Court filing

Appendix Volume 1 — Marshall v. Prestamos CDFI, LLC (Dkt. 157-3, E.D. Pa. No. 5:21-cv-04337)

Filed May 7, 2025 in Marshall v. Prestamos CDFI, LLC; one of 344 filings from this case.

Record facts

Court	U.S. District Court for the Eastern District of Pennsylvania
Filed	2025-05-07

U.S. District Court for the Eastern District of Pennsylvania · No. 5:21-cv-04337-JMG · Doc. 157-3 · 2025-05-07 · Docket on CourtListener

Full text

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Page 1 of 186

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ALICIA MARSHALL, et al.,

Civil Action No. 5:21-cv-04337-JMG

Plaintiffs,
v.
PRESTAMOS CDFI, LLC,
Defendant.
DEFENDANT PRESTAMOS CDFI, LLC’S
APPENDIX IN SUPPORT OF MOTION FOR
SUMMARY-8'*0(17 92/80(2)
Exhibit Document
Bates Numbers
1

Greg Lloyd Signed Form 2483

Def_Appx_0001-0006

J. Martinez Declaration

Def_Appx_0007-0010

W. Briggs Deposition Transcript Excerpts

Def_Appx_0011-0017

W. Manger Deposition Transcript Excerpts

Def_Appx_0018-0026

D. Castillo Declaration

Def_Appx_0027-0040

Disbursement and Return Compilation

Def_Appx_0041

SBA and Secret Service PPP Application Fraud
Indicators
SBA DirectLYH to Recover on Fraud Loans

Def_Appx_0042-0043

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9

Compilation of Examples RDFI Seeking Return of
Suspect Funds

Def_Appx_0044-0084
Def_Appx_0085-0176

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Exhibit 1
Greg Lloyd Signed Form 2483

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Def_Appx_0001

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Exhibit 2
J. Martinez Declaration

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EXCERPTS OF NACHA RULES
Article One General Rules
Section 1.2 Participating DFIs Must Comply with Rules
A Participating DFI must comply with these Rules and warrants that it is legally able to comply
with all applicable requirements of these Rules. Only Participating DFIs may be ODFIs and
RDFIs. A Participating DFI is responsible for its Third-Party Service Providers’ compliance with
these Rules.
Subsection 1.2.1 Effect of Illegality
Nothing in these Rules requires a Participating DFI to debit or credit an account or to transfer funds
or take other action required by the Rules if the Participating DFI reasonably believes that taking
such action in connection with a specific Entry would violate applicable U.S. Legal Requirements,
including the obligations of the Participating DFI under programs administered by the U.S.
Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Financial Crimes
Enforcement Network (FinCEN). A Participating DFI must comply with all other requirements of
these Rules with respect to all other Entries or other aspects of the same Entry, including the timely
transmission of Return Entries and the availability of funds from Entries.
Article Three Rights and Responsibilities of RDFIs and Their Receivers
Section 3.8 RDFI’s Right to Transmit Return Entries
An RDFI may return an Entry for any reason, except as otherwise provided for in Subsection 3.8.1
(Restrictions on RDFI’s Right to Transmit Return Entries). An RDFI must comply with the
requirements of Appendix Four (Return Entries) for each Return Entry it initiates.
An RDFI must Transmit a Return Entry to its ACH Operator by the ACH Operator’s deposit
deadline for the Return Entry to be made available to the ODFI no later than the opening of
business on the second Banking Day following the Settlement Date of the original Entry, except
as otherwise provided in Subsection 3.8.3 (Exceptions to Timing Requirements for Return Entries)
and Section 3.13 (RDFI Right to Transmit Extended Return Entries). A Return Entry that is
rejected by an ACH Operator does not satisfy or extend the timing requirements contained in this
Section 3.8.
Subsection 3.8.1 Restrictions on RDFI’s Right to Transmit Return Entries
Subsection 3.8.1.1 RDFI May Not Return an Entry Due to the Type of Entry
An RDFI may not return an Entry because it is a particular type of Entry, unless expressly
provided for in Subsection 3.8.2 (Exceptions to Restrictions on RDFI’s Right to Transmit
Return Entries).
Subsection 3.8.1.2 RDFI May Not Return an Entry Based on MICR Data
An RDFI may not return an Entry to a Transaction Account based exclusively on data that
were accurately obtained from the on-us field of the MICR line of a Check for the account,
unless the RDFI had previously initiated a Notification of Change that was not properly
acted upon.

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Article Eight Definitions of Terms Used in These Rules
Section 8.37 “Entry”
(a) an order or request for the transfer of money to the deposit account or loan account of a
Receiver, or general ledger account of an RDFI (a “credit Entry”);
(b) an order or request for the withdrawal of money from the deposit account of a Receiver, or
general ledger account of an RDFI (a “debit Entry”); and
(c) a Non-Monetary Entry to the deposit account or loan account of a Receiver, or general ledger
account of an RDFI.
An Entry must comply with the requirements of Appendix Three (ACH Record Format
Specifications), Appendix Four (Return Entries), Appendix Five (Notification of Change), or
Appendix Six (Acknowledgment Entries), as applicable. For all Entries except RCK Entries, each
debit Entry shall be deemed an “item” within the meaning of Revised Article 4 of the Uniform
Commercial Code (1990 Official Text) and that Article shall apply to such Entries except where
the application is inconsistent with these Rules, in which case these Rules shall control. An RCK
Entry is an item as that term is defined by Revised Article 4 of the Uniform Commercial Code
only for the limited purposes of presentment as set forth in Article 4-110(c) and notice of dishonor
as set forth in Article 4-301(a)(2).
Section 8.72 “Originator”
a Person that (i) has been authorized by a Receiver to initiate a credit Entry, debit Entry, or NonMonetary Entry to the Receiver’s account at the RDFI (except where authorization is not required
by these Rules); and (ii) has authorized an ODFI (directly or through a Third-Party Sender) to
Transmit, for the account of that Person, a credit Entry, debit Entry, or Non-Monetary Entry to the
Receiver’s account at the RDFI.
Section 8.70 “Originating Depository Financial Institution” or “ODFI”
a Participating Depository Financial Institution with respect to Entries (a) it Transmits directly or
indirectly to an ACH Operator for Transmittal to an RDFI, and (b) on which it is designated as the
ODFI in accordance with Appendix Three (ACH Record Format Specifications). An RDFI is not
considered an ODFI solely by reason of its initiation of Acknowledgment Entries, Return Entries,
Extended Return Entries, or Notifications of Change.
Section 8.76 “Participating Depository Financial Institution” or “Participating DFI”
a financial institution that (a) is authorized by applicable Legal Requirements to accept deposits,
(b) has been assigned a routing number by LexisNexis, and (c) has agreed to be bound by these
Rules.
Section 8.85 “Receiver”
a Person that has authorized an Originator to initiate a credit Entry, debit Entry, or Non-Monetary
Entry to the Receiver’s account at the RDFI. With respect to debit Entries, the term “Receiver”
means all Persons whose signatures are required to withdraw funds from an account for purposes
of the warranty provisions of Subsection 2.4.1 (General ODFI Warranties).

