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How Much Did JPMorgan Chase Make From Pandemic Relief?

JPMorgan Chase lent more PPP money than any other lender, $41.6 billion in 438,565 loans of its own, and the SBA's schedule set a processing fee for every one. Priced loan by loan from the agency's own data, those fees come to about $1.70 billion, the most of any lender in the program. More than a sixth of it, $299 million, came from 25,993 loans approved in the program's first two weeks, when the bank's average loan was more than twice the program's. In May 2020 the bank said it did "not intend to earn a profit from PPP." Its filings never reported the fees, the costs or the profit.

I. One modeled answer and three blanks

"Made" can mean four things here. Public records support an estimate of one of them.

QuestionTermFigure
What did the SBA's fee schedule owe JPMorgan for processing its PPP loans?Fees (modeled, accrued)$1.70 billion; $1.66 billion to $1.70 billion under the alternative assumptions in Section IV
What did JPMorgan report receiving?Fees (reported)Not disclosed. Its filings say only that the fees were "deferred and accreted into interest income"
What was left after costs?ProfitNot disclosed. Its chief financial officer said in July 2020 that it would be "near zero"
How much did it pay out to loan agents or give away?Paid outIts annual and quarterly reports, proxy statements and earnings releases filed from 2020 through early 2022 show neither an agent payment nor a fee donation. A federal judge ruled in 2020 that it owed agents nothing without an agreement

The first figure is our estimate. The SBA never published what it paid each lender, so each JPMorgan loan in the SBA's loan-level file is priced under the fee rule in force when it was made. The method is the one used in How Much Did Womply Make From Pandemic Relief? and on the PPP lenders ranked by estimated fees. JPMorgan's public filings do not break out the other three.

II. Who paid JPMorgan, and for what

The money came from the SBA. The loans carried a 100 percent federal guarantee. The SBA paid the lender a processing fee set by the first PPP rule, published in April 2020 (85 FR 20811):

  • "Five (5) percent for loans of not more than $350,000";
  • "Three (3) percent for loans of more than $350,000 and less than $2,000,000"; and
  • "One (1) percent for loans of at least $2,000,000."

Say a lender processed a $20,000 loan in April 2020. The SBA owed it 5 percent, $1,000. On a $10 million loan, the program's maximum, it owed 1 percent: $100,000, a hundred times the first fee. The rule paid by the dollar lent.

The same rule settled two other points. Anyone who helped a borrower apply was the lender's problem: "Agent fees will be paid by the lender out of the fees the lender receives from SBA. Agents may not collect fees from the borrower or be paid out of the PPP loan proceeds." And it answered one question in a single word. "Is the PPP 'first-come, first-served?'" "Yes."

The SBA's Inspector General, in a flash report on May 8, 2020, listed why banks would sign up. The PPP interest rate beat comparable yields, and "the fact that the loans are 100 percent guaranteed by the SBA and the fact that lenders will receive a substantial processing fee from the SBA provide ample inducement for lenders to participate in the PPP" (SBA OIG Report 20-14).

The 2021 rules changed the arithmetic for small loans. For loans made on or after December 27, 2020, the fee on a loan of $50,000 or less became "the lesser of fifty (50) percent or $2,500" (86 FR 3692). Second-draw loans got the same small-loan rule, 5 percent up to $350,000 and 3 percent above it, with no 1 percent tier (86 FR 3712). On a $5,000 loan in 2021, the fee was $2,500.

III. JPMorgan's book, by round and by size

In the SBA's loan-level data (the September 30, 2024 release), JPMorgan Chase Bank, N.A. is the originating lender on 452,892 loans for $44.1 billion (lender page). Of those, 14,327 loans for $2.56 billion carry one San Francisco lender location. Their borrowers are mostly in California (10,474), then New York, Massachusetts, Oregon and Florida, the markets of First Republic Bank, which failed in May 2023 and was taken over by JPMorgan. JPMorgan's own lender locations are in Chicago and Columbus. From that we infer the San Francisco loans are First Republic's book under its buyer's name, and we count them, with their $90.4 million in modeled fees, to First Republic, the bank that made them. That leaves JPMorgan 438,565 loans for $41.6 billion: first among the program's lenders by dollars and fourth by loan count, with 3.8 percent of the program's loans. Priced under the schedules above:

RoundLoansDollars approvedModeled fees
2020 (first draw)280,145$29.34B$1,033.2M
2021 first draw35,904$1.35B$104.7M
2021 second draw122,516$10.86B$562.3M
Total438,565$41.55B$1,700.2M

That is $3,877 a loan, and 4.4 percent of the $38.2 billion the same model gives for every lender in the program.

