Idle on EIDL Fraud: Staff Report — Select Subcommittee on the Coronavirus Crisis (June 2022)

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S E L E C T  S U B C O M M I T T E E  O N  T H E  C O R O N A V I R U S  C R I S I S
HOW THE TRUMP ADMINISTRATION
WASTED TAXPAYER DOLLARS BY
LEAVING THE COVID-19 EIDL
PROGRAM VULNERABLE TO FRAUD  
IDLE ON EIDL FRAUD:
STAFF REPORT
JUNE 2022

A.   
B.
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UNDER THE TRUMP ADMINISTRATION,
SBA FAILED TO IMPLEMENT BASIC
FRAUD CONTROLS, LEADING TO THE
DISTRIBUTION OF TENS OF BILLIONS OF
DOLLARS IN POTENTIALLY FRAUDULENT
COVID-19 EIDL LOANS AND GRANTS
THE TRUMP ADMINISTRATION AWARDED
A $750 MILLION EIDL PROCESSING
CONTRACT TO A SMALL COMPANY THAT
RELIED ON A SUBCONTRACTOR FOR
NEARLY ALL THE WORK REQUIRED YET
STILL ACCRUED WINDFALL PROFITS AT
TAXPAYERS’ EXPENSE
BACKGROUND
II
FINDINGS
RECOMMENDATIONS
IV
A.
B.
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III
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THE PRE-PANDEMIC EIDL PROGRAM
THE COVID-19 EIDL PROGRAM
22
EXECUTIVE SUMMARY
1
I
S E L E C T  S U B C O M M I T T E E  O N  T H E  C O R O N A V I R U S  C R I S I S

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I. 
EXECUTIVE SUMMARY 
 
This staff report presents findings from an investigation conducted by the Select 
Subcommittee on the Coronavirus Crisis into the Small Business Administration (SBA) 
Economic Injury Disaster Loan (EIDL) program’s operation during the pandemic.  The Select 
Subcommittee initiated this investigation following reports that raised concerns that the Trump 
Administration failed to prevent billions of dollars in potential fraud by approving EIDL loans 
and grants with significant fraud indicators.  The investigation also commenced in light of 
reports that SBA had awarded a costly $750 million no-bid contract to aid in implementing the 
program.1  While the EIDL program delivered vital relief to millions of eligible small businesses, 
$86 billion dollars in EIDL funds were disbursed to applicants with fraud alerts on their 
applications.2 
 
The Select Subcommittee’s investigation has uncovered new evidence that, under the 
Trump Administration, SBA failed to implement basic safeguards to prevent fraud, even 
directing loan reviewers to approve applications with serious fraud alerts without taking steps to 
ensure that the applications were legitimate.  Subsequent Department of Justice (DOJ) 
prosecutions, moreover, have overwhelmingly involved EIDL applications that were submitted 
during the period when the Trump Administration failed to implement basic fraud controls, 
suggesting that this failure facilitated a large share of the fraud committed against the program.  
Further, the Trump Administration’s failure to adequately assess reasonable labor costs required 
for its EIDL processing contract also led it to waste hundreds of millions of taxpayer dollars with 
more than $340 million of taxpayer funds paid to a company that assigned only six employees to 
work on the project.     
 
Specifically, the Select Subcommittee’s investigation found: 
 
The Trump Administration Failed to Implement Basic Fraud Controls, Leading to Billions 
of Dollars in Potentially Fraudulent Loans and Grants. 
 
 
New documents obtained by the Select Subcommittee show that SBA under the 
Trump Administration directed a subcontractor to create a “batch” approval 
function that allowed SBA employees to approve COVID-19 EIDL applications 
without any review.  These documents show that SBA specifically asked its contractor to 
create this batch approval function.  The Select Subcommittee has learned that SBA loan 
reviewers did not even have the ability to open EIDL application files included in batches, 
meaning as many as 1.6 million of the 3.9 million loan applications that were ultimately 
approved may have been approved with no actual review by an SBA employee.  SBA’s 
directives further indicate that some applications were included in these batches for 
approval without review despite the presence of fraud indicators identified by the 
automated processing system run by SBA’s subcontractor.   
  