2
Def_Appx_0009

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Section 8.87 “Receiving Depository Financial Institution” or “RDFI”
a Participating Depository Financial Institution with respect to Entries (a) it receives from its ACH
Operator to the accounts of Receivers, and (b) on which it is designated as the RDFI in accordance
with Appendix Three (ACH Record Format Specifications). An ODFI is not considered an RDFI
solely by reason of its receipt of Acknowledgment Entries, Return Entries, Extended Return
Entries, or Notifications of Change.
Section 8.97 “Return Entry” or “Return”
a credit or debit Entry initiated by an RDFI or ACH Operator, that returns a previously originated
credit or debit Entry to the ODFI within the time frames established by these Rules. A Return
Entry must comply with the requirements of Appendix Four (Return Entries). For all Entries except
IAT Entries, an ODFI may dishonor a Return Entry. A dishonored Return Entry must comply with
Subsection 2.13.6 (Dishonor of Return Entries) and Appendix Four (Return Entries). For all
Entries except IAT Entries, an RDFI may create a corrected or contested dishonored Return Entry
in compliance with Subsection 3.8.5 (Receipt of Dishonored Returns) and Appendix Four (Return
Entries).
Section 8.103 “Rules” or “Nacha Operating Rules” or “Nacha Rules” or “ACH Rules”
the Operating Rules of the National Automated Clearing House Association, including all
appendices, formal rules interpretations, and schedule of fees, as in effect from time to time.
Appendix Four Return Entries
An RDFI may return Entries for any reason, except as otherwise provided in Article Three,
Subsection 3.8.1 (Restrictions on RDFI’s Right to Transmit Return Entries) of these Rules. The
RDFI must use an appropriate Return Reason Code as specified in this Appendix Four. If it uses
Return Reason Code R17 [Entry initiated under questionable circumstances], it must specify the
reason for the Return. If no appropriate Return Reason Code is defined within this Appendix Four,
the RDFI must use the code that most closely approximates the reason for Return.

3
Def_Appx_0010

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Exhibit 3
W. Briggs Deposition Transcript Excerpts

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Deposition of William Briggs

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Alicia Marshall, et al. v. Prestamos CDFI, LLC

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

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ALICIA MARSHALL, et. al.,
)
individually and on behalf of )
all others similarly situated, )
)
Plaintiffs,
)
vs.
)Case No.
)5:21-cv-04337-JMG
PRESTAMOS CDFI, LLC., )
)
Defendant.
)

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REMOTE DEPOSITION OF WILLIAM BRIGGS

Thursday, August 22, 2024

Austin, Texas

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Reported By:

JOB NO. 31471

TRICIA J. LATHOURIS, CSR, RPR

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215-341-3616
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Def_Appx_0011
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Thursday, August 22, 2024

9:02 a.m.

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REMOTE DEPOSITION OF WILLIAM BRIGGS, held

(virtually) via Zoom videoconference before Tricia

J. Lathouris, CSR, RPR.

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Deposition of William Briggs

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A P P E A R A N C E S:

(All counsel appearing remotely.)

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BAILEY GLASSER

BY:

LARRY LEDERER, ESQ.

1055 Thomas Jefferson Street, NW

Suite 540

Washington, DC 20007

- and -

NOLAN, HELLER & KAUFFMAN

BY:

GREGORY ZINI, ESQ.

80 State Street

11th Floor

Albany, New York 12207

ATTORNEYS FOR THE PLAINTIFFS;

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BALLARD SPAHR

BY:

ED ROGERS, ESQ.

CHESLEY BURRUSS, ESQ.

1735 Market Street

51st Floor

Philadelphia, Pennsylvania 19103

ATTORNEYS FOR THE DEFENDANT.
215-341-3616
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Def_Appx_0013
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Deposition of William Briggs

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I N D E X

WITNESSES

All Witnesses:

WILLIAM BRIGGS for Defendant
Examination by Mr. Rogers

Page
5

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EXHIBITS

NO.

Exhibit 1

DESCRIPTION

PAGE

Report of William Briggs,
dated 7/12/2024

Report of William Briggs -Rebuttal to Report of
Kenneth A. Swain, dated
8/9/2024

Supplement to Briggs's
Opening and Rebuttal
Reports Identifying Certain
Sources in Forming Opinions
Express, dated 8/13/2024

Exhibit 2
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12

Exhibit 3

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Exhibit 3A Greathouse versus Capital
Plus case

Exhibit 3B Memorandum Opinion dated
3/30/2023

Exhibit 4

Third Amended Class Action
Complaint

Exhibit 5

Declaration of David Castillo

Exhibit 6

Report by Select Subcommittee
on Coronavirus Crisis entitled
"We Are Not the Fraud Police.
How Fintechs facilitated fraud
in the Paycheck Protection
Program."

129

YouTube video

134

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Exhibit 7

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Deposition of William Briggs

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regulatory paperwork or other conditions?

Correct.

But you agree that an applicant needed to

provide certain documents in order to get a PPP

loan?

Correct.

And included in that group of documents

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were documentation of payroll records?
MR. LEDERER:

I'm sorry.

question, please?
MR. ROGERS:

Could you repeat the

Sorry.
I'm going to rephrase it.

BY MR. ROGERS:
Q

Among the documents required to be provided

were payroll records; correct?
A

There were multiple types of documents that

could be provided.

Tell me what those were.

Some examples include payroll records, tax

forms and/or bank records.

Okay.

I believe that some form of documentation

Were any of those required?

was required sufficient that the bank could make a

loan calculation determination.

When you say -- what do you mean by "loan
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Deposition of William Briggs

More or less than ten?

I can't recall.

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I would say ten would be a

good number.
Q

Were these typically in person?

I guess

not during COVID.
A

No.

Given the social distancing

environment, everything was not in person.
Q

Am I correct, as a general matter, that

there was a standard form note used by lenders in

connection with the PPP?

There was a standard form note.