Loan sizeLoansShare of loansDollarsModeled feesShare of fees
$50,000 or less290,91666.3%$5.69B$440.9M25.9%
Over $50,000 to $150,00094,73321.6%$8.24B$412.0M24.2%
Over $150,000 to $350,00031,8347.3%$7.16B$358.1M21.1%
Over $350,000, under $2 million19,1384.4%$13.66B$409.7M24.1%
$2 million and over1,9440.4%$6.81B$79.5M4.7%

Two-thirds of the loans were for $50,000 or less, and they carried a quarter of the fees. The 21,082 loans over $350,000, about one in twenty, carried $489.2 million, 28.8 percent.

The first two weeks

The SBA opened the program on April 3, 2020. "[B]y April 16, just 14 days after SBA launched the program," the Inspector General reported, "PPP lenders approved more than 1,661,000 loans totaling nearly $342.3 billion" (OIG 20-14). New money arrived on April 27. The 2024 file shows 25,993 JPMorgan loans approved in those 14 days, for $12.0 billion: 1.6 percent of the loans approved in the window and 3.8 percent of the dollars.

JPMorgan's first-round loans averaged $462,200. The average for every lender in the window was $197,400. Under the schedule, those 25,993 loans owed the bank $298.6 million, or $11,487 a loan. The next 254,152 loans, approved from April 27 through the August 2020 close, averaged $68,200 and owed $2,891 a loan.

JPMorgan's first-round average was the highest of the large banks'.

LenderLoans approved April 3–16, 2020Average loan
JPMorgan Chase Bank25,993$462,200
PNC Bank20,562$430,000
Bank of America9,056$400,700
Truist Bank30,653$289,200
TD Bank25,904$222,200
U.S. Bank17,371$131,500
Wells Fargo Bank1,004$99,800
Cross River Bank13,615$77,900
All lenders1,618,962$197,400

The 2021 small-loan rule

The $2,500 rule changed the small end. JPMorgan's 2021 loans of $50,000 or less, 107,335 of them for $2.1 billion, owed it $259.3 million: 12.6 percent of the money lent and $2,415 a loan. Its 183,581 loans in the same band in 2020 had owed 5 percent, $181.6 million, or $989 a loan. The bank made 42 percent fewer small loans in 2021 and was owed 43 percent more for them.

IV. The model: $1.70 billion, and how far it moves

The model takes every loan in the SBA file with JPMorgan as originating lender, except the San Francisco location, and drops loans never disbursed; JPMorgan has none. It prices each loan's current approved amount under the rule that applied: 85 FR 20811 for 2020 loans, 86 FR 3692 for 2021 first-draw loans and 86 FR 3712 for second-draw loans. The result is $1,700,183,418. The bank's lender page follows the names in the SBA file and shows $1,790,545,416, First Republic's $90.4 million included. The schedules are laid out in PPP fee schedules by vintage.

One bank published a number the model can be checked against. Wells Fargo committed to donate the gross processing fees on its 2020 PPP loans, "a ~$420 million commitment." The model gives $420.7 million for Wells Fargo's 2020 loans (Wells Fargo 4Q21 financial results presentation, Form 8-K Exhibit 99.3, January 14, 2022).

Assumption changedModeled feesChange
None (the model)$1,700.2M
Price each loan on its initial approved amount$1,704.3M+$4.1M
Price each loan on the amount disbursed$1,700.2M0
Pay 1 percent, not 3 percent, on the 285 second-draw loans of $2 million$1,688.8M−$11.4M
Drop the fee on every loan later charged off (10,088 loans, $1.01B)$1,658.1M−$42.1M

The last row is a stress test. A rule published June 1, 2020 told lenders they would not receive the processing fee if the SBA determined a borrower was ineligible (GAO-20-625); the loan file does not say on which loans, if any, that happened. The range is $1.66 billion to $1.70 billion, accrued rather than received.