 
The Select Subcommittee uncovered documents showing that, under the Trump 
Administration, even when EIDL applications were reviewed by SBA employees, the 
reviewers were directed to approve applications containing indications of identity 
theft without taking action to ensure the applications were legitimate.  The Reference 

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Guide distributed to SBA loan officers instructed them to simply approve COVID-19 EIDL 
applications with indicators of fraud associated with identity theft, including where the 
applicant’s online identity verification had failed and where the applicant’s information 
couldn’t be validated—in some cases where there was an indication the applicant may be 
deceased—without conducting additional diligence.  Early in the Biden Administration, 
SBA changed this guidance to direct loan reviewers to both obtain government 
identification and ask for personal identifying information by the phone where there were 
indications of identity theft. 
   
 
A Select Subcommittee analysis has found that the vast majority of DOJ prosecutions 
of COVID-19 EIDL fraud have involved fraudulent applications submitted during 
the Trump Administration, particularly between March and August of 2020.  This 
analysis found that 98 percent of DOJ prosecutions of EIDL fraud through May 2022 
involve fraudulent applications submitted during the Trump Administration, even as SBA 
has continued to disburse tens of billions of dollars in EIDL funds.  This disparity is likely 
a result of the Biden Administration’s implementation of stronger fraud safeguards, 
including requiring that loan reviewers address all fraud alerts before approval, verify tax 
information with tax transcripts, and use the Department of the Treasury (Treasury) Do 
Not Pay List to identify ineligible applicants.   
 
The Trump Administration Awarded a $750 Million EIDL Processing Contract to a 
Company that Relied on a Subcontractor for Nearly All the Work Required Yet Still 
Accrued Windfall Profits at Taxpayers’ Expense.  
 
 
The Trump Administration awarded its pre-pandemic EIDL contract to a small 
business—RER Solutions Inc. (RER)—which did not have the capacity to 
immediately scale up loan recommendation services in a catastrophic situation.  Prior 
to the pandemic, SBA determined that it was appropriate to award its approximately $10 
million annual EIDL processing and loan recommendation contract as a small business set 
aside to RER, even though there were clear indications that RER would need to rely on its 
large firm partner Rocket Loans (Rocket)—which, unlike RER, had significant experience 
with relevant lending technology and services—for core contract services.  This was 
particularly concerning because SBA foresaw the possibility that its EIDL loan 
recommendation contractor could be required to quickly scale up its services a hundredfold 
in the event of a catastrophic disaster.  In light of regulations requiring that 50 percent of 
revenue from small business set aside contracts remain with the prime small business 
contractor, this decision also created the risk that in an emergency the contract would be 
greatly expanded and result in an unjustified windfall for RER at taxpayers’ expense.  At 
the onset of the pandemic, with demand for millions of EIDL loans and grants, RER’s 
existing system run by subcontractor Rocket was not capable of handling the type and 
volume of EIDL applications.  RER had to further subcontract with Rocket-affiliated 
technology firm Rapid Financial Services LLC (Rapid) to build a system capable of 
handling the surge in EIDL applications, and Rapid ultimately provided the large majority 
of the labor and key inputs necessary to fulfill the COVID-19 EIDL contract.   
   

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 
The Trump Administration awarded the $750 million COVID-19 EIDL loan 
recommendation contract—the largest individual contract across the entire federal 
government to respond to the pandemic’s economic impact—to RER without a 
competitive process or an adequate assessment of the reasonable cost of the services 
provided.  SBA did not use a competitive process for this award and instead modified 
RER’s much smaller pre-pandemic contract.  Contractor RER, through subcontractor 
Rapid, primarily provided automated services that required relatively little labor, and which 
reviewed COVID-19 EIDL application information in less than a second to provide fraud 
alerts, credit checks, and approval or denial recommendations.  Despite this, SBA agreed 
to pay RER more than $40 per EIDL application reviewed without assessing whether this 
price was reasonable in light of the actual costs the contractor would incur.  
 