The

regulations allowed lenders to either use that one

or their own note as well.

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Okay.

Do you know whether in this case

Prestamos used the standard form note?
A

It looks to me, based on what I saw in the

Third Amended Complaint, that Prestamos used the

standard form note.

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Let's look at the Third Amended Complaint.

I don't recall if we have marked it yet.
MR. LEDERER:

You didn't.

At least in this

deposition.
MR. ROGERS:

I did not.

Chesley is shaking his

head.
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according to your records, the intended recipient of

the loan doesn't have an account with you.

Correct?

Correct.

Okay.

And that at least in some instances

-- and we don't have to quantify, and we don't have

to get into the reasons why -- at least in some

instances that occurred in the PPP; correct?

Yes.

Okay.

And that in the situation I'm

describing, the hypothetical situation that I'm

describing, that money comes back to me and I

cannot -- I cannot pick up the phone or send an

email or get together with you in person and say,

"Mr. Briggs, this is an SBA-approved loan.

person submitted the application.

was processed by our LSP, and the Federal Reserve

Board gave me the money.

Take the money."

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This

The application

What's the problem here?

In that example, you would agree that I
can't force you to take the money; correct?
A

You, as Prestamos, in this hypothetical

example, cannot force a bank to take money.
Q

I want to go, now, to 46 of Castillo.
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Exhibit 4
W. Manger Deposition Transcript
Excerpts

Case 5:21-cv-04337-JMG
Deposition of William M. Manger, Jr.

Document 157-3

Filed 05/07/25

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Alicia Marshall, et al. v. Prestamos CDFI, LLC

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

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ALICIA MARSHALL, et. al.,
)
individually and on behalf of )
all others similarly situated, )
)
Plaintiffs,
)
vs.
)Case No.
)5:21-cv-04337-JMG
PRESTAMOS CDFI, LLC., )
)
Defendant.
)

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REMOTE DEPOSITION OF WILLIAM M. MANGER, JR.

Monday, August 26, 2024

South Hampton, New York

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Reported By:

JOB NO. 31472

TRICIA J. LATHOURIS, CSR, RPR

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215-341-3616
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Def_Appx_0018
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Filed 05/07/25

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Monday, August 26, 2024
9:03 a.m.

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REMOTE DEPOSITION OF WILLIAM M. MANGER, JR., held

(virtually) via Zoom videoconference before Tricia

J. Lathouris, CSR, RPR.

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Deposition of William M. Manger, Jr.

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A P P E A R A N C E S:

(All counsel appearing remotely.)

3
4

BAILEY GLASSER

BY:

LARRY LEDERER, ESQ.

1055 Thomas Jefferson Street, NW

Suite 540

Washington, DC 20007

- and -

NOLAN, HELLER & KAUFFMAN

BY:

GREGORY ZINI, ESQ.

80 State Street

11th Floor

Albany, New York 12207

ATTORNEYS FOR THE PLAINTIFFS;

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BALLARD SPAHR

BY:

ED ROGERS, ESQ.

CHESLEY BURRUSS, ESQ.

1735 Market Street

51st Floor

Philadelphia, Pennsylvania 19103

ATTORNEYS FOR THE DEFENDANT.
215-341-3616
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Def_Appx_0020
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Deposition of William M. Manger, Jr.

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I'm going to start at the beginning.

Yeah.

You would agree that the borrower seeking a

PPP loan needed to provide certain documents

evidencing their right to get one of these loans?

Correct.

And one type of document was payroll

records.

That's correct.

And if the borrower had no payroll, as in

the case of a sole proprietor, it needed to provide

other types of documents such as tax returns, and,

in particular, a Schedule C?

I believe that's correct, yes.

And that at times the borrower had to

provide bank statements evidencing the business

activity in which the borrower was engaged?

I believe that's true.

I want to go back to this concern about

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speed.
Can we agree that the speed of processing

is inversely related to the volume and nature of

documents that are required to be submitted by the

borrower?
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Larry rather than just give it to someone else.

That's my scenario?

MR. LEDERER:

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Well, yeah, yeah, yeah -Excuse me.

Is there a question?

BY MR. ROGERS:
Q

My question is:

Can Larry force you to

take that money and credit it to Ed Roger's account

at Manger Bank & Trust, which you believe doesn't

exist?

Well, I would just say if there's no

account, you can't put the money in no account.

yeah, that's logical.

Okay.

So,

And how about the next item is an

"Invalid Account Number Initiated Under Questionable

Circumstances."

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Can Larry force you to take the money in
that instance?
A

Again, if -- I've had this happen to me,

actually, with an ACH.

that was incorrect.

account, the one number off made it very difficult.

So in that instance the bank reached out to me and

said we're having a problem with this.

us verify your account number.

I had one number in a series

Although I have a legitimate

Can you help

And then I actually

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told the bank, this is the correct number, and then

they said, oh, yes, we were one digit wrong in the

series of numbers that we had for the account, so

now that we've corrected it, now -- now it will

work.

So, again, I would say that you'd have to

-- the lender would have to understand why this

wasn't working properly and try and rectify the

situation just like my bank did with my ACH account.

MR. ROGERS:

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Okay.

Let's build on that example.
We can take down the document now.

BY MR. ROGERS:
Q

Are you aware, sitting here today, based on

your review of the Castillo Declaration, that

Prestamos had a process to correct errors of the

type you mentioned, among others, and it was

referred to as the reverification process?

MR. LEDERER:

Yeah.

Objection to form.

I mean, they may have had that

system.

whether it was used in every instance.

BY MR. ROGERS:

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Again, I don't -- I'm not able to say

I'm not asking you whether it was used in

every instance.
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And it says "Evolve Bank & Trust."

Do you see that?

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Hold on.

I got to put my glasses on again.

It -- it -- yes, I see that.

Yes.

So I want to make sure I'm understanding

the document correctly, consistent with your

experience as the -- you know, experience at the

SBA.

Yeah.

As part of the required documents, a

borrower needed to direct the lender to transfer the

loan proceeds to the borrower's bank account; am I

correct?

Yes.

So in this case we have redacted the

account number to protect Ms. Marshall's privacy,

but the --

Sure.

-- but am I correct that this form shows

that Ms. Marshall directed Prestamos to put money --

to put the loan proceeds into her account at Evolve

Bank & Trust, and then she listed the account number

and the routing; correct?

That's what it appears to be, yes.
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was not, prior to reading this Declaration?
A

I don't know if I remembered anything about

a specific process that I had knowledge of, and --

yeah, and then -- yeah, it gets more confusing in

that it says that if it didn't go through, they got

like a prepaid card.

