Clyburn to RER Solutions — EIDL Contracting Investigation Letter (July 30, 2020)

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July 30, 2020 
 
 
Errin Green 
Chairman and Chief Executive Officer 
RER Solutions, Inc. 
950 Herndon Parkway 
Suite 410 
Herndon, VA 20170 
 
Dear Ms. Green: 
 
Our Committees are examining the $500 million contract issued by the Small Business 
Administration (SBA) to process Emergency Injury Disaster Loan (EIDL) applications during 
the coronavirus crisis.  We are concerned by reports that millions of small businesses seeking 
emergency loans have faced long delays, poor service, and processing errors.  As the 
Committees of jurisdiction, it is our duty to ensure that taxpayer money is being spent efficiently, 
effectively, and equitably. 
 
At the onset of the coronavirus crisis, SBA faced an unprecedented number of EIDL 
applications from small businesses impacted by the pandemic.  SBA reportedly “attempted to 
solve the problem by outsourcing much of its loan evaluation work to Rocket Loans” through a 
pre-existing contract with another company, RER Solutions.1  On March 29, 2020, SBA’s Office 
of Disaster Assistance issued an emergency $50 million contract to RER Solutions for “data 
analysis and loan recommendation services for Covid-19.”2  Since then, SBA has expanded the 
award amount to half a billion dollars.3  
 
Your company, RER Solutions, is a minority-owned and women-owned business that 
participates in SBA’s 8(a) program for businesses owned by economically and socially 
disadvantaged individuals.  According to Dun & Bradstreet, RER Solutions has 40 employees.4  
The $500 million contract awarded by SBA is more than 10 times the value of all federal 
contracts the company was awarded in Fiscal Year 2019.  RER Solutions appears to have 
engaged Rocket Loans as a subcontractor on the contract.  Rocket Loans is a subsidiary of Rock 
 
1 Here’s Where the Small Business Administration’s Coronavirus Disaster Loans Are Going, Washington 
Post (June 9, 2020) (online at www.washingtonpost.com/business/2020/06/09/sba-disaster-loans/). 
2 USA Spending, Contract Summary (online at 
www.usaspending.gov/#/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed July 9, 
2020). 
3 Id. 
4 Dun & Bradstreet, Company Profile:  RER Solutions Inc. (online at www.dnb.com/business-
directory/company-profiles.rer_solutions_inc.c3794f63228e308a0255da27b92f865e.html) (accessed July 9, 2020). 

Ms. Errin Green 
Page 2 
 
 
 
Holdings Inc., the parent company for Quicken Loans, one of the nation’s largest mortgage 
lenders with nearly $900 million in income last year.5 
 
Recent reports about the EIDL program raise questions about whether RER Solutions and 
Rocket Loans have provided adequate services to SBA and the millions of small businesses 
seeking EIDL funds.  The EIDL program has reportedly been “hobbled by delays and confusion” 
that have left many applicants waiting for months for funds.6  SBA has reportedly “struggled to 
keep up with a flood of more than 9 million applications, nearly 100 times what it had received 
in previous years.”7  The program has been plagued by average wait times of 41 days to process 
loans, technical glitches that delayed disbursements to many small businesses, a lack of 
communication with applicants, and widespread reports that businesses have not received funds 
SBA claimed were disbursed.8 
 
We are seeking to ensure that taxpayer dollars are being spent in the best interest of the 
American people and not diverted to fraud, waste, or abuse.  To assist with this investigation, 
please produce by August 13, 2020, the following documents and information from January 1, 
2020, to the present:  
 
1. 
All documents relating to the solicitation, award, modification, or performance of 
the contract awarded by SBA to RER Solutions in March 2020 related to EIDL 
loans, including but not limited to: 
 
a. 
all offer information, including proposals, quotes, unsolicited proposals, 
submitted by RER Solutions and/or Rocket Loans to SBA; 
b. 
the contract between SBA and RER Solutions, including the statement of 
work, and all modifications; 
c. 
any documents regarding the eligibility of RER Solutions for certification 
under SBA’s 8(a) business development program;  
d. 
any documents regarding the ability of RER Solutions to perform the 
contract;  
e. 
any documents regarding Rocket Loans’ participation in the contract; and 
f. 
the contract between RER Solutions and Rocket Loans, in addition to all 
documents between any of the three parties leading to the contractual 
 
