Indictment — No. 1:26-cr-00358 (Dkt. 1, D. Md.)

Summary

The indictment of Kara DiPietro filed October 8, 2026 in the U.S. District Court for the District of Maryland, No. 1:26-cr-00358, charging bank fraud under 18 U.S.C. § 1344 in Counts One through Six and seeking forfeiture under 18 U.S.C. § 982(a)(2)(A). It describes DiPietro as President and CEO of Maryland companies including H.M.C., Inc., Holdings Management Company Inc. and Kinetic Capital LLC. The grand jury charges a scheme to defraud financial institutions including GNCU, Sandy Spring, FHB and CB through Paycheck Protection Program applications. One listed application, submitted May 4, 2020 to Sandy Spring for "HMC, Inc.," is for $664,331 and is alleged to have used an EIN assigned to Holdings.

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Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Pagei1of11

j LW/JMM USAO# 2023R00361

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

UNITED STATES OF AMERICA *
v. * CRIMINAL NO. M2 S98
*
KARA DIPIETRO, ne (Bank Fraud, 18 U.S.C. § 1344;
* Forfeiture 18 U.S.C. § 982(a)(2)(A))
Defendant. *
KKK KKK
INDICTMENT

COUNTS ONE THROUGH SIX
(Bank Fraud)

The Grand Jury for the District of Maryland charges that:

At times relevant to this Indictment:

L. Defendant KARA DIPIETRO (“DIPIETRO”) was a resident of Baltimore
County, Maryland.

Entities Associated With DIPIETRO

2. DIPIETRO was the President and CEO of multiple Maryland companies,
including H.M.C., Inc. (“HMC”), Holdings Management Company Inc. (“Holdings”), and Kinetic
Capital LLC (“Kinetic”).

3. In or about 2015, DIPIETRO purchased HMC from DIPIETRO’s relative.

4. From in or about 2015 until in or about 2020, HMC offered millwork and
constructions service and had multiple employees.

5, On or about November 1, 2018, DIPIETRO filed articles of incorporation creating
Kinetic.

6. On or about December 4, 2019, DIPIETRO filed articles of incorporation creating

Holdings. DIPIETRO also filed paperwork for Holdings to use “HMC” as a trade name.

Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Page 2 of 11

7. Between in or about 2020 and in or about 2021, Holdings assumed HMC’s
employees and business operations and HMC ceased operating as a business.

8. HMC and Holdings controlled a business location at 7190 Oakland Mills Road,
Suite 10, Columbia, Maryland.

9. HMC was assigned and used the internet protocol (“IP”) address 173.10.189.241
(“HMC IP”), with a listed address of 7190 Oakland Mills Road, Columbia, Maryland.

10. | DIPIETRO’s personal residence was assigned and used the IP address
71.179.172.29 (“DIPIETRO’s Home IP”).

11. DIPIETRO used a personal cell phone number ending in 1523 (1523 Cell”)

12. | HMC used an office phone number ending in 0729 (“HMC Phone”).

13. | DIPIETRO was assigned a nine-digit social security number (“K.D. SSN”)

Employer Identification Numbers

14. | An Employer Identification Number (“EIN”) is a federal tax identification number
assigned to businesses and other entities. Following an application, the Internal Revenue Service
(“IRS”) assigned a particular business a unique EIN. Any particular corporate entity was assigned
only one EIN at a time, and any particular EIN was assigned to only one corporate entity at a time.

1d. The EIN 52-2005467 was assigned to HMC.

16. The EIN 84-3773828 was assigned to Holdings.

17. The EIN 83-2424221 was assigned to Kinetic.

18. | The IRS had not assigned the EINs 84-3777828 and 54-2005467 to any business

entity controlled or associated with DIPIETRO.

Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Page 3of11

The Paycheck Protection Program

19. First Home Bank (“FHB”), Sandy Spring Bank (“Sandy Spring”), and Customers
Bank (“CB”) were financial institutions as defined in 18 U.S.C. § 20, and had their deposits insured
by the Federal Deposit Insurance Corporation (“FDIC”).

20. Greater Nevada Credit Union (“GNCU”) was a financial institution as defined in
18 U.S.C. § 20, and had its deposits insured by the National Credit Union Share Insurance Fund.

21. The United States Small Business Administration (“SBA”) was a_ federal
government agency that provided support to entrepreneurs and small businesses. The mission of
the SBA was to maintain and strengthen the nation’s economy by supporting the establishment
and viability of small businesses and by assisting in the economic recovery of communities after
disasters.