So it gets more confusing because,

obviously, that wasn't part of the PPP, to get

prepaid cards.

That's out of my realm of understanding in regard to

the Paycheck Protection Program.

Okay.

So I can't really speak to that.

Now I want to go back to paragraph

20 of your opening report, and we're going to go to

the middle of page 7.

below the middle of the page.

highlight it for us.

report.

It says -- it's just a little
Chesley will

This, again, is your opening

"A mere attempt to fund a loan, or an

attempt to do so that, for instance, the borrower's

bank rejected, should have resulted in the loan

being cancelled in SBA's e-tran system."

Do you see that?

Yes.

Is it your view that consistent with the
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Deposition of William M. Manger, Jr.

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Alicia Marshall, et al. v. Prestamos CDFI, LLC

program, Prestamos should not have given the

borrower a second chance to satisfy the

documentation requirements, but should simply have

cancelled the loan if it was rejected by the bank

the first time?

No.

The lender should have tried to clear

up with the borrower any of the, you know,

documentation that didn't, you know, seem to be

accurate.

account number was off.

Like my example, one of the digits in the

Right.
And that's consistent with the purpose and

the intent of the program that you were in charge of

running, that you wanted to get the money out and

you wanted to maximize the federal financial support

to COVID-affected small businesses?

17
18
19

Correct.

And I think what I stated here is

completely in line with that.
Q

So, in other words, when you say a mere

attempt to fund a loan, included in the mere attempt

is this verification -- reverification process?

Yes.

I mean, what I was getting at here is

if the bank, you know, formally rejected it for some

reason, that should have been communicated to the
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Exhibit 5
D. Castillo Declaration

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ALICIA MARSHALL, et al., individually
and on behalf of all others similarly situated,

Plaintiffs,
Civil Action No. 5:21-cv-04337-JMG

PRESTAMOS CDFI, LLC,

Defendant.
DECLARATION OF DAVID CASTILLO
Pursuant to 28 U.S.C. § 1746, I hereby declare as follows:
1.

My name is David Castillo. I am over the age of 18 and competent to make this

declaration, which is based on my personal knowledge.
2.

I have been employed by Prestamos CDFI, LLC (“Prestamos”) since September

02, 2014. I am currently Senior Credit Officer with Prestamos and have served in that role since
November 2023. Prior to this, I was Portfolio Manager.
3.

Under my new role, I am responsible for managing risk. See Job Description for

more detail.
4.

Prestamos is a Community Development Financial Institution (“CDFI”) created in

2000 with the mission of building strong communities by providing small business owners access
to capital through non-traditional financing resources.
5.

CDFIs are certified by the U.S. Department of the Treasury and are private-sector,

financial intermediaries that work to supply tools to economically disadvantaged individuals and
underserved communities to become self-sufficient.

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Prestamos is committed to supporting small businesses that face barriers to securing

credit from traditional lending sources because of smaller loan requests, a need for flexible
underwriting, or the need for assistance to meet underwriting standards.
7.

In its capacity as a CDFI, Prestamos provides financial services, loans, investments;

training and technical assistance services, and promotes development efforts that enable
individuals and communities to effectively use credit and capital. Prestamos works with
communities in Arizona, California, Nevada, New Mexico, and Texas.
8.

During the COVID-19 pandemic, the federal government enacted the Coronavirus

Aid, Relief, and Economic Security Act (“CARES Act”), which included the Paycheck Protection
Program (“PPP”). The PPP was designed to help small businesses, include sole proprietors,
continue to pay their workers during the pandemic.
9.

In May 2020, the U.S. Small Business Association (“SBA”)—the federal agency

responsible for reviewing and approving PPP loans—allowed CDFI lenders to participate in the
PPP loan process as part of the second round of PPP funding. On or around April 2020, the SBA
approved Prestamos to act as a PPP lender.
10.

Prestamos was a lender through its own SPARK program and through its contact

with Blueacorn.
11.

Prestamos approved 494,415 PPP loans, and completed 3,146 loans through

SPARK and 460,841 loans with the assistance of Blueacorn. Some approved borrowers did not
sign SBA Form 147, the loan note, and their loans were never funded.
12.

Prestamos began working with Blueacorn, as its lender service provider for PPP, in

April 2021. Prestamos and Blueacorn agreed that Blueacorn would include Prestamos among the

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lenders Blueacorn used when submitting PPP loan applications to the SBA, and Prestamos agreed
to use Blueacorn for due diligence.
13.

While not a lender itself, Blueacorn committed to connect PPP lenders with

borrowers. Blueacorn partnered with an advertising company that directed prospective PPP
borrowers to Blueacorn’s website.
14.

Once there, Blueacorn outlined that a potential borrower could submit information

to determine if they met the criteria for a PPP loan and, if so, the potential borrower could then use
the Blueacorn website to provide the additional information needed to complete a PPP loan
application.
15.

After a potential borrower completed a PPP loan application, Blueacorn committed

to conducting an initial round of due diligence to determine if the applicant met the SBA
requirements. Blueacorn committed to use individual reviewers along with proprietary software to
conduct due diligence.
16.

Blueacorn outlined that once it completed due diligence on an application, it would

submit the application to the SBA for approval and would designate a PPP lender (sometimes
Prestamos).
17.

Once Blueacorn submitted an application to the SBA, the SBA would make a

decision approving or denying the application. The SBA did not approve all applications.
18.

If the SBA denied an application, Prestamos generally did not take any further

19.

If the SBA approved a PPP loan application, the applicant was required to execute

action.

a promissory note and other loan documents. Blueacorn committed to transmitting those
documents to each borrower and, once completed, returned the documents to Prestamos.

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20.

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Once the SBA approved a borrower’s PPP loan application and the borrower signed

and returned the promissory note and loan documents, Prestamos would either send an Automated
Clearing House (“ACH”) payment electronically to the account the borrower designated on the
loan documents or cancel the loan.
21.

Pursuant to the CARES Act, the Federal Reserve maintained a credit facility from

which PPP lenders could borrow funds for use in issuing PPP loans.
22.

When a borrower’s PPP loan application was approved by the SBA, and the

borrower signed a promissory note, Prestamos would request a credit advance from the Federal
Reserve.
23.

If Prestamos canceled a loan, it was usually because the application was flagged by

Blueacorn’s software for suspected fraud.
24.