The fees reached JPMorgan's income statement slowly. "PPP processing fees are deferred and accreted into interest income over the contractual life of the loans," the bank wrote in its second-quarter 2020 Form 10-Q (pp. 60–61). By year-end it added that recognition "may be accelerated upon forgiveness or prepayment" (Form 10-K for 2020, p. 113). Forgiveness came fast. By December 31, 2021, "approximately $34 billion of PPP loans have been repaid through payments of forgiveness amounts to the Firm from the SBA," and $6.7 billion of PPP loans remained on the books (Form 10-K for 2021, p. 109).

V. The line and the lawsuits

The fee schedule paid more for bigger loans; the same rule said first come, first served.

On April 22, 2020, the New York Times reported that "nearly all of the 8,500 commercial and private banking clients who applied for a loan got one" at JPMorgan. By contrast, "only 18,000 of more than 300,000 small-business banking customers who applied through Chase's retail bank, where they normally did business, got loans, according to the bank" (Flitter and Cowley, "Banks Gave Richest Clients 'Concierge Treatment' for Pandemic Aid"). A JPMorgan spokeswoman told the paper: "We worked as quickly as possible in a race against time, volume and manual processes."

Borrowers sued. The Judicial Panel on Multidistrict Litigation listed seven federal cases alleging that JPMorgan "failed to implement and follow federal regulations requiring that PPP loan applications be processed on a 'first-come, first-served' basis" (order denying transfer, MDL No. 2944). One complaint gave a motive. Sha-Poppin Gourmet Popcorn, a five-employee company in Westchester, Illinois, alleged that JPMorgan acted "out of a combination of elite favoritism and, to be sure, at least some additional profit." It priced one example: two $10 million loans to Ruth's Chris entities "would have earned Chase $200,000 in origination fees" (class action complaint, paras. 10 and 41). These are allegations.

On August 5, 2020 the panel refused to combine the cases, finding that "individualized factual issues concerning the circumstances of each loan application will significantly diminish the potential efficiencies from centralization." Here is how the seven ended:

CaseCourt and numberOutcome
Hyde-Edwards Salon & Spa v. JPMorgan Chase & Co.S.D. Cal. 3:20-cv-00762Sent to arbitration and stayed, Nov. 23, 2020 (order)
Sha-Poppin Gourmet Popcorn v. JPMorgan Chase Bank (with Ajira AI, No. 20-cv-4428)N.D. Ill. 1:20-cv-02523Sent to arbitration under the deposit account agreement, Aug. 10, 2021 (opinion); a JAMS appellate panel ruled the claims arbitrable on Aug. 3, 2023, and the plaintiff said it "plans to proceed in arbitration" (joint status report)
Legendary Transport v. JPMorgan Chase & Co.C.D. Cal. 2:20-cv-03636Voluntarily dismissed with prejudice, Oct. 29, 2020 (Dkt. 49)
Ladaga Ventures v. JPMorgan Chase BankD. Colo. 1:20-cv-01204Voluntarily dismissed with prejudice, Oct. 15, 2020 (Dkt. 32, docket text)
Shiny Strands v. JPMorgan Chase & Co.N.D. Ill. 1:20-cv-02547Voluntarily dismissed with prejudice before JPMorgan had answered, Oct. 14, 2020 (Dkt. 27)
Outlet Tile Center v. JPMorgan Chase & Co.C.D. Cal. 2:20-cv-03603Voluntarily dismissed, Aug. 17, 2020 (Dkt. 18, docket text); the panel had noted settlement talks
Starwalk of Dallas v. JP Morgan Chase & Co.N.D. Tex. 3:20-cv-01005Dismissed with prejudice on the parties' stipulation, Feb. 1, 2021 (Dkt. 21)

No court decided whether JPMorgan followed the first-come, first-served rule, and we have no record of how the arbitrations came out. The courts' route is described in The Banks Served Their Own Customers First, and Courts Shrugged.

The agents

The other claim on JPMorgan's fees came from accountants and accounting firms that had helped borrowers apply. The rule capped what a lender could pay them at 1 percent on loans up to $350,000, 0.50 percent on loans from there to just under $2 million, and 0.25 percent on loans of $2 million or more. Applied to every JPMorgan loan from 2020, those caps come to $200 million, the ceiling on agent fees had every 2020 borrower used an agent.