22. The Paycheck Protection Program (“PPP”) was a COVID-19 pandemic relief
program administered by the SBA that provided forgivable loans to small businesses for job
retention and certain other expenses. Pursuant to the PPP, participating third-party lenders
approved and disbursed SBA-backed PPP loans to cover, among other things, payroll, utilities,
rent/mortgage, and other bills incurred by qualifying businesses during, and resulting from, the
COVID-19 pandemic. PPP loans were fully guaranteed by the SBA.

23. To obtain a PPP loan, a qualifying business had to submit a PPP loan application
signed by an authorized representative of the business. The PPP loan application required the
business (through its authorized representative) to acknowledge the program rules and make
certain affirmative certifications to be eligible to obtain the PPP loan, including that the business
was in operation prior to February 15, 2020, and paid employees salaries and payroll taxes or paid
independent contractors. The authorized representative was also required to disclose any other

businesses they owned or controlled.

Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Page4of11

24. An entity applying for PPP benefits had to state its (a) average monthly payroll
expenses and (b) number of employees. These figures were used to calculate the amount of PPP
money the small business could receive. The business was required to provide documentation
supporting its claimed payroll expenses, such as federal income tax documents.

25. Eligible business entities with an EIN were able to obtain two PPP loans: a First
Draw loan and a Second Draw loan.

26. — Inthe First Draw PPP loan application, the business’ authorized representative was
required to certify that, during the relevant application window, “the Applicant has not and will
not receive another loan under the Paycheck Protection Program.”

27. In the Second Draw PPP loan application, the business’ authorized representative
was required to certify that the “Applicant has not and will not receive another Second Draw
Paycheck Protection Loan.”

28. PPP loan applications were electronically submitted or caused to be submitted by
the borrower and received through SBA servers located outside Maryland. Once approved, the
business received the PPP loan proceeds via an electronic funds transfer from the third-party lender
to a financial account provided by the business’ authorized representative during the application
process.

29. PPP loan proceeds were required to be used by the business on certain permissible
expenses, including payroll costs, rent for the business premises, interest on mortgages on the
business premises, utilities for the business, and worker protection costs related to COVID-19.

30. GNCU, FHB, Sandy Spring, and CB were third-party participating lenders in the

PPP program.

Case 1:26-cr-00358-MJM Documenti1 Filed 10/08/26 Page5of11

The Scheme to Defraud

a1. Beginning in and about April 2020 and continuing through in and about May 2021,
in the District of Maryland and elsewhere, the defendant,
KARA DIPIETRO,
knowingly devised and intended to devise a scheme and artifice to defraud financial institutions,
including GNCU, Sandy Spring, FHB, and CB, and to obtain money and property owned by or
under the custody and control of those financial institutions, by means of materially false and
fraudulent pretenses, representations, and promises.

The Object of the Scheme to Defraud

32. The object of the scheme to defraud was for DIPIETRO to obtain PPP loan
benefits for her financial gain.

Manner and Means of the Scheme to Defraud

It was part of the scheme to defraud that:

33. | DIPIETRO submitted, and caused to be submitted, PPP loan applications that
contained false statements, misrepresentations, and omissions related to multiple businesses,
including false information about the applying business entity’s operations, payroll expenses, and
number of employees.

34. | DIPIETRO submitted, and caused to be submitted, more than twenty PPP loan
applications on behalf of HMC, Holdings, Kinetic, and similarly spelled entities.

35. | DIPIETRO submitted, and caused to be submitted, PPP loan applications that
listed false and fraudulent EINs not assigned by the IRS to the applying entity.

36. | DIPIETRO caused the use of the HMC IP in connection with PPP applications for

HMC, Holdings, Kinetic, and similarly spelled entities.

Case 1:26-cr-00358-MJM Documenti1 Filed 10/08/26 Page6of11

37. DIPIETRO caused the use of DIPIETRO’s Home IP for multiple PPP
applications.
38. During 2020 and 2021, DIPIETRO caused the submission of PPP loan

applications, seeking more than $7.5 million, and obtaining more than $2.5 million, as reflected

below:
Approx. Approx.
Approx.| Applying |EINorTax] Electronic Phone Listed Email A t Ainount
Date Entity | ID Used Signer Listed shes ee ou
Requested| Funded
04/08/20 a 84-3777828] Kara DiPietro | .. hel K.dipietro@hmcincorporated.com| $ 57,940 _—
LLC [incomplete]
04/08/20 |Kinetic Capital 84-3777828] Kara DiPietro |___ 4! | k dipietro@hmeincorporated.com| $ 57,940 =
[incomplete]