This suspected fraud could be because of issues relating to identity verification,

business verification, and/or financial verification among other things, including bank rejections
of loan proceeds by banking institutions that had established Anti-Money Laundering/Bank
Secrecy Act (“AML/BSA”) policies, as well as information collision (e,g., when borrowers used
the same address or Schedule C, etc.).
25.

Notably, this entire process took place on a very compressed time schedule. In

approximately six weeks, Prestamos funded 463,987 PPP loans. On average, it took Prestamos 8
days from the time the SBA approved a borrower’s application to fund the borrower’s PPP loan.
26.

Because of the high volume of PPP loans for which Prestamos acted as the lender,

Prestamos sent orders to its bank, Evolve Bank & Trust (“Evolve”), for ACH payments in batches
by compiling the information needed to make a given payment (i.e., borrower name, recipient
bank, payment amount, account, and routing number) into a single spreadsheet.

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27.

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Prestamos’ bank, Evolve would then provide confirmation that the requested ACH

payments were made to borrowers.
28.

Prestamos is a non-depository bank, and did not (and does not) have the liquidity

that other SBA-approved PPP lenders had. As a result, in order to fund PPP loans, Prestamos
needed a credit advance from the Federal Reserve.
29.

In order for the Federal Reserve to release the funds for a credit advance, Prestamos

had to submit both the SBA Form 1502 to the SBA and the “Paycheck Protection Program
Liquidity Facility PPP Pledge and Advance Request” to the Federal Reserve—i.e., Prestamos had
to submit SBA Form 1502 before any money was released by the Federal Reserve or deposited
into a borrower’s account.
30.

Before drafting this declaration, I reviewed paragraphs 20 and 43 of Plaintiffs’

expert William Briggs’s report, as well as paragraphs 20 and 23 of Plaintiffs’ expert William
Manger’s report. Both Briggs and Manger state that lenders were supposed to file SBA Form 1502
after a PPP loan was funded. That may have been true for depository banks that were also PPP
lenders. But for non-depository banks like Prestamos—who had to rely on credit advances from
the Federal Reserve—that was not possible.
31.

The “loan status” section of SBA Form 1502 needed to be filled out as “Funded,”

“Undisbursed,” or “Cancelled.” Prestamos used “Funded” in order to initiate the credit advance
from the Federal Reserve.
32.

A small percentage of the PPP loans that Prestamos funded in the manner described

above were rejected by the borrowers’ banks. In other words, the loan funds were sent
electronically from Prestamos’s bank, Evolve, by ACH payment, the borrower’s bank received the
funds, and the borrower’s bank returned or rejected the funds.

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33.

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ACH payments, including loans, may be rejected for a number of reasons. In fact,

there are more than eighty (80) ACH “return codes” that a receiving depository financial institution
(“RDFI”) may use when returning an ACH payment to the originating depository financial
institution (“ODFI”).
34.

The same was true for PPP loans. For example, borrowers’ banks returned ACH

payments because the borrower’s bank account was closed, frozen, subject to a stop payment,
invalid, nonexistent, or unable to be located. The ACH payment may also have been returned
because the account holder was deceased, the name on the account did not match the name listed
in the requested ACH, or a governmental agency told the bank to reject the loan funds.
35.

Moreover, a bank’s policies could have caused the rejection of the borrower’s ACH

payment. For example, the borrower may have identified a personal bank account that could not
accept business loans (such as a PPP loan). A borrower’s bank may have rejected loan funds for a
number of other reasons, including: the account was non-depository; the account holder failed to
submit required documentation; or the bank detected fraud.
36.

When a borrower’s bank rejected an ACH payment, it would notify Prestamos of

the rejection and the ACH return code, along with any other reasons listed for not depositing the
funds.
37.

Pursuant to its contract with Prestamos, Blueacorn was responsible for addressing

the ACH return issues with the borrowers through reverification. Blueacorn resolved a large
number of PPP loan rejections, which enabled those borrowers to receive the full amount of their
PPP loans. For some borrowers whose ACH payment did not go through, their PPP loan was
deposited on a prepaid card and sent to them.

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38.

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Notably, the rules governing PPP loans required banks to act consistent with their

AML/BSA compliance programs. Prestamos is not a depository bank, and therefore did not have
a AML/BSA compliance program. Instead, if an ACH payment was flagged by a borrower’s bank
consistent with its AML/BSA compliance program, it triggered Prestamos’s reverification process.
39.

In addition, in March 2021, the SBA Office of Inspector General and the U.S.

Secret Service Office of Investigations issued guidance to Prestamos and other PPP lenders that,
if a borrower’s bank rejected PPP loan funds, it was a sign of suspicious activity by the borrower.
Based on this guidance, Prestamos and other lenders began to conduct enhanced due diligence for
those borrowers.
40.

Blueacorn committed to perform this enhanced due diligence, which included the

close examination of the borrower’s file (as opposed to the generalized review that was conducted
at the application and submission stage). Prestamos understands that the precise steps taken during
the enhanced due diligence process were not uniform, but varied depending on the ACH return
code or any other specific issue identified as causing the failed deposit.
41.

Enhanced due diligence consisted of additional steps, such as requesting

submission of additional identification, asking security questions, and/or seeking additional
financial information (e.g., tax returns or bank statements).
42.

Blueacorn committed to manually review the entire loan file and looked for any

evidence of fraud or other suspicious activity. During the manual review, Blueacorn could
potentially identify a separate reason, aside from that identified by the ACH return code, that the
loan should not be funded. Blueacorn could follow up with the borrower about these lateridentified issues.

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43.

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If a borrower cleared the enhanced due diligence process, Prestamos would fund

the loan again by instructing Evolve to issue an ACH payment to the borrower’s bank account.
For some borrowers, this second attempt to fund the loan was successful. In some cases, however,
the borrower’s bank once again rejected the funds.
44.

If a borrower’s bank rejected the PPP loan ACH payment a second time, Prestamos

usually did not make further attempts to deposit the loan amount.
45.

Similarly, if a borrower failed the enhanced due diligence process—either because

the borrower failed to resolve the issue identified during the first payment attempt or failed to
resolve evidence of fraud or suspicious activity discovered during the enhanced due diligence—
Prestamos generally did not make further attempts to pay the PPP loan funds.
46.

Prestamos was required to submit SBA Form 1502 monthly to report updates on

the status of PPP loans. During reverification and/or the enhanced due diligence process,
Prestamos would keep the loan status as “Funded” on SBA Form 1502.
47.

If a party failed the reverification and/or enhanced due diligence process, or failed

to provide the documents Blueacorn requested to complete the process, Prestamos changed the
loan status from “Funded” to “Cancelled” on SBA Form 1502.
48.