They sued JPMorgan and three other banks in New York. Judge Jed Rakoff ruled on September 21, 2020: "The Court holds that, absent an agreement between agent and lender, defendant banks are not required to pay agent fees under the text of the CARES Act or its implementing regulations" (Johnson v. JPMorgan Chase Bank, N.A., S.D.N.Y. No. 1:20-cv-04100, Dkt. 69, p. 3). Judgment for JPMorgan followed the next day. In Los Angeles, JPMorgan was among seven lender defendants in American Video Duplicating v. Citigroup. Judge Otis Wright wrote: "It appears every court that has decided this issue has held that the CARES Act does not require lenders to pay agent fees absent an agreement to do so, nor does it create a corresponding private right of action" (order, Nov. 16, 2020); the case ended in a stipulated dismissal. When the agent suits reached the multidistrict panel, "Chase oppose[d] industry-wide centralization, but support[ed] a Chase-specific MDL" (MDL No. 2950 order). The Agents Got Nothing follows the rest of the agent suits.

VI. What the investigators found

In October 2020 the House Select Subcommittee on the Coronavirus Crisis published a staff report, Underserved and Unprotected, built on documents and loan data the banks gave it. At JPMorgan, Wholesale Banking clients, companies with more than $20 million in revenue and high-net-worth individuals, had relationship managers "to personally assist clients in completing their PPP applications," while Business Banking customers used the online application (p. 13). From application to funding:

JPMorgan PPP loans, data through July 31, 2020Average days to funding
Wholesale Banking clients3.1
Business Banking clients14.9
Loans over $5 million3.7
Loans over $1 million to $5 million8.2
Loans over $100,000 to $1 million14.9
Loans of $100,000 and under14.5
Applicants with more than 100 employees8.7
Applicants with 5 or fewer employees14.3

Source: Select Subcommittee staff report, pp. 14–15, from data JPMorgan's counsel sent the Subcommittee on September 16, 2020.

JPMorgan told the staff that "[f]rom early on there was an understanding from Treasury that banks were working with existing clients" (p. 5). It also said it "did not receive guidance from Treasury or the SBA on prioritizing loan applications benefiting underserved and rural markets" (p. 9). The Inspector General had found the same gap in May: "We did not find any evidence that SBA issued guidance to lenders to prioritize the markets indicated by the Act" (OIG 20-14). Some lenders, JPMorgan among them, told the Subcommittee they funded larger customers faster "due to the customer's greater business acumen"; the staff wrote that its investigation "casts doubt on that explanation," pointing to U.S. Bank, which took 15.6 days for applicants with more than 100 employees and 15.7 days for single-employee applicants (p. 15). The Subcommittee's findings carry no penalty.

Two years later the Subcommittee used JPMorgan as the yardstick for the fintechs. Its December 2022 report, "We Are Not the Fraud Police," said Blueacorn's partner lenders "together facilitated almost three times as many PPP loans in 2021 than JPMorgan Chase and Bank of America combined" (p. 20). It ranked Prestamos third by 2021 dollars, "after JP Morgan Chase Bank and Bank of America" (p. 44) (House report).

VII. What JPMorgan said

On May 1, 2020, JPMorgan announced that it expected to fund about $29 billion to more than 239,000 businesses. The press release closed: "Finally, the firm does not intend to earn a profit from PPP and remains fully committed to supporting programs that help small businesses" (press release).

On July 14, 2020, an analyst asked the chief financial officer, Jennifer Piepszak, about PPP fees. Her answer: "So we've been really clear on PPP, which is that we don't intend to profit from PPP. That doesn't mean that you won't have some geography issues. So you'll have some revenue and then you'll have expenses, and the profit will be near zero." And: "Again, it will still be zero on the bottom line, and even the gross numbers won't be meaningful in the grand scheme of things" (2Q20 earnings call transcript, p. 17).