04/22/20} HMC, Inc. |52-2005467] Kara DiPietro | HMC Phone | k dipietro@hmcincorporated.com| $ 429,004 —

Kara Anne

05/02/20} Holdings |84-3777828 Dipietro

1523 Cell | k.dipietro@hmcincorporated.com| $ 664,331] $ 664,331

05/04/20} HMC, Inc. |84-3773828] Kara DiPietro | HMC Phone | k dipietro@hmcincorporated.com| $ 429,004] $ 429,004

05/04/20 Nae ecag 83-2424221| Kara DiPietro | None listed |  kara@kineticcapitalliccom |$ 20,130| $ 20,130
05/14/20] HMC Inc. |52-2005467] Kara DiPietro 1523 Cell | k.dipietro@hmcincorporated.com} $ 433,000 _
06/04/20} HMC — |52-2005467 Sanan. 1523 Cell | k.dipietro@hmcincorporated.com| $ 433,000] $ 433,000
01/13/21 Holdings |84-3773828] Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 436,600 —

01/15/21] H.M.C., Inc. |52-2005467] Kara DiPietro 1523 Cell | k.dipietro@hmcincorporated.com| $ 466,772 —

01/15/21] H.M.C., Inc. |52-2005467] Kara DiPietro 1523 Cell | k.dipietro@hmcincorporated.com| $ 466,773 —

02/04/21 HMC Inc |84-3773828] Kara DiPietro | 1523 Cell | k.dipietro@hmcincorporated.com| $ 429,004] $ 429,004

02/07/21 Holdings |84-3773828] Kara DiPietro 1523 Cell |k dipietro@hmcincorporated.com]| $ 423,890 —

02/10/21 HMC 52-2005467] Kara DiPietro | 1523 Cell | k.dipietro@hmcincorporated.com| $ 466,772] $ 466,772

02/16/21 ee aes 83-2424221| Kara DiPietro | 1523 Cell k.dipietro@hmeoinc.com $ 20,130] $ 20,130
03/03/21 EMG 54-2005467} Kara DiPietro | 1523 Cell karahmckccf@gmail.com $ 327,395] $ 327,395
Incorporated


Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Page 7 of 11

03/13/21 HMC K.D. SSN | Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 471,445 —
03/16/21 HMC Inc K.D. SSN | Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 386,158 _
03/17/21 HMC Inc K.D. SSN | Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 437,925 _
03/17/21 Holdings |84-3773828] Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 371,365 —_
03/23/21 Holdings |84-3773828] Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 416,233 _
03/31/21] H.M.C., Inc. |52-2005467] Kara DiPietro 1523 Cell k.dipietro@hmcoinc.com $ 426,358 _
04/08/21 HMC K.D. SSN | Kara DiPietro 1523 Cell karahmckcecf@gmail.com $ 426,358 _
04/08/21} HMC., Inc. |52-2005467] Kara DiPietro 1523 Cell k dipietro@hmcoinc.com $ 426,358 _

39. | DIPIETRO caused the submission of PPP loan applications that did not disclose
prior PPP loan applications associated with (a) DIPIETRO; (b) the applying entity; and/or (c)
other entities owned, controlled, created, and/or used by DIPIETRO.

40. In or about April 2020, DIPIETRO caused Kinetic to apply for multiple PPP loans
using the EIN number 84-3777828, which was not assigned to Kinetic.

41. In or about February 2021, DIPIETRO caused the submission of a false and
fraudulent PPP loan application for Kinetic, which provided false information about Kinetic’s
employees, payroll expenses, and business operations.

42. DIPIETRO submitted, and caused to be submitted, false and fraudulent tax
information and documents in support of PPP loan applications.

43. | DIPIETRO caused the submission of PPP loan applications that contained false
certifications that the applicant business had not already received a First Draw PPP loan.

44. | DIPIETRO caused the submission of PPP loan applications that contained false
certifications that the applicant business had not already received a Second Draw PPP loan.

45. DIPIETRO attested that the information presented in PPP loan applications was

true and accurate when DIPIETRO then and there knew that was false.


Case 1:26-cr-00358-MJM Document1 Filed 10/08/26 Page 8of11

46. | DIPIETRO caused the use of the following email addresses on PPP applications:
k.dipietro@hmcincorporated.com, k.dipietro@hmcoinc.com, karahmckccf@gmail.com, and
kara@kineticcapitalllc.com.

47. DIPIETRO controlled and was the authorized signatory on the following bank
accounts: a Sandy Spring account ending 5801 (“SS 5801”), a Sandy Spring account ending in
4301 (“SS 4301”), a Bank of America account ending in 3171 (“BOA 3171”), and a Bank of
America account ending 8374 (“BOA 8374”).