As a general matter, Prestamos’s practice regarding approved loans—consistent

with SBA guidance for PPP loans and other SBA loans—was to direct Evolve to disburse the
money. Once the ACH payment was initiated and sent to the borrower’s bank, Prestamos’s role in
the PPP loan disbursement process was complete, subject to any reverification by Blueacorn.
49.

Indeed, once Evolve attempted to make an ACH payment at Prestamos’s request,

Prestamos did not have control over the ultimate disposition of the funds and was not in a position

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to override or dispute any rejection by a borrower’s bank, which, as noted above, was often a result
of a borrower’s bank’s AML/BSA compliance program.
50.

Unlike other SBA loan programs, and because of the quick turnaround required by

the program, PPP loans did not go through full underwriting, which would likely have prevented
the actions taken by some borrower’s banks, including returning ACH payments or freezing them.
51.

In September 2021, Prestamos returned the credit advances from the Federal

Reserve for loans that were ultimately not funded.

I certify under the penalty of perjury that the foregoing is true and correct.

Executed on August 9, 2024.

David Castillo

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JOB DESCRIPTION
Title: Chief Credit Officer

Reports To: Vice President of Prestamos

Classification:
‫ ܆‬Exempt ‫ ܆‬Non-Exempt
Hours:
‫ ܆‬FT ‫ ܆ ¾ ܆‬PT ‫ ܆‬On-Call ‫܆‬
Temp
Schedule:
‫ ܆‬Within Standard Business Hour Range
‫ ܆‬Atypical
If Atypical: ‫ ܆‬School Schedule ‫܈‬
Evenings
‫ ܆‬Nights ‫ ܆‬Weekends ‫ ܆‬Staggered
Days
Emergency Essential:
‫ ܆‬Yes
‫ ܆‬No

Program/Department: Prestamos
Pillar:
Economic Development
Executive Vice President:
Jose Martinez, EVP, Economic Development
Eligible for:
‫ ܆‬Phone Allowance ‫ ܆‬Mileage (Federal Rate) ‫ ܆‬Car
Allowance
Established Date:
Click or tap to enter a date.

Revision Date(s):

OBJECTIVE AND POSITION SUMMARY
Responsible for providing support, direction, credit information, and loan policies and procedures to ensure
the overall quality of the lending portfolio. Duties include calculating the Allowance for Loan Loss Reserve
(ALL) and making recommendations to executive management and the Board of Directors for monthly
allocations to the Loan Loss Reserve. Responsible for execution and communication of policy, approval
process, administration, portfolio analysis and asset quality Reviews large and complex loans prior to
submission to Loan Committee. Reviews loan portfolio on a continuing basis in order to manage the
mitigation of risk associated with the loan portfolio, oversee collections and loan procedures losses and
ensures internal compliance objectives are met. Ensures that appropriate policies, procedures, and systems
are developed, implemented, and maintained to identify, measure, monitor and control credit risks in
accordance with credit policies, standards, and applicable regulatory guidelines.
SUPERVISORY RESPONSIBILITIES
Supervise the Director of Loan Servicing and works directly with the Director of Lending.
SPECIALIZATIONS
x Demonstrated understanding of loan underwriting structures, pricing and processes as they relate to
the funding of small business loans for business start ups and ongoing business entities.
x Must have thorough knowledge of financial accounting theory and logic and loan structuring.
x Must maintain a demonstrated understanding of loan analysis, closing, funding and collections
procedures.

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JOB DESCRIPTION
x
x
x
x
x

Must be able to communicate information and concepts clearly, both orally and in writing; ability to
interpret and discuss analytical data.
Technical skills should include proficiency in MS Office (Word and Excel in particular) as well as a
familiarity with Microsoft Outlook and loan portfolio software systems
Must understand auditing practices
Helpful to have a working knowledge of SBA lending programs and New Market Tax Credit financing.
Ability to work independently, as well as in a team environment.

PRIMARY DUTIES AND ESSENTIAL FUNCTIONS
x

Oversee the credit approval process, as well as portfolio monitoring systems for all current and future
credit products.

Responsible for the credit policies and its compliance with the applicable regulations and laws, credit
risk, product and program management.

Ensure that credit policies are routinely reviewed, modified as necessary, and well-communicated
throughout the organization.

Ensure that allowance for credit losses and the charge-off process and procedures are consistent with
industry best practices and meet current and anticipated accounting and regulatory guidelines.

Monitor and track all underwriting activity to ensure underwriting guidelines and regulations are being
adhered to, and information is analyzed and completed within established timelines.
Ensuring that systems of internal controls and procedures are consistent with the best practices in the
industry and are appropriate for all regulatory requirements.
Ensuring that all loan systems and tracking techniques provide the appropriate data to management,
and the Board of Directors, to allow for accurate assessment of loan quality and risk management.
Provide overall loan portfolio management analysis and oversight to ensure that the Prestamos’ asset
quality meets objectives, and that the emphasis of Prestamos’ overall credit relationship management
is consistent with Prestamos’ underwriting standards.
Support diversification of the loan portfolio by establishing sound credit policies and proper training of
BDOs and credit officers.

x
x
x

x
x

Maintain knowledge of applicable state and federal lending and compliance laws and regulations and
implement appropriate policies, procedures, and controls.

Assist with the monitoring of loan performance in the Prestamos’ portfolio and ensure loans are
appropriately Risk Rated and adequately reserved. Attempts to ensure that individual loans are risk
rated correctly when reviewing loans for loan committee submission.

Prepare all portfolio performance reports for senior management and Executive Board.

Manage loan delinquencies and loan servicing matters, including third party servicers & facilitate
appropriate strategies and procedures to ensure that delinquencies and defaults are effectively
managed and reported to the Executive Management, and the Board.

Underwrite, structure and present large and complex loans.

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JOB DESCRIPTION
x

Review and recommend loan requests for approval submitted by BDO/ loan analysts within delegated
authority limits.

Reviews and approves/declines large loans prior to submission to Loan Committee.

Approve short-term loan payment adjustments within delegated authority limits.

Generate all memos that explain all divergence from the loan approval and obtain all necessary
approvals.

Identify problematic loans and manage workouts. Supervises Prestamos’ collections and assists in
curing weak credits, collection of such credits, or the movement of such undesirable credits.

Negotiate, recommend and discuss workout and or liquidation strategies to minimize loss to the
Prestamos and to maximize recovery.