The claim about gross numbers holds up on the bank's own scale. JPMorgan reported net income of $29.1 billion for 2020 and $48.3 billion for 2021 (fourth-quarter earnings releases, January 15, 2021 and January 14, 2022). The modeled fees for both years, $1.70 billion, equal 2.2 percent of that $77.4 billion. The filings called PPP's effect on interest income "not material" for 2020 (Form 10-K for 2020, p. 113), while the fees were still being spread over the loans' lives. By the fourth quarter of 2021 the release listed "the accelerated recognition of deferred processing fees due to loan forgiveness" among the reasons Consumer & Business Banking revenue rose 7 percent.

The claim about profit cannot be checked. JPMorgan's 10-Ks for 2020 and 2021, its quarterly reports and its earnings releases from mid-2020 through 2021 do not report the fees, the cost of processing the loans or the profit. Jamie Dimon's letter to shareholders for 2020 describes "more than 1,000 people who manually reviewed applications" and "over 280,000 PPP loans for more than $32 billion — the most of any lender." It does not mention the fees (letter; see Jamie Dimon). The same letter lists commitments of $250 million "in global business and philanthropic initiatives" and $350 million "to support underserved small businesses"; the letter does not tie either to PPP fees.

Wells Fargo made the other kind of promise. It "voluntarily committed to donate the gross processing fees received from Paycheck Protection Program (PPP) loans funded in 2020," and by January 2022 reported: "Fulfilled our ~$420 million commitment" (Wells Fargo 4Q21 presentation). JPMorgan disclaimed the profit. Wells Fargo gave away its 2020 fees.

VIII. Where $1.70 billion ranks

The table ranks the largest fee collectors of the pandemic loan programs, counting every dollar once. A lender's figure is its modeled fees owed, less any share it passed to an agent where records give it, or the fee figure it published itself; an agent's is its receipts as documented or reported. Womply, covered in its own piece, is ranked on what it billed.

RankCollectorHow it was paidEstimate ($M)Basis
1WomplyFees billed to lenders1,847–2,641 billedCourt records and modeled lender fees
2JPMorgan ChasePPP lender fee1,700.2Model
3Bank of AmericaPPP lender fee1,491.1Model
4BlueacornAgent fees from lenders1,080–1,086Reported: Blueacorn's figures, quoted in a House report
5Cross River BankPPP lender fee1,034.6Model
6Wells FargoPPP lender feeabout 690Company filings: about $420M for 2020 and about $270M for 2021; the 2020 fees donated
7PNC BankPPP lender fee606.8Model
8Truist BankPPP lender fee588.5Model
9U.S. BankPPP lender fee506.9Model
10TD BankPPP lender fee497.9Model
11Itria VenturesPPP lender fee473.4Model

Model figures are SBA processing fees owed, before any costs. Blueacorn's $1.08 billion sits in its own row and is subtracted from the partner lenders that paid it. Womply's figure is what it billed for 2021, not what it collected. Loans the SBA file lists under a buyer's name are counted to the bank that made them, so JPMorgan's figure leaves out First Republic's $90.4 million. Customers Bank, ranked on its own published figure of "close to $350 million," is 17th; Capital Plus, ranked on its parent's audited accounts ($305.7 million), is 23rd.

JPMorgan earned its place with volume and size: 438,565 loans averaging $94,700. Cross River, fifth, made 478,866 loans averaging $26,900 and was owed $1.03 billion. Bank of America made more loans than JPMorgan, 491,034, for $7.1 billion less money and $209 million less in modeled fees.

Two of the first four names made no loans. Womply's billings are worked through in its own piece. Blueacorn, by the House report's account, "received over $1.08 billion from its lending partners as fees for its PPP services in 2021" (p. 23). JPMorgan's whole 2021 book, 158,420 loans for $12.2 billion, carried $667.0 million in modeled fees.

Methodology and what would change the numbers

Data and pricing

Loan data: the SBA's PPP loan-level FOIA release of September 30, 2024 (13 files), originating-lender field "JPMorgan Chase Bank, National Association," less originating-lender location 474333 (San Francisco: 14,327 loans, $2.56 billion, $90.4 million in modeled fees), counted to First Republic Bank. Rows whose undisbursed amount equals or exceeds the current approved amount are dropped; no JPMorgan row is. Round: second-draw loans are those processed as "PPS"; other loans approved on or after January 1, 2021 are 2021 first-draw loans; the rest are 2020 loans. Fee basis: current approved amount. Schedules: 85 FR 20811 (2020: 5 / 3 / 1 percent), 86 FR 3692 (2021 first draw: lesser of 50 percent or $2,500 up to $50,000, then 5 / 3 / 1 percent), 86 FR 3712 (second draw: lesser of 50 percent or $2,500 up to $50,000, then 5 / 3 percent). The first-round window is loans with an approval date from April 3 through April 16, 2020. Program-wide totals (11,468,206 loans and $38.2 billion in modeled fees) come from the same run over all lenders.

Exact figures (documents)

The press release, earnings-call and filing quotations; JPMorgan's reported net income; Wells Fargo's $420 million commitment and its fulfillment; the Subcommittee's processing-time tables; the Inspector General's first-round totals; the case numbers, dates and outcomes in Section V; the Blueacorn fee total.

Modeled figures

Every fee figure for JPMorgan and the other banks; the size-band and first-round splits; the $200 million agent-fee ceiling; the sensitivity rows. Each is an accrual under the published schedules.

Documents that would collapse the range to a point

The SBA's record of processing fees paid to JPMorgan, loan by loan, including any fee withheld or recovered; JPMorgan's internal accounting of PPP revenue and expense, which its chief financial officer described in July 2020 without figures; and the arbitration files in Hyde-Edwards and Sha-Poppin.

Sources: SBA PPP loan-level FOIA data (release of Sept. 30, 2024), priced under 85 FR 20811, 86 FR 3692 and 86 FR 3712; JPMorgan Chase lender page; PPP per-lender totals; SBA OIG, Report 20-14 (May 8, 2020); GAO, GAO-20-625 (June 2020); Select Subcommittee on the Coronavirus Crisis, Underserved and Unprotected: How the Trump Administration Neglected the Neediest Small Businesses in the PPP (staff report, October 2020) and "We Are Not the Fraud Police" (Dec. 1, 2022); JPMorgan Chase, press release of May 1, 2020, 2Q20 earnings call transcript (July 14, 2020), Form 10-Q for the quarter ended June 30, 2020, Forms 10-K for 2020 and 2021, fourth-quarter 2020 and 2021 earnings releases (Form 8-K, Exhibit 99.1), and Jamie Dimon's letter to shareholders for 2020; Wells Fargo & Company, 4Q21 financial results presentation (Form 8-K, Exhibit 99.3, Jan. 14, 2022); Emily Flitter and Stacy Cowley, "Banks Gave Richest Clients 'Concierge Treatment' for Pandemic Aid", New York Times (Apr. 22, 2020); FDIC BankFind, institution history for First Republic Bank (FDIC cert. 59017); In re JPMorgan Chase Paycheck Protection Program Litigation, MDL No. 2944, order denying transfer (Aug. 5, 2020); Hyde-Edwards Salon & Spa v. JPMorgan Chase & Co., S.D. Cal. 3:20-cv-00762 (order compelling arbitration); Sha-Poppin Gourmet Popcorn LLC v. JPMorgan Chase Bank, N.A., N.D. Ill. 1:20-cv-02523 (complaint, memorandum opinion and order, joint status report); Legendary Transport, LLC v. JPMorgan Chase & Co., C.D. Cal. 2:20-cv-03636, Dkt. 49; Ladaga Ventures LLC v. JPMorgan Chase Bank, N.A., D. Colo. 1:20-cv-01204, Dkt. 32; Shiny Strands, Inc. v. JPMorgan Chase Bank, N.A., N.D. Ill. 1:20-cv-02547, Dkt. 27; Outlet Tile Center v. JPMorgan Chase and Co., C.D. Cal. 2:20-cv-03603, Dkt. 18; Starwalk of Dallas LLC v. JP Morgan Chase & Co., N.D. Tex. 3:20-cv-01005, Dkt. 21; Johnson v. JPMorgan Chase Bank, N.A., S.D.N.Y. 1:20-cv-04100, Opinion and Order (Dkt. 69, Sept. 21, 2020) and Judgment (Dkt. 70, Sept. 22, 2020); American Video Duplicating, Inc. v. Citigroup Inc., C.D. Cal. 2:20-cv-03815 (order granting motions to dismiss, stipulation of dismissal); In re PPP Agent Fees Litigation, MDL No. 2950, order denying transfer (Aug. 5, 2020). 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).

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