48. DIPIETRO received, obtained, used, and controlled PPP loan proceeds that were
deposited into SS 5801, SS 4301, BOA 3171, and BOA 8374.

49. DIPIETRO caused PPP loan proceeds to be transferred and used for expenses not
permissible under the PPP, including renovations to DIPIETRO’s personal residence.

THE CHARGES

50. Onor about the dates set forth below, in the District of Maryland and elsewhere,
the defendant,
KARA DIPIETRO,
knowingly and willfully executed and attempted to execute the scheme and artifice to defraud
financial institutions, namely GNCU, Sandy Spring, FHB, and CB, and to obtain money, funds,
credits, assets, securities, and other property under the custody and control of the financial
institutions by means of materially false and fraudulent pretenses, representations, and promises,

as described below:

Case 1:26-cr-00358-MJM Document 1

Filed 10/08/26

Page 9 of 11

COUNT

DATE

DESCRIPTION

AMOUNT
OBTAINED

May 2, 2020

DIPIETRO submitted and caused the submission of
a PPP application to GNCU for Holdings that listed
an EIN not assigned to Holdings, falsely listed
Holdings’ average monthly payroll, and relied upon
a 2019 IRS Form 940 that was submitted to the IRS
by a different entity, HMC.

$664,331

May 4, 2020

DIPIETRO submitted and caused the submission of
a PPP application to Sandy Spring for “HMC, Inc.”
that listed an EIN assigned to Holdings, and falsely
certified that “[dJuring the period beginning on
February 15, 2020, and ending on December 31,
2020, the Applicant has not and will not receive
another loan under the Paycheck Protection
Program.”

$429,004

June 4, 2020

DIPIETRO submitted and caused the submission
of a PPP application to FHB for HMC that falsely
certified that “[d]uring the period beginning on
February 15, 2020, and ending on December 31,
2020, the Applicant has not and will not receive
another loan under the Paycheck Protection
Program.”

$433,000

February 4,
2021

DIPIETRO submitted and caused the submission
of a PPP application to Sandy Spring on behalf of
“HMC, Inc.” that falsely listed an EIN assigned to
Holdings, and falsely certified that “[t]he Applicant
has not and will not receive another Second Draw
Paycheck Protection Loan.”

$429,004

February 10,
2021

DIPIETRO submitted and caused the submission
of a PPP application to FHB for HMC that falsely
certified that “[t]he Applicant has not and will not
receive another Second Draw Paycheck Protection
Loan.”

$466,772

March 3,
2021

DIPIETRO submitted and caused the submission
of a PPP application to CB for “HMC,
Incorporated” that fraudulently listed an EIN not
assigned to that business and falsely certified that
“(t]he Applicant has not and will not receive
another loan under the Paycheck Protection
Program.”

$327,395

18 U.S.C. § 1344
18 U.S.C. § 2


Case 1:26-cr-00358-MJM Documenti1_ Filed 10/08/26 Page 10 of 11

FORFEITURE ALLEGATION

The Grand Jury for the District of Maryland further charges that:

lL. Pursuant to Rule 32.2, Fed. R. Crim. P., notice is hereby given to the defendant that
the United States will seek forfeiture as part of any sentence in accordance with 18 U.S.C.
§ 982(a)(2)(A) and 21 U.S.C. § 853(p), in the event of the defendant’s conviction of the offense
alleged in Counts One through Six of this Indictment.

2. Upon conviction of the offense alleged in Counts One through Six, the defendant,

KARA DIPIETRO

shall forfeit to the United States, pursuant to 18 U.S.C. § 982(a)(2)(A) any property, real or
personal, which constitutes or is derived from proceeds the defendant obtained, directly or
indirectly, as a result of the scheme to defraud.

Substitute Assets

as If, as a result of any act or omission by the Defendant, any of the property

described above as being subject to forfeiture:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third person;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been comingled with other property which cannot be divided without

difficulty,

the United States, pursuant to 21 U.S.C. § 853(p) and 28 U.S.C. § 2461(c), shall be entitled to

forfeiture of substitute property up to the value of the forfeitable property described above.

10

Case 1:26-cr-00358-MJM Document 1

18 U.S.C. § 982(a)(2)(A)
21 U.S.C. § 853(p)
28 U.S.C. § 2461(c)

SIGNATURE REDACTED

Foreperson

Date: 10/6 % /2 O26

1]

Filed 10/08/26 Page 11 of 11

J V u /4 ag
KELLY O. HAYES
UNITED STATES ATTORNEY

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