160 if it ran on the fees left after the first 20 percent, as the letter can be read, or $200 if it ran on the whole fee, as the complaint describes it. Capital Plus kept $980 to $1,020, 39 to 41 cents of each fee dollar, before its own costs.

Womply came in late, and through Blueacorn. Its Order Form with a different Blueacorn company, BA Fin Orion, LLC, dated May 10, 2021, gave Womply "the first $250 from any Lender Processing Fee, plus 1/3 of the remaining Lender Processing Fee after the $250 is subtracted," with a 1 percent referral fee counted inside that amount (Womply's First Amended Complaint, N.D. Tex. No. 3:21-cv-02636, para. 65; the Order Form's worked example is quoted in the court's opinion, p. 17). On a $2,500 fee, that is $1,000. By Blueacorn's account, the fee was Blueacorn's to pay: its lawyers told the Subcommittee that Womply "was to receive payment from Blueacorn upon Blueacorn's receipt of payment from Blueacorn's lending partner" (letter of March 25, 2022). Womply's contracts, as its complaint quotes them, set the same timing (para. 69). The complaint also alleges that Donnelly, for Crossroads and Capital Plus, "promised to pay Technology Fees" (para. 150), and that Blueacorn refused to pay while "waiting for payment from Capital Plus" (para. 6).

A third channel was small. Capital Plus "partnered with a handful of banks that referred loans to the Company," processed on "a third-party platform"; it "paid an administration fee to the platform provider and the SBA authorized referral fees to the banks." About 500 loans came that way (FY2021 annual disclosure, note 6).

The money to lend came from the Federal Reserve, and Capital Plus was the borrower. Crossroads reported that "[t]he Company" (the group) "borrowed $6.4 billion from the Federal Reserve Bank of Cleveland to fund the" loans through the PPP Liquidity Facility (Q3 FY2021 disclosure statement). The Federal Reserve's own reports name the institution as "PPPLF CAPITAL PLUS" of Bedford, Texas, with advances of about $6.46 billion between February and July 2021, and Crossroads' consolidating balance sheet puts the facility in Capital Plus's column (Federal Reserve Board, PPPLF transaction-specific disclosures; FY2021 annual disclosure, Schedule I). The loans paid 1 percent and the facility cost 0.35 percent. In fiscal 2021 the spread produced $26.8 million of PPP interest income against $10.2 million of facility interest (FY2021 annual disclosure, note 6). That is interest, and it stays out of the fee figures.

III. 395,359 loans, and where they came from

The SBA file does not record who referred a borrower, so the channel counts come from the parties:

Count	Loans	Source
Applications Blueacorn submitted to the SBA for Capital Plus	521,221	Capital Plus's counsel to the Subcommittee, July 22, 2022 (House report, p. 42 and n. 119)
Approved by May 31, 2021, by Crossroads' count	472,036	Q2 FY2021 release
"Issued and approved," by the September 2021 count	389,254, with 82,782 more applications withdrawn	Q3 FY2021 release
Loans in the SBA file	395,359 ($6.21 billion)	SBA loan-level data
of which referred by Womply, through Blueacorn	86,521 ("over $950 million")	Womply's complaint, para. 72; opinion of May 11, 2022
of which referred by partner banks	about 500	FY2021 annual disclosure, note 6
of which from Blueacorn's own funnel	about 308,300	the remainder
Bought from Hanmi Bank, serviced but not originated	1,402 ($132.7 million)	SBA file; FY2021 annual disclosure, note 6

The 472,036 and the 389,254 describe the same pipeline: the two September figures add up to the June one.

Blueacorn told the Subcommittee that it processed the Womply loans "at a point when Womply's portfolio of non-CDFI lenders no longer had the ability to make loans for borrowers already in processing" (letter of January 12, 2022). The same letter says they "were reviewed and underwritten by Womply without any involvement from Blueacorn." Capital Plus was a community development financial institution, and Crossroads' July shareholder letter thanked "the administration's intentional efforts to give CDFIs an unobstructed head start in the latest PPP round and a similar landscape to finish PPP."

The SBA file dates every one of the 395,359 approvals to 2021: 190 in January, 996 in February, 118,434 in March, 181,595 in April, 94,134 in May and 10 in June. On one day, May 20, 2021, it records 34,683. Of the whole book, 343,081 were first-draw loans and 52,278 second-draw; 369,662, or 93.5 percent, went to sole proprietors, independent contractors and the self-employed; and 342,455, or 86.6 percent, paid Capital Plus exactly $2,500.