 
Illustrating the Trump Administration SBA’s failure to ensure the contract was 
reasonably priced, RER ultimately netted more than $340 million for the work of just 
six employees.  RER subcontractor Rapid provided most of the labor and technology 
needed to fulfill the contract, employing 163 employees and contractors who contributed 
to the company’s work for SBA and providing proprietary software; Rapid received $148 
million, just 20 percent of the contract’s proceeds.  By contrast, RER subcontractor Rocket 
(a Rapid affiliate) received $233 million for just 20 employees it contributed to the 
COVID-19 EIDL contract work.  Most egregiously, prime contractor RER, which told the 
Select Subcommittee that it assigned only six employees to work on the contract and 
primarily engaged in “contractual administrative duties,” pocketed $340 million.  SBA’s 
failure to adequately assess the reasonable cost of the contract, including by considering 
reasonable labor and other real costs, cost taxpayers hundreds of millions of dollars and 
resulted in a windfall for two private companies who contributed relatively little to the 
contract’s performance.  
 
II. 
BACKGROUND 
 
A. 
The Pre-Pandemic EIDL Program  
 
SBA’s Economic Injury Disaster Loan program predated the pandemic.  Under the EIDL 
program, SBA makes loans available to homeowners and small businesses for economic injuries 
caused by disasters—typically localized disasters like hurricanes, tornadoes, and earthquakes—
in areas subject to certain disaster and emergency declarations.3  SBA’s Office of Disaster 
Assistance (ODA) administers the EIDL program and processed an average of 65,000 EIDL 
applications annually before the pandemic.4 
 
1. 
SBA’s 2018 Contract for EIDL Application Processing and Recommendations 
 
In 2018, SBA solicited contractors to analyze EIDL applications and to quickly provide 
SBA with recommendations to approve or decline the applications, with the agency retaining the 
final decision on an application’s approval or denial.5  Although SBA’s solicitation noted that the 
volume of EIDL applications had recently averaged 65,000 annually, a rate of slightly more than 
5,000 per month, SBA made clear that it foresaw the possibility that a catastrophic event could 
dramatically increase the volume of loan recommendations required to one million applications 

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in 60 days, a rate of 500,000 per month.6  In response to a question from a potential bidder about 
this capacity requirement, SBA reiterated that it required contractors be able to scale up their 
analysis and recommendation capacity to allow SBA to “make a million decisions in a short 
period,” and that this would require the contractor recommend decisions to approve or deny loan 
applications at a rate of “12 loans per minute.”7  
 
Although SBA understood that a major catastrophe could require the EIDL program to 
quickly surge its processing capacity a hundredfold to aid in making a million loan decisions “in 
a short period,” SBA solicited its loan recommendation services contract as a small business set 
aside.8  SBA told the Select Subcommittee that the contract was solicited as a small business set 
aside in accordance with the federal acquisition regulations “Rule of Two,” which requires that 
agencies set contracts aside for small businesses when there is a “reasonable expectation” that 
two or more small businesses are likely to offer the solicited services “competitive in terms of 
fair market prices, quality, and delivery.”9  SBA ultimately awarded the contract to RER, which 
qualified as a small business at that time.10  The 2018 SBA contract with RER had a ceiling of 
$10 million for the first year and $100 million over a four year period.11  Despite its 
determination that this contract was appropriate to set aside for a small business contractor, SBA 
also found that the ultimate small business contractor would need to engage a large firm as a 
subcontractor to meet contract requirements.12 
 
2. 
RER, Rocket Loans, and Rapid Financial Services 
 
  To meet SBA’s requirement that a large firm partner with the small business that 
obtained the contract, RER partnered with Rocket, a larger company with experience in 
supporting personal lending (and subsidiary of Rocket Companies, Inc., which has billions of 
dollars in annual revenue).13   
 
Before receiving its EIDL contract, RER’s previous federal contracts were to provide 
professional services support for federal agencies.  For example, RER contracted with the 
Department of Energy for about $1 million per year to provide “general and business 
management support services.”14  RER had some experience assisting agencies in making 
lending decisions on a much smaller scale than required by the EIDL program, including, for 
example, a $165,000 contract with the Department of Housing and Urban Development to 
support underwriting 2,460 loans.15   
 
Rocket Loans, by contrast, is a subsidiary of Rocket Companies, which is a financial 
technology and financial services company that supports various types of personal lending, 
including mortgages, home, and auto loans.16  Rocket Companies had more than $5 billion in 
revenue in 2019.17  Rocket ultimately provided the software needed to make loan 
recommendations to SBA for the pre-pandemic EIDL contract.18  Rocket has an affiliate (which 
is not a subsidiary), Rapid, that did not contribute the pre-pandemic EIDL processing contract 
and was brought in later to support EIDL processing during the pandemic.  Rapid is a financial 
technology company that specializes in underwriting loans to small businesses using an 
automated platform that employs data and algorithms to assess risk, identify potential fraud, and 
make lending recommendations.19  Before working on EIDL during the pandemic, Rapid had 
experience serving 35,000 small businesses related to $2.2 billion in private financing.20  

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B. 
The COVID-19 EIDL Program 
 
1. 
With the Onset of the Pandemic, Congress Expanded the EIDL Program and SBA 
Received an Unprecedented Number of EIDL Applications. 
 