5 Securities and Exchange Commission, Form S-1, Rocket Companies, Inc. (July 7, 2020) (online at 
www.sec.gov/Archives/edgar/data/1805284/000104746920004008/a2241988zs-1.htm). 
6 Thousands of Small Business Owners Have Not Gotten Disaster Loans the Government Promised Them, 
ProPublica (July 16, 2020) (online at www.propublica.org/article/thousands-of-small-business-owners-have-not-
gotten-disaster-loans-the-government-promised-them); Here’s Where the Small Business Administration’s 
Coronavirus Disaster Loans Are Going, Washington Post (June 9, 2020) (online at 
www.washingtonpost.com/business/2020/06/09/sba-disaster-loans/). 
7 SBA Grant Program Attracting the Wrong Kind of Attention, Washington Post (July 15, 2020) (online at 
www.washingtonpost.com/business/2020/07/15/sba-eidl-loan-program-coronavirus/). 
8 Thousands of Small Business Owners Have Not Gotten Disaster Loans the Government Promised Them, 
ProPublica (July 16, 2020) (online at www.propublica.org/article/thousands-of-small-business-owners-have-not-
gotten-disaster-loans-the-government-promised-them). 

Ms. Errin Green 
Page 3 
relationship, including but not limited to the solicitation and offer between 
RER Solutions and Rocket Loans; and 
2.
All communications regarding the SBA contract and its performance, including
internal communications and communications with SBA, Rocket Loans, Quicken
Loans, Rock Holdings, Inc. or any affiliated company, the White House, other
federal agencies, or third parties; and
3.
A list and description of all other federal loan processing contracts on which RER
Solutions has performed either as a prime contractor or subcontractor.
In addition, please provide written responses to the following questions by August 13, 
2020: 
1.
Describe the contractual relationship between RER Solutions and Rocket Loans,
the amount of work Rocket Loans will perform, and the revenue and profit Rocket
Loans will receive from RER Solutions.
2.
Has RER Solutions partnered with any other entities to perform its contractual
obligations to SBA?  If so, which entities; in what capacity; what is the scope of
work they are supposed to perform; and how much money will each entity receive
for their work?
3.
How did RER Solutions identify Rocket Loans as the right candidate for the SBA
contract?  Did RER Solutions engage with and/or request offers or quotes from
any other companies before partnering with Rocket Loans?
We also request a staff briefing on these issues by August 13, 2020. 
An attachment to this letter provides additional instructions for responding to this request.  
If you have any questions regarding this request, please contact staff for the Select Subcommittee 
on the Coronavirus Crisis at (202) 225-4400.   
Sincerely, 
__________________________ 
__________________________ 
James E. Clyburn 
Nydia M. Velázquez  
Chairman 
Chairwoman 
Select Subcommittee on the  
Committee on Small Business  
Coronavirus Crisis 

Ms. Errin Green 
Page 4 
 
 
 
Enclosure 
 
cc: 
The Honorable Steve Scalise, Ranking Member 
 
Select Subcommittee on the Coronavirus Crisis 
 
 
The Honorable Steve Chabot, Ranking Member 
 
Committee on Small Business  
 
 
 
 
 
 

Responding to Oversight Committee Document Requests 
 
1. 
In complying with this request, produce all responsive documents that are in your 
possession, custody, or control, whether held by you or your past or present agents, 
employees, and representatives acting on your behalf.  Produce all documents that you 
have a legal right to obtain, that you have a right to copy, or to which you have access, as 
well as documents that you have placed in the temporary possession, custody, or control 
of any third party.  
 
2. 
Requested documents, and all documents reasonably related to the requested documents, 
should not be destroyed, altered, removed, transferred, or otherwise made inaccessible to 
the Committee. 
 
3. 
In the event that any entity, organization, or individual denoted in this request is or has 
been known by any name other than that herein denoted, the request shall be read also to 
include that alternative identification. 
 
4. 
The Committee’s preference is to receive documents in electronic form (i.e., CD, 
memory stick, thumb drive, or secure file transfer) in lieu of paper productions. 
 
5. 
Documents produced in electronic format should be organized, identified, and indexed 
electronically. 
 
6. 
Electronic document productions should be prepared according to the following 
standards: 
 
a. 
The production should consist of single page Tagged Image File (“TIF”), files 
accompanied by a Concordance-format load file, an Opticon reference file, and a 
file defining the fields and character lengths of the load file. 
 
b. 
Document numbers in the load file should match document Bates numbers and 
TIF file names. 
 
c. 
If the production is completed through a series of multiple partial productions, 
field names and file order in all load files should match. 
 
d. 
All electronic documents produced to the Committee should include the following 
fields of metadata specific to each document, and no modifications should be 
made to the original metadata: 
 
BEGDOC, ENDDOC, TEXT, BEGATTACH, ENDATTACH, PAGECOUNT, 
CUSTODIAN, RECORDTYPE, DATE, TIME, SENTDATE, SENTTIME, 
BEGINDATE, BEGINTIME, ENDDATE, ENDTIME, AUTHOR, FROM, CC, 
TO, BCC, SUBJECT, TITLE, FILENAME, FILEEXT, FILESIZE, 
DATECREATED, TIMECREATED, DATELASTMOD, TIMELASTMOD, 

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INTMSGID, INTMSGHEADER, NATIVELINK, INTFILPATH, EXCEPTION, 
BEGATTACH. 
 
7. 
Documents produced to the Committee should include an index describing the contents 
of the production.  To the extent more than one CD, hard drive, memory stick, thumb 
drive, zip file, box, or folder is produced, each should contain an index describing its 
contents. 
 
8. 
Documents produced in response to this request shall be produced together with copies of 
file labels, dividers, or identifying markers with which they were associated when the 
request was served. 
 
9. 
When you produce documents, you should identify the paragraph(s) or request(s) in the 
Committee’s letter to which the documents respond. 
 
10. 
The fact that any other person or entity also possesses non-identical or identical copies of 
the same documents shall not be a basis to withhold any information. 
 
11. 
The pendency of or potential for litigation shall not be a basis to withhold any 
information.    
 
12. 
In accordance with 5 U.S.C.§ 552(d), the Freedom of Information Act (FOIA) and any 
statutory exemptions to FOIA shall not be a basis for withholding any information.   
 
13. 
Pursuant to 5 U.S.C. § 552a(b)(9), the Privacy Act shall not be a basis for withholding 
information.   
 
14. 
If compliance with the request cannot be made in full by the specified return date, 
compliance shall be made to the extent possible by that date.  An explanation of why full 
compliance is not possible shall be provided along with any partial production. 
 
15. 
In the event that a document is withheld on the basis of privilege, provide a privilege log 
containing the following information concerning any such document:  (a) every privilege 
asserted; (b) the type of document; (c) the general subject matter; (d) the date, author, 
addressee, and any other recipient(s); (e) the relationship of the author and addressee to 
each other; and (f) the basis for the privilege(s) asserted.   
 
16. 
If any document responsive to this request was, but no longer is, in your possession, 
custody, or control, identify the document (by date, author, subject, and recipients), and 
explain the circumstances under which the document ceased to be in your possession, 
custody, or control. 
 
17. 
If a date or other descriptive detail set forth in this request referring to a document is 
inaccurate, but the actual date or other descriptive detail is known to you or is otherwise 
apparent from the context of the request, produce all documents that would be responsive 
as if the date or other descriptive detail were correct. 

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18. 
This request is continuing in nature and applies to any newly-discovered information.  
Any record, document, compilation of data, or information not produced because it has 
not been located or discovered by the return date shall be produced immediately upon 
subsequent location or discovery. 
 
19. 
All documents shall be Bates-stamped sequentially and produced sequentially. 
 
20. 
Two sets of each production shall be delivered, one set to the Majority Staff and one set 
to the Minority Staff.  When documents are produced to the Committee, production sets 
shall be delivered to the Majority Staff in Room 2157 of the Rayburn House Office 
Building and the Minority Staff in Room 2105 of the Rayburn House Office Building. 
 
21. 
Upon completion of the production, submit a written certification, signed by you or your 
counsel, stating that:  (1) a diligent search has been completed of all documents in your 
possession, custody, or control that reasonably could contain responsive documents; and 
(2) all documents located during the search that are responsive have been produced to the 
Committee. 
 
Definitions 
 
1. 
The term “document” means any written, recorded, or graphic matter of any nature 
whatsoever, regardless of how recorded, and whether original or copy, including, but not 
limited to, the following:  memoranda, reports, expense reports, books, manuals, 
instructions, financial reports, data, working papers, records, notes, letters, notices, 
confirmations, telegrams, receipts, appraisals, pamphlets, magazines, newspapers, 
prospectuses, communications, electronic mail (email), contracts, cables, notations of any 
type of conversation, telephone call, meeting or other inter-office or intra-office 
communication, bulletins, printed matter, computer printouts, teletypes, invoices, 
transcripts, diaries, analyses, returns, summaries, minutes, bills, accounts, estimates, 
projections, comparisons, messages, correspondence, press releases, circulars, financial 
statements, reviews, opinions, offers, studies and investigations, questionnaires and 
surveys, and work sheets (and all drafts, preliminary versions, alterations, modifications, 
revisions, changes, and amendments of any of the foregoing, as well as any attachments 
or appendices thereto), and graphic or oral records or representations of any kind 
(including without limitation, photographs, charts, graphs, microfiche, microfilm, 
videotape, recordings and motion pictures), and electronic, mechanical, and electric 
records or representations of any kind (including, without limitation, tapes, cassettes, 
disks, and recordings) and other written, printed, typed, or other graphic or recorded 
matter of any kind or nature, however produced or reproduced, and whether preserved in 
writing, film, tape, disk, videotape, or otherwise.  A document bearing any notation not a 
part of the original text is to be considered a separate document.  A draft or non-identical 
copy is a separate document within the meaning of this term. 
 
2. 
The term “communication” means each manner or means of disclosure or exchange of 
information, regardless of means utilized, whether oral, electronic, by document or 
otherwise, and whether in a meeting, by telephone, facsimile, mail, releases,  electronic 

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message including email (desktop or mobile device), text message, instant message, 
MMS or SMS message, message application, or otherwise. 
 
3. 
The terms “and” and “or” shall be construed broadly and either conjunctively or 
disjunctively to bring within the scope of this request any information that might 
otherwise be construed to be outside its scope.   The singular includes plural number, and 
vice versa.  The masculine includes the feminine and neutral genders. 
 
4. 
The term “including” shall be construed broadly to mean “including, but not limited to.” 
 
5. 
The term “Company” means the named legal entity as well as any units, firms, 
partnerships, associations, corporations, limited liability companies, trusts, subsidiaries, 
affiliates, divisions, departments,  branches, joint ventures, proprietorships, syndicates, or 
other legal, business or government entities over which the named legal entity exercises 
control or in which the named entity has any ownership whatsoever. 
 
6. 
The term “identify,” when used in a question about individuals, means to provide the 
following information:  (a) the individual’s complete name and title; (b) the 
individual’s business or personal address and phone number; and (c) any and all 
known aliases. 
 
7. 
The term “related to” or “referring or relating to,” with respect to any given subject, 
means anything that constitutes, contains, embodies, reflects, identifies, states, refers to, 
deals with, or is pertinent to that subject in any manner whatsoever. 
 
8. 
The term “employee” means any past or present agent, borrowed employee, casual 
employee, consultant, contractor, de facto employee, detailee, fellow, independent 
contractor, intern, joint adventurer, loaned employee, officer, part-time employee, 
permanent employee, provisional employee, special government employee, 
subcontractor, or any other type of service provider. 
 
9. 
The term “individual” means all natural persons and all persons or entities acting on 
their behalf.

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