Meets with Director of Loan Servicing and Sets goals/strategies for payment resolution of impaired
loans.

Manage liquidations of collateral

Manage Loan Loss Reconciliation in coordination with the Accountant

Generate and lead monthly Portfolio Quality Review with Vice President and BDOs

Updates job knowledge by participating in educational opportunities; reading professional
publications; maintaining personal networks; participating in professional organizations.

Document and report on lending relationships' status and quality.

Investigate and understand discrepancies, problems, and unusual situations.

Analyze financial information to determine credit quality, approve credit, and document risk factors.

x
x

Develop and document risk mitigation standards and processes.
May perform other duties as assigned

MINIMUM QUALIFICATIONS AND COMPETENCIES
1. Education /Background:
x Candidate should possess a minimum of a bachelor’s degree in finance, business or accounting or
combination of education and experience. Work related experience should consist of a financial
analyzing or lending background
x Advanced degree preferred.
x Mastered experience, knowledge and training in financial statement and tax return analysis typically
resulting from a combination of education in accounting, financial and/or credit analysis or related
areas.
x Possess a clear understanding of reporting guidelines.
x 10+ years of experience working in credit risk analytics and/or risk management with financial
institutions including the development of credit policy, underwriting standards, and internal risk rating
scorecards.
x Knowledge of and experience in regulatory compliance, including CRA and Fair Lending compliance.
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JOB DESCRIPTION
2. Other requirements:
x

Able to work in office Monday through Friday

Effective January 3, 2022, all CPLC Employees and all Service Providers, are required to be Fully Vaccinated
against COVID-19. Newly hired employees, who are not Fully Vaccinated at the time of hire, are expected to
begin a vaccination series immediately upon hire. CPLC recognizes medical and religious exemptions to the
COVID-19 vaccination requirement, in accordance with applicable law and upon approval by CPLC. However,
any person approved for an exemption, without exception, is subject to masking, weekly COVID-19 testing at
their expense, and other requirements established by CPLC from time to time.

PHYSICAL DEMANDS AND TYPICAL WORKING CONDITIONS (please review below the 3 categories and edit
as necessary)
Position requirements: This position is both a mobile and a sedentary position with periods of light physical
activity, and is performed mostly in office surroundings. Positions typical in nature require regular walking or
standing; sitting, lifting and carrying up to 20 pounds; climbing stairs, bending, reaching, holding, grasping and
turning objects; and using fingers to operate computer keyboards. This position will require the ability to speak
normally and to use normal or aided vision and hearing.
Travel: Local, interstate and intrastate travel to Chicanos Por La Causa, Inc., its affiliates and/or subsidiaries, will
be necessary to successfully fulfill the duties of this position. Candidate must have and maintain a valid driver’s
license and auto insurance. Technology will be utilized to minimize travel whenever feasible. The travel
requirements for this position are anticipated to be 25 to 35 percent assignment depending. Overnight travel
must be approved in advance by the Department VP.
Continuous Learning: All certifications related to the position at hire, or obtained while employed by CPLC,
must be maintained. Candidate will be expected to participate in continuous learning opportunities to maintain
competency and enhance skillset. Learning opportunities must be approved by Department VP.
LIMITATIONS AND DISCLAIMER
This job description is meant to describe the general nature and level of work being performed; it is not
intended or is implied to be construed as an exhaustive list of all responsibilities, duties and skills required for
the position. Duties, responsibilities and activities may change or new ones may be assigned at any time with
or without notice.
Requirements are representative of minimum levels of knowledge, skills and/or abilities. To perform this job
successfully, the employee must possess the abilities or aptitudes to perform each duty proficiently. All
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JOB DESCRIPTION
employees are accountable for understanding and complying with all corporate policies and procedures as well
as any program specific policies and procedures. Continued employment remains on an “at-will” basis.
This job description is subject to possible modification to reasonably accommodate individuals with
disabilities. Some requirements may exclude individuals who pose a direct threat or significant risk to the
health and safety of themselves or other employees. Employee signature below indicates the employee’s
understanding of the requirements, essential functions and duties of the position.
EMPOWERING LIVES THROUGH CONTINUOUS LEARNING
Continuous Learning: All certifications related to the position at hire, or obtained while employed by CPLC, must be
maintained. Candidate will be expected to participate in continuous learning opportunities to maintain competency and
enhance skillset. Learning opportunities must be approved by supervisor.
CPLC Mission, Vison and Values in Action: Our mission and purpose is to drive economic and political empowerment. We
cannot achieve our vision of “Empowered Lives” without the full engaged participation of each employee. Each CPLC
employee is expected to adhere not only to the CPLC Code of Conduct when acting on behalf of CPLC, but each employee
is also expected to contribute to promoting and demonstrating CPLC’s Values in Action in their interactions with clients,
other CPLC employees, CPLC stakeholders, and at any and all times representing CPLC.
CPLC Values in Action
(1) I deliver on my commitments
(2) I bring innovative solutions and adapt to address challenges.
(3) I advance and own my professional and personal growth.
(4) I engage passionately and fully in advocating for, and responding to, the needs of our community.
(5) I demonstrate respect with honest and transparent communication.
(6) I protect CPLC resources as if they are my own.
I understand, acknowledge and will do my utmost to fulfill the job duties and functions as outlined above and to
demonstrate CPLC’s values in my behaviors and actions now that I have become an integral and vital part of the CPLC
Familia.

Employee Name (Print)

Hiring Manager Name (Print)

Employee Signature

Hiring Manager Signature

Date

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Exhibit 6
Disbursement and Return Compilation

-20780

-7915

6/2/2021

5/13/2021

-4130

6/20/2021

20832

Account

-20832

Bank Routing

Account

SBA Funding:

CustomerName Description

PRESTAMOS CDFI, LLC

Individual ID

PRESTAMOSCDFI

Immediate Destination Name

Amount

PRESTAMOSCDFI

Immediate Destination Name

Amount

PRESTAMOSCDFI

Immediate Destination Name

Normal

File Type

Def_Appx_0041

gregory lloyd

Name

PRESTAMOS-00452293

Individual ID

SBA

Amount

BATES NO. EVOLVE-00000003

Individual ID

BATES NO. EVOLVE-00000012

Kolawole Ahmadou

ABA/Routing Individual Name

Jamie Jones

PARIS TOWNSEND

Amount

Prestamos ACH

Table Names

20832 SBA Funding:

Text4

4130 SBA Funding

20012 SBA Funding:

12500 SBA Funding:

Text4

19020 SBA Funding:

10865 SBA Funding:

Text4

7915 SBA Funding:

20780 SBA Funding:

14165 SBA Funding:

1875 SBA Funding:

Text4

checking

Type

R23

Return Code

R23

R03

Return Code

R23

R17

Return Code

R23

R16

R03

Return Code

5/31/2021

date

Credit Entry Refused by Receiver

Return Description

Credit Entry Refused by Receiver

No Account/Unable to Locate Account

Return Description

Credit Entry Refused by Receiver

File Record Edit Criteria

Return Description

Credit Entry Refused by Receiver

Account Frozen

No Account/Unable to Locate Account

Return Description

Filed 05/07/25

Amount

7/6/2021

Amount

-20012

6/16/2021

SHARON SMITH

ABA/Routing Individual Name

RESTAMOSCDFI

PRESTAMOSCDFI

Immediate Destination Name

BATES NO. EVOLVE-00000020

Individual ID

Document 157-3

Date

-12500

6/11/2021

Account

5/28/2021

Amount

Lametria Marvel

Date

John Martin

-10865

ABA/Routing Individual Name

Alicia Marshall

Alyshia Johnson

Jahbrael Horne

Kristina Henderson

ABA/Routing Individual Name

-19020

Account

5/26/2021

Amount

-14165

6/7/2021

Date

-1875

Amount

5/13/2021

Date

BATES NO. EVOLVE-00000027

Case 5:21-cv-04337-JMG
Page 48 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Page 49 of 186

Exhibit 7
SBA and Secret Service PPP Application
Fraud Indicators

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0042

Filed 05/07/25

Page 50 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0043

Filed 05/07/25

Page 51 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Page 52 of 186

Exhibit 8
SBA DirectLYH to Recover on Fraud
Loans

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0044

Filed 05/07/25

Page 53 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0045

Filed 05/07/25

Page 54 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0046

Filed 05/07/25

Page 55 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0047

Filed 05/07/25

Page 56 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0048

Filed 05/07/25

Page 57 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0049

Filed 05/07/25

Page 58 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0050

Filed 05/07/25

Page 59 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0051

Filed 05/07/25

Page 60 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0052

Filed 05/07/25

Page 61 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0053

Filed 05/07/25

Page 62 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0054

Filed 05/07/25

Page 63 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0055

Filed 05/07/25

Page 64 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0056

Filed 05/07/25

Page 65 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0057

Filed 05/07/25

Page 66 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0058

Filed 05/07/25

Page 67 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0059

Filed 05/07/25

Page 68 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0060

Filed 05/07/25

Page 69 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0061

Filed 05/07/25

Page 70 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0062

Filed 05/07/25

Page 71 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0063

Filed 05/07/25

Page 72 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0064

Filed 05/07/25

Page 73 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0065

Filed 05/07/25

Page 74 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0066

Filed 05/07/25

Page 75 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0067

Filed 05/07/25

Page 76 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0068

Filed 05/07/25

Page 77 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0069

Filed 05/07/25

Page 78 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0070

Filed 05/07/25

Page 79 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0071

Filed 05/07/25

Page 80 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0072

Filed 05/07/25

Page 81 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0073

Filed 05/07/25

Page 82 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0074

Filed 05/07/25

Page 83 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0075

Filed 05/07/25

Page 84 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0076

Filed 05/07/25

Page 85 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0077

Filed 05/07/25

Page 86 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0078

Filed 05/07/25

Page 87 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0079

Filed 05/07/25

Page 88 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0080

Filed 05/07/25

Page 89 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0081

Filed 05/07/25

Page 90 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0082

Filed 05/07/25

Page 91 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0083

Filed 05/07/25

Page 92 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0084

Filed 05/07/25

Page 93 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Page 94 of 186

Exhibit 9
Compilation of Examples RDFI Seeking
Return of Suspect Funds

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Page 95 of 186

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Def_Appx_0085

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0086

Filed 05/07/25

Page 96 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0087

Filed 05/07/25

Page 97 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0088

Filed 05/07/25

Page 98 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Def_Appx_0089

Filed 05/07/25

Page 99 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0090

Page 100 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0091

Page 101 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0092

Page 102 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0093

Page 103 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0094

Page 104 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0095

Page 105 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0096

Page 106 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0097

Page 107 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0098

Page 108 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0099

Page 109 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0100

Page 110 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0101

Page 111 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0102

Page 112 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0103

Page 113 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0104

Page 114 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0105

Page 115 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0106

Page 116 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0107

Page 117 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0108

Page 118 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0109

Page 119 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0110

Page 120 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0111

Page 121 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0112

Page 122 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0113

Page 123 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0114

Page 124 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0115

Page 125 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0116

Page 126 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0117

Page 127 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0118

Page 128 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0119

Page 129 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0120

Page 130 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0121

Page 131 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0122

Page 132 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0123

Page 133 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0124

Page 134 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0125

Page 135 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0126

Page 136 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0127

Page 137 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0128

Page 138 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0129

Page 139 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0130

Page 140 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0131

Page 141 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0132

Page 142 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0133

Page 143 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0134

Page 144 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0135

Page 145 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0136

Page 146 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0137

Page 147 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0138

Page 148 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0139

Page 149 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0140

Page 150 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0141

Page 151 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0142

Page 152 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0143

Page 153 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0144

Page 154 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0145

Page 155 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0146

Page 156 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0147

Page 157 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0148

Page 158 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0149

Page 159 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0150

Page 160 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0151

Page 161 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0152

Page 162 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0153

Page 163 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0154

Page 164 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0155

Page 165 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0156

Page 166 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0157

Page 167 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0158

Page 168 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0159

Page 169 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0160

Page 170 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0161

Page 171 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0162

Page 172 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0163

Page 173 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0164

Page 174 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0165

Page 175 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0166

Page 176 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0167

Page 177 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0168

Page 178 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0169

Page 179 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0170

Page 180 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0171

Page 181 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0172

Page 182 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0173

Page 183 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0174

Page 184 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0175

Page 185 of 186

Case 5:21-cv-04337-JMG

Document 157-3

Filed 05/07/25

Def_Appx_0176

Page 186 of 186

File and source

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Size: 14,145,305 bytes
SHA-256: bb0fe56df41af8e3dcfd66e63af1b991c020056da51d44b4a57119c0fb7b1a45
Our copy: gov.uscourts.paed.589575.157.3.pdf
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Appendix Volume 1 — Marshall v. Prestamos CDFI, LLC (Dkt. 157-3, E.D. Pa. No. 5:21-cv-04337)

Record facts

Full text

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