The Coronavirus Preparedness and Response Supplemental Appropriations Act, 
Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Paycheck Protection 
Program and Healthcare Enhancement Act, the December Consolidated Appropriations Act, 
2021, and the American Rescue Plan directed the SBA to provide EIDLs and EIDL advance 
grants to small businesses harmed by the pandemic, which SBA refers to as its “COVID-19 
EIDL” program.21  By March 21, 2020, SBA declared all states, the District of Columbia, and all 
territories to be disaster areas, making small businesses everywhere in the country eligible for 
loans through the COVID-19 EIDL program for the economic injuries suffered as a result of the 
pandemic; demand for EIDLs from affected businesses was extraordinarily high.22  Following 
passage of the CARES Act on March 27, 2020, small businesses were also eligible for COVID-
19 EIDL advance grants that did not need to be repaid.23  Funds for COVID-19 EIDL grants 
were subsequently replenished in the American Rescue Plan and other pandemic relief 
legislation.24 
 
The coronavirus crisis led to an unprecedented volume of EIDL applications, with SBA 
receiving 4.5 million applications between March 31, 2020, and April 10, 2020, and nearly 18 
million applications by July 2021.25  COVID-19 EIDL loans were limited to a $150,000 
maximum loan amount (with some periods where the maximum amounts were adjusted to 
$500,000), and EIDL advance grants (and later targeted and supplemental targeted grants) of up 
to $10,000 were also available for affected small businesses.  As of April 2022, SBA had 
approved more than 3.9 million COVID-19 EIDL applications and a total of over $378 billion in 
EIDLs for American businesses.26  5.8 million EIDL advance grants and 1 million targeted and 
supplemental targeted EIDL advance grants totaling $27.5 billion were also disbursed.27 
 
2. 
SBA Dramatically Expanded RER’s Contract in a Non-Competitive Process. 
 
In late March 2020, SBA engaged with RER and Rocket, as well as Rocket’s affiliate 
Rapid, to create new system for providing loan recommendations and analysis for COVID-19 
EIDL applications.28  SBA’s existing portal could not handle the volume of EIDL applications, 
and Rocket’s existing loan processing system, which more commonly handled EIDLs for home 
property damage, was not able to handle the volume and type of applications being submitted in 
the COVID-19 EIDL program.29  SBA rushed to create a new system that would send EIDL 
application data to Rapid, and where Rapid would provide SBA with recommendations to 
approve, manually review, or decline EIDL applications.30  In April 2020, SBA modified its 
contract with RER to incorporate the COVID-19 EIDL program without a competitive process, 
increasing RER’s total contract ceiling from $100 million to $600 million (and later that year to 
$750 million).31  In justifying this modification SBA asserted that the pandemic presented 
“exceptional circumstances” given the millions of applications received, and the modification 
was ultimately approved by then-SBA Administrator Jovita Carranza.32  The modified contract 
with RER was the largest contract awarded by the federal government in service of the response 
to the pandemic’s economic impacts.33 

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3. 
SBA COVID-19 EIDL Application Vetting and Approval Process  
 
SBA implemented a process where RER subcontractor Rapid would process EIDL 
applications through an automated system which would generate a recommendation to SBA loan 
officers on whether to approve, decline, or manually review the COVID-19 EIDL application.  
Rapid’s system included automated fraud checks that generated alerts when there were 
indications that an EIDL application might be fraudulent.34  Adapting its existing business loan 
system, Rapid created the portal where SBA loan officers and Team Leads could review Rapid’s 
recommendation to approve a loan, manually review its fraud flags, or decline the loan, and 
where SBA Team Leads could ultimately obligate funds.35  Rapid’s system employed automated 
fraud checks that included running COVID-19 EIDL application information through third party 
data services including Lexis and Iovation Identity Verification, the Lynx Fraud Indicator, 
DecisionLogic bank information verification, Experian, and other email, phone, and bank 
account verification services.36  These automated fraud check systems would lead to alerts when 
“Fraud Check Indicators” were present in an EIDL application, which were flagged for SBA 
loan reviewers as “fraud alerts.”37   
 