On Womply's own figures, the loans it referred paid less per loan than the rest. Womply pleaded, on information and belief, that Capital Plus received $186,882,948 in fees on its 86,521 loans, which is $2,160 a loan; the court's opinion recites the same figure. The remaining 308,838 loans come to $750.4 million on the model, about $2,430 a loan. Womply's claim of $76,714,482.67 is 41 cents of each fee dollar on its loans, the same share Womply's money article derives from the Order Form.

IV. The model and what moves it

Capital Plus's $937.3 million on $6.21 billion of loans is 15.1 cents for each dollar lent; on the same model JPMorgan Chase, the largest fee earner among lenders, was owed 4.1 cents a dollar on $41.6 billion of its own loans (PPP lenders by estimated fees). At the 2020 rate of 5 percent, the same 395,359 loans would have paid $307.9 million. The 2021 rule added $629.5 million (The 2021 fee schedule). In fiscal 2021 Capital Plus booked $628.1 million of fees to its service partners.

What stayed moves with three things.

What Capital Plus finally paid Blueacorn. The $386 million comes from Blueacorn's own cash-flow statement for January 1, 2021, to February 28, 2022, as the House report describes it; the statement itself is not public (House report, p. 23 and nn. 152–153). The Crossroads group later accrued another $80 million as due to Blueacorn, while disputing that it was owed (FY2023 audited financials, note 19): $466 million in all. The modeled $937.3 million covers the 395,359 loans Capital Plus originated and already leaves out the 1,402 loans bought from Hanmi Bank. At the 52.8 percent implied by Blueacorn's letter, Blueacorn's share of it comes to about $494.9 million; at the 47 percent of the Schedule A that the YXS complaint quotes (para. 19), about $440.5 million. Neither figure includes the founders' 8 percent, which went to YXS. The roughly 500 bank-referred loans are not identified in the SBA file. Even if they were the 500 largest loans in the book, their fees would total at most $6.5 million, or $3.4 million at 52.8 percent. (All computed from the loan-level fee model and the rates quoted above.)

Set beside the $466 million, the 52.8 percent rate leaves about $25 million to $29 million unaccounted for, and the 47 percent rate leaves nothing. That difference is a reconciliation item, not a finding of underpayment. Part of Blueacorn's share was held back until borrowers applied for forgiveness, any payment Capital Plus made after February 2022 would reduce the difference, and no document we have shows those payments.

The $80 million arbitration. Blueacorn (the contracting company is Fin Cap, Inc.) filed a demand for arbitration against Capital Plus in March 2023, "claiming fees owed," and Capital Plus counterclaimed in May 2023. The hearing was set for February 2024 (FY2023 audited financials, note 19). The arbitrator issued a Final Award on April 29, 2024, and in May 2025 the federal court in Phoenix confirmed it and entered judgment for Blueacorn against Capital Plus (order; amended judgment). The award is under seal, so its amount is not public. Fin Cap's application to confirm it says that "a portion of funds has been paid and resolved" between Capital Plus and Blueacorn, without saying how much (application, para. 10).

Womply's $76.7 million. The low end of the model-based range, $474.6 million, subtracts Womply's claim on top of Blueacorn's $386 million. Blueacorn's lawyers described Womply's fee as payable by Blueacorn once Capital Plus had paid it, and Womply's contracts set the same timing, but Womply alleged that Capital Plus had also promised to pay (section II). The low end is therefore correct only if Capital Plus bore the fee separately, for instance in the settlement described in section VI, whose terms are not public.

The SBA file lists 46,727 Capital Plus loans, $826.5 million, as charged off. The model puts the fees on them at $113.1 million. Under the rule quoted above, the lender keeps a fee unless it is found guilty of fraud on the loan. And 324,195 loans show forgiveness totaling $5.01 billion.

V. What the House Subcommittee said

The House Select Subcommittee on the Coronavirus Crisis gave Capital Plus its own section in its staff report of December 1, 2022, headed "Capital Plus, Which Had Primary Responsibility for Overseeing Blueacorn Under PPP Program Rules, Reaped Windfall Profits While Not Conducting Sufficient Oversight" (House report, p. 42). It said:

• Capital Plus was "a small, for-profit CDFI with 34 full-time employees." The report cites Capital Plus's counsel and Crossroads' fiscal 2021 disclosure, which gives 34 as the count for the whole consolidated group. Capital Plus told the Subcommittee it "relied on Blueacorn's technological solutions to determine borrower eligibility and combat fraud efficiently and at scale" (pp. 42–43).
• Capital Plus told the Subcommittee it "does not maintain statistics regarding the number of PPP loan applications that were manually reviewed by Capital Plus personnel to verify eligibility or to identify fraud" (p. 43).
• Capital Plus said "senior leadership regularly discussed combating potential fraud," but no minutes were kept, and it declined to provide the amounts budgeted for and spent on anti-money-laundering, Bank Secrecy Act, eligibility verification and fraud compliance work (p. 43).
• Capital Plus hired Everett Advisors, "the same consultancy retained by Blueacorn," to audit its antifraud and compliance programs (p. 43).
• Capital Plus "issued hundreds of thousands of dollars in loans to Blueacorn's principals and their businesses." Its chief financial officer, Farzana Giga, "signed off on the loan to Mr. Reis where he inaccurately described himself as an African American and a veteran." Capital Plus told the Subcommittee it was "made aware" of the founders' loans "through an unidentified source sometime after they were approved" (p. 43).

Earlier in the report, the Subcommittee recorded that Giga asked Blueacorn on June 8, 2021, for a list of loans to its insiders, and that Blueacorn identified 11. It added that Nathan Reis and Stephanie Hockridge repaid "PPP loans totaling over $100,000" in July 2021 at Capital Plus's request (pp. 37–38). It also quoted an academic study that found "the four largest FinTech lenders, Cross River [Bank], Prestamos [affiliated with Blueacorn], Harvest [affiliated with Womply], and Capital Plus [affiliated with Blueacorn] exhibited high rates of misreporting and large lending volume growth" (p. 16).

The Subcommittee's findings carry no penalty. On December 8, 2022, the SBA said it had "immediately suspended non-lenders Blueacorn and Womply" and "launched a full investigation" of eight lenders, Capital Plus among them (SBA statement). By the account in the Crossroads group's audited statements, Capital Plus signed a "Voluntary Agreement" for enhanced supervision on January 6, 2023, and the SBA paused all of its guaranty purchase requests during the review. The same statements say the SBA told Capital Plus on August 28, 2023 that the review had concluded "with no material adverse findings" (FY2023 audited financials, note 19); we found no SBA record of this. Crossroads' quarterly disclosures in 2022 also said that "Congress and the Department of Justice are investigating paycheck protection program lending, including the Company's subsidiary, Capital Plus Financial" (quarterly disclosure, January 31, 2022).

The criminal cases went to Blueacorn's founders. Reis's factual resume stipulates that "through Blueacorn, Reis and his coconspirators submitted and caused to be submitted PPP loan applications that they knew contained materially false information in order to make more money, causing Lender-2, based in Bedford, Texas to transfer loan funds to borrowers" (factual resume). The resume does not name Lender-2. Capital Plus's own PPP loan, from Simmons Bank in 2020, lists a Bedford address (SBA loan-level file). Capital Plus was not a defendant in that case.

Borrowers sued it from the other direction. In Greathouse v. Capital Plus Financial, a proposed class sued Capital Plus, Crossroads, Donnelly and Crossroads' chairman, Robert Alpert, alleging that the lender failed to fund loans the SBA had approved. On September 6, 2023 the court dismissed the unjust-enrichment claims and, at the pleading stage, held that the complaint alleged actual fraud well enough to keep the claims against Crossroads; the same day it denied class certification. The parties settled, and the case was dismissed with prejudice on May 22, 2024 (case filings).

VI. Womply's suit over its $76.7 million

Womply sued Capital Plus Financial, LLC; its parent, Crossroads Systems, Inc.; Eric Donnelly, Crossroads' chief executive, who had run Capital Plus until August 30, 2021 (Womply's amended complaint, para. 14); BA Fin Orion, LLC d/b/a Blueacorn; and Blueacorn's Barry Calhoun in Dallas County on September 9, 2021; the defendants removed the case to federal court (notice of removal). Womply's amended complaint claimed $76,714,482.67, "approximately $9 million" under the referral contract and "approximately $67 million" under the technology contract (First Amended Complaint, paras. 6 and 79).

Womply alleged that on a May 11, 2021 call, Donnelly and Calhoun represented that the SBA fees on its loans would go into an account held jointly by Blueacorn and Capital Plus, which Womply could see. The fees, it alleged, went instead to "an account controlled solely by Capital Plus" (paras. 8 and 58). It alleged that Capital Plus "saw an opportunity to reap a massive windfall for itself, claiming for the first time that Capital Plus was prohibited by SBA rules from paying Blueacorn," and called it "a money grab, plain and simple" (para. 7). These are allegations. Capital Plus's position, as the court summarized it, was that the technology fee "compensated Womply for processing applications and referrals[,] . . . the same bundle of services," and so fell under the SBA's 1 percent cap on agent fees (opinion). Agents who sued lenders for their 1 percent had lost.

The court dismissed Blueacorn and Calhoun for lack of personal jurisdiction on April 11, 2022 (order). On May 11, 2022, Judge Jane Boyle split the rest. She dismissed five claims without prejudice, holding that "the statutory and regulatory framework forecloses Womply's claims for SBA Fees from Capital Plus, since Womply did not directly contract with Capital Plus." She kept the claims for a declaratory judgment, tortious interference, fraud and civil conspiracy. On the fee question she found "the Referral Fees and Technology Fees are for distinct services," and, "based on the information before the Court at this stage of litigation," did "not find the SBA regulation clearly precludes the collection of a Technology Fee" (opinion, pp. 15–19).

That was a ruling on the pleadings. The parties settled, and the case was dismissed with prejudice on January 5, 2023 (N.D. Tex. No. 3:21-cv-02636-B, Doc. 156). The terms are not public, so no document says how much of the $76.7 million Capital Plus, Crossroads, BA Fin Orion or anyone else paid. The dismissal order records no finding against any party, and a settlement is not an admission by either side.

VII. What Crossroads said, and what Crossroads paid out

In its July 2021 shareholder letter, covering the quarter to April 30, Crossroads wrote that "the approval process was an incredibly secure one." It added that "we would rather have frustrated applicants than fraudulent borrowers," and that active fraud cases were "less than .25bps" (Q2 FY2021 shareholder letter). Applied to the 472,036 loans in the same letter, that rate is about 12 loans. The letter also spoke of "the windfall associated with the PPP loan program." Womply's amended complaint used the word in December 2021, and the House report's heading used it in December 2022.

The September 2021 letter said Capital Plus had "detected, reported, and stopped over 80,000 applications that were withdrawn due to insufficient data or other reasons." The next paragraph said: "To date, not a single one of the applicants we have worked with has been turned away" (Q3 FY2021 shareholder letter).

The July letter also concluded that "we are now overcapitalized" and announced "a special dividend of $40 per share on July 26, 2021," paid by Crossroads to Crossroads' shareholders (Q2 FY2021 shareholder letter; dividend release). On 5,971,994 shares that is $238,879,760: 1.22 times the Crossroads group's consolidated net income for the fiscal year, $195.4 million, and 0.90 times the $265.0 million in Capital Plus's column. At that year's end, $256.2 million of fees owed to Capital Plus's service providers was still unpaid.

Crossroads itself had no revenue that year and $20,649 of cash at its start. At the year's end its column showed $548,770 of cash and an "intercompany payable" of $304,252,816 owed to Capital Plus, up from $21,553,266 a year earlier; consolidation cancels the balance, so the group's statements do not show it (FY2021 annual disclosure, Schedule I, unaudited). No statement calls the balance a loan or says what it paid for. Two parties claiming money from Capital Plus later called it one. Fin Cap did so in a 2023 Texas court application, and Blueacorn's departed founders' companies alleged in 2024 that Crossroads funded the dividend and bonuses "by causing its subsidiary Capital Plus to make a $335 million intercompany 'loan' to Crossroads" and asked a court to void it as a fraudulent transfer (YXS Investments v. Capital Plus, N.D. Tex. No. 4:24-cv-00664-P, complaint, paras. 47 and 75). The $335 million matches the balance on July 31, 2022. The court denied a partial motion to dismiss by Capital Plus in September 2024, in an order whose reasons the free docket does not show, and no court decided whether the claim was true before the case closed in February 2025. The Greathouse ruling in section V reached similar allegations only at the pleading stage.

The group's income statement for fiscal 2021 has a line for "Management bonus": $20,798,948, booked in Crossroads' column, although Donnelly's and Giga's employment agreements are with Capital Plus (Crossroads' 2022 proxy statement). Salaries and wages that year were $3,841,942. Donnelly's reported compensation was $9,249,474, of which $8,899,474 was a bonus, and chief financial officer Giga's was $9,199,474, including a bonus of the same $8,899,474. The two bonuses and a $3 million accrual make up the management-bonus line to the dollar (FY2021 annual disclosure, Item 11 compensation table and management's discussion). Capital Plus, the certified CDFI, also booked $1,826,265 of "Grant income - CDFI rapid response program."

On the $80 million it had accrued for Blueacorn by October 31, 2023, Crossroads' audited statements for fiscal 2023 say: "While the Company disputes that these amounts are owed, the Company has maintained this accrual pending the outcome of the arbitration." On July 31, 2024, the accrued liabilities in Capital Plus's column of the group's consolidating balance sheet were $69,978,515, less than that accrual alone (financial statements for the quarter to July 31, 2024).

Method, and what would change the numbers

Modeled. Capital Plus's fees are the SBA PPP loan-level file (release of September 30, 2024) priced loan by loan under 86 FR 3692 and 86 FR 3712, with every loan that shows a disbursement counted; the same method produces the fee ranking and the lender page. All of Capital Plus's loans were approved in 2021, so no 2020 fee applies. The 2020-schedule comparison prices the same loans at 5 percent. The channel figures and the fees on the non-Womply loans are subtractions from the file totals.

Reported. The fee income, fee expense, accruals, dividend, bonus and compensation figures are from Crossroads' own statements, which cover the group: its FY2021 annual disclosure statement, its FY2023 audited consolidated financial statements (which carry fiscal 2022 as the comparative year), and its 2021 releases and shareholder letters. Which company each figure belongs to comes from the consolidating schedules in the same documents: the fiscal 2021 schedule is unaudited, and the fiscal 2022 and 2023 schedules were examined by the auditor. The PPP fee lines, the PPP Liquidity Facility and the loans sit in Capital Plus's column; the dividend, the income tax and the management bonus sit in Crossroads'. The 1,402 loans bought from Hanmi Bank earn no processing fee for the buyer; the file lists Hanmi as their originator, and their total, $132,740,429, matches the purchase Crossroads disclosed to the dollar.

Documented by others, and claimed. Blueacorn's $386 million is its unaudited cash-flow statement as the House report describes it. The contract terms are Blueacorn's lawyers' description, and the 47 percent is Schedule A as the YXS complaint quotes it. Womply's $186,882,948 and $76,714,482.67 are its pleading; the court recited the first and ruled on neither.

Documents that would close the gaps. The payee split of Capital Plus's $623.5 million of processing-fee expense; an account of the intercompany balance between Capital Plus and Crossroads; the Capital Plus–Blueacorn agreement (BA-SSCC-0000026-40); the sealed Blueacorn arbitration award; and the Womply settlement agreement.

Sources: Crossroads Systems / Crossroads Impact Corp.: FY2021 annual disclosure statement, FY2023 audited consolidated financial statements, Q3 FY2021 disclosure statement, quarterly disclosure statement for the quarter ended January 31, 2022, Q2 FY2021 release, Q3 FY2021 release, Q2 FY2021 shareholder letter, Q3 FY2021 shareholder letter, special dividend release, July 15, 2021, quarterly disclosure statement for the quarter ended July 31, 2022, 2022 notice of annual meeting and proxy statement; Federal Reserve Board, PPP Liquidity Facility transaction-specific disclosures (2021); Select Subcommittee on the Coronavirus Crisis, "We Are Not the Fraud Police" (Dec. 1, 2022); Select Subcommittee, Blueacorn documents (Sidley Austin letters of Jan. 12 and Mar. 25, 2022); SBA statement, Dec. 8, 2022; Oto Analytics, Inc. d/b/a Womply v. Capital Plus Financial, LLC, N.D. Tex. No. 3:21-cv-02636-B (notice of removal, First Amended Complaint, order of Apr. 11, 2022, memorandum opinion and order of May 11, 2022; order of dismissal, Jan. 5, 2023, Doc. 156); YXS Investments, Inc. v. Capital Plus Financial, LLC, N.D. Tex. No. 4:24-cv-00664-P (complaint, Doc. 1, July 17, 2024); United States v. Reis & Hockridge, N.D. Tex. No. 4:24-cr-00287-O (factual resume); Greathouse v. Capital Plus Financial; SBA PPP loan-level FOIA data (2024-09-30 release), priced under 85 FR 20811, 86 FR 3692 and 86 FR 3712; Womply's PPP fees, lender by lender; Womply loan count; Blueacorn network page. The House report is a partisan staff document released by the Democratic majority's staff in the final weeks of the 117th Congress, with no public hearing and no sworn testimony; an arbitrator refused it as "rank hearsay" that relied on companies then in arbitration with Womply, and a federal judge declined to take judicial notice of its findings (about the report).