 
 
When fraud alerts were generated by Rapid’s system, the application was generally—
though not always—sent to an SBA loan officer to review the fraud alerts or other flags and 
subsequently sent to an SBA Team Lead for final approval or declination.38  When no fraud 
indicators were generated, Rapid’s system would send the application directly to an SBA Team 
Lead with a recommendation for approval.39  Rapid’s system also allowed loan officers and 
Team Leads to access information about loan applicants, fraud alerts, or other information 
deficiencies on their applications, to change loan totals, to access contact information for 
applicants, and to eventually approve or deny EIDL applications.40   

7 
 
 
 
 
Although Rapid’s system ran automated fraud checks and provided the portal used by 
SBA loan officers and Team Leads, Rocket continued to provide services for funding and 
disbursing loans after they were approved through SBA’s Etran payments system.41  Documents 
and information obtained by the Select Subcommittee show that RER’s very small staff assigned 
to work on this contract largely performed “contractual administrative duties” like negotiating 
with SBA and sending the agency invoices and data concerning the number of applications 
processed, and high level “project management.”42   
 
 
SBA greatly expanded its workforce of loan officers and other staff reviewing EIDL 
applications after they were processed by Rapid’s system.  In total, SBA expanded its relevant 
staff more than five-fold to over 8,000 loan officers, Team Leads, and support staff.43  These 
loan officers and other staff generally reviewed EIDL application information, including fraud 
alerts, after the applications were recommended to approval, denial, or manual review by Rapid’s 
system.44  The cost of paying this staff to review EIDL applications was not included in the $750 
million contract with RER, and was an additional expense incurred by SBA.45   
 
4. 
Reports of Fraud Vulnerabilities 
 
Reports and testimony of government watchdogs, including SBA OIG and the 
Government Accountability Office (GAO), raised serious concerns about the Trump 
Administration SBA’s failure to implement basic safeguards to prevent widespread fraud during 
the early operation of the COVID-19 EIDL program.46  An independent watchdog report also 
alleged that SBA loan officers did not receive basic guidance on fraud prevention until after SBA 
OIG reported that there was significant fraud in the COVID-19 EIDL program and that SBA 
failed to provide adequate training to loan officers.  This reportedly led loan officers to override 
fraud alerts and approve potentially fraudulent EIDL applications.47 

8 
 
5. 
The Select Subcommittee’s Investigation 
  
The Select Subcommittee first initiated an investigation of the COVID-19 EIDL program, 
and of the Trump Administration’s decision to award such a significant contract supporting the 
program without a competitive process, in July 2020.48  Following reports of extensive fraud 
vulnerabilities in the COVID-19 EIDL program, the Select Subcommittee expanded its 
investigation in early 2021 to include COVID-19 EIDL fraud risks.49  The Select Subcommittee 
has requested and received documents and information from SBA, RER, Rocket, and Rapid.50  In 
total, the Select Subcommittee has received and reviewed 17,000 pages of documents responsive 
to these requests.  The Select Subcommittee has also held two briefings with RER and Rapid, 
four briefings with SBA regarding the operation of the COVID-19 EIDL program, and a hearing 
on fraud in SBA programs that included the SBA Inspector General’s testimony on EIDL 
fraud.51  
 
III. 
FINDINGS 
 
The Select Subcommittee’s investigation has found that, under the Trump 
Administration, SBA failed to safeguard taxpayer dollars in the COVID-19 EIDL program.  
First, early in the Trump Administration’s implementation of the program, SBA failed to 
implement even the most basic safeguards to prevent fraud, including by directing loan officers 
to approve applications with serious fraud indicators without appropriate investigation.  Second, 
SBA failed to rigorously assess the appropriate price of its contract for automated EIDL loan 
recommendation and processing services when modifying its existing contract in a 
noncompetitive process, leading to windfalls for RER and Rocket that cost taxpayers hundreds of 
millions of dollars.  
 
A. 
Under the Trump Administration, SBA Failed to Implement Basic Fraud 
Controls, Leading to the Distribution of Tens of Billions of Dollars in 
Potentially Fraudulent COVID-19 EIDL Loans and Grants. 
 
SBA contracted with RER and its subcontractor Rapid to provide automated checks for 
indications of fraud in EIDL applications, but SBA retained the role and responsibility of 
approving EIDL loans and advance grants.  After receiving data from Rapid’s automated review 
of EIDL applications, including alerts that fraud indicators were present, SBA loan officers and 
Team Leads were responsible for reviewing EIDL applications, ensuring that the applications 
were not fraudulent, and ultimately approving the loans.52  Under the Trump Administration, 
though, SBA took several steps that significantly increased the vulnerability of the EIDL 
program to fraud, including by (i) directing Rapid to create a “batch” approval mechanism that 
prevented the designated SBA employee from reviewing applications before approval, (ii) 
directing loan officers to approve applications flagged as potentially involving identity theft 
without further identity verification, and (iii) directing that Rapid not flag applications containing 
some fraud indicators as requiring additional review by loan officers.  The Trump 
Administration’s decision to remove basic safeguards contributed to the distribution of tens of 
billions of dollars in potentially fraudulent loans and grants.  
 

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1. 
The COVID-19 EIDL Program Was Vulnerable to Widespread Fraud. 
 
As the Select Subcommittee has previously reported, the COVID-19 EIDL program 
under the Trump Administration was vulnerable to widespread fraud.  SBA OIG found that the 
Trump Administration disbursed $86 billion in EIDL loans and advances in response to 
potentially fraudulent applications that contained fraud indicators including duplicate IP 
addresses, email addresses, physical addresses, bank accounts, bank account information with 
discrepancies, links to identity theft, and Employer Identification Numbers (EINs) registered 
after the early 2020 cutoff date.53  SBA Inspector General Hannibal “Mike” Ware testified to the 
Select Subcommittee in March 2021 that EIDL fraud risk “wasn’t taken as seriously” as fraud 
risk in other programs operated by the Trump Administration, and that OIG “notified SBA up 
front” as the EIDL program rolled out that “we have to strengthen our controls.”54 
 
Although the precise extent of fraud in the COVID-19 EIDL program is not yet known, 
numerous indicators suggest that it was extensive.  GAO found that financial institutions filed 
more than 20,000 suspicious activity reports (SARs) related to COVID-19 EIDL transactions.55  
SBA also disbursed more than 112,000 COVID-19 EIDL loans and 98,000 advance grants that it 
later referred to SBA OIG as being related to an identity theft complaint. As of January 2021, 
SBA estimated that it had received over 150,000 returned loan statements related to incorrect or 
fraudulent addresses, indicating that COVID-19 EIDL identity theft fraud may have been even 
more extensive.56  SBA OIG also found that, in 2020, SBA distributed approximately $4.5 
billion in $10,000 EIDL advance grants to sole proprietors and independent contractors that they 
were categorically ineligible for given the $1,000 per employee advance grant limit.57  These 
findings taken together show that the Trump Administration likely permitted the COVID-19 
EIDL program to disburse billions of taxpayer dollars in response to fraudulent applications.  
 
2. 
During the Trump Administration, SBA Created a “Batch” Approval Mechanism 
That Facilitated Approval of EIDL Loans with No Review by Loan Officers. 
 
New evidence uncovered by the Select Subcommittee shows that SBA under the Trump 
Administration implemented a design that left the COVID-19 EIDL program vulnerable to fraud, 
as many applications received no review at all from SBA loan officers or Team Leads.  GAO and 
SBA OIG have previously criticized SBA’s use of “batch” approval of EIDL applications, 
whereby SBA Team Leads could approve dozens of loan applications at once “with little to no 
vetting of the loan information” or “with little to no additional review by the team leaders.”58  
New evidence obtained by the Select Subcommittee now shows both that SBA specifically 
requested that its contractor add this “batch” approval function allowing mass approval of loan 
applications without review, and that the system prevented any review whatsoever of EIDL 
applications that were included in “batches.”59 
 
SBA’s decision to employ a “batch” approval mechanism required its subcontractor 
Rapid to add a function that was not part of its initial planning or existing system, which 
envisioned a “detailed review” of COVID-19 EIDL applications “one at time.”60  SBA requested 
that Rapid add functionality that would allow SBA loan officers to approve batches of as many 
as 500 applications at a time (ultimately, batches included 25 to 50 applications), which would 
be the “only inherently governmental check” before funds were obligated and disbursed.61   
 

10 
 
 
 
 
These batches of EIDL applications were sent directly to SBA Team Leads and 
recommended for approval without any initial review by other SBA loan officers.62  SBA OIG 
has pointed out that this batch approval process abandoned SBA’s traditional “Rule of Two” 
control, which had previously required that two SBA employees review and approve a loan 
application, by only requiring loan approval by a single SBA employee.63   
 

11 
 
In practice, applications in batches received no review at all from any SBA employee.  
SBA’s Processing and Disbursement Center Director told the Select Subcommittee that the EIDL 
application processing system did not even allow SBA Team Leads to open individual EIDL 
application files in batches recommended for approval64—making approval without review 
essentially automatic without any human laying eyes on application details.  Data from Rapid 
obtained by the Select Subcommittee shows that as many as 1.6 million EIDL applications may 
have been included in “batches” recommended for approval and received no actual review by an 
SBA employee in the COVID-19 EIDL program’s early months.65  Nearly all of these 
applications were ultimately approved, even as less than 50 percent of those applications 
recommended for manual review were approved in the same period.66   
 
Additionally, there are strong indications that some EIDL applications included for 
“batch” approval without review contained fraud alerts.  SBA provided Rapid with instructions 
that it should include applications in batches even when they contained as many as two 
indicators of potential fraud.67  These applications, including those with fraud flags, would then 
be approved in batches without any further substantive review.  This was evidently because SBA 
determined that certain fraud indicators—including emails that failed to pass validation, phone 
numbers that weren’t associated with the relevant business or owner, international locations, and 
businesses whose registration could not be confirmed—were less concerning and directed that 
such applications be included in batch files for nearly automatic approval.68  SBA staff told the 
Select Subcommittee that these fraud indicators were at the lower end of the hierarchy, and that 
they did not present an issue.69  
 
 
Given the unprecedented demand for EIDL loans and grants at the onset of the pandemic, 
SBA’s decision to employ automated fraud checks for efficiency and speed could be defensible.  
However, SBA’s judgment to not only have EIDL applications in batches approved without any 
actual review by an SBA employee, but to also include applications in those unreviewed batches 
that contained fraud indicators, significantly and unjustifiably increased the program’s 
vulnerability to fraud. 

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3. 
Even When EIDL Applications Were Manually Reviewed, the Trump 
Administration SBA Directed Loan Officers to Approve Loans with Serious 
Fraud Indicators. 
 
When Rapid’s automated system found that EIDL applications included what SBA had 
determined were serious fraud indicators, the applications were sent to SBA loan reviewers for 
manual review before they could be recommended to an SBA Team Lead for ultimate 
approval.70  Applications subject to manual review included those where the business owner 
information could not be validated, where there was suspected digital identity fraud or suspicious 
online behavior, and where there were indications that bank account information was incorrect or 
did not match the applicant.71  Documents uncovered by the Select Subcommittee show, 
however, that during the Trump Administration, SBA specifically directed loan reviewers to 
approve applications with the most serious fraud alerts—including those related to identity 
theft—without any attempt to ensure the applications were legitimate.   
 
SBA staff told the Select Subcommittee that it found identity theft to be a particularly 
significant source of EIDL fraud.72  This assessment is in accord with the SBA OIG finding that 
SBA disbursed EIDL loans and advance grants in over 200,000 cases in response to applications 
associated with identity theft complaints.73  Yet, despite the assessment that identity theft was a 
significant source of fraud, SBA issued guidance to loan reviewers that directed them to approve 
EIDL applications with critical fraud indicators without taking action to ensure the applications 
were not the result of identity theft.  Specifically, SBA’s Guide for loan officers directed them to 
simply “Approve” applications that “failed online identity verification,” and directed loan 
reviewers to “Approve” applications where the “Owner/Client information failed validation (info 
doesn’t go together, person is listed as deceased, etc.)” without taking action to address the fraud 
flag.74   
 
 
 
SBA eventually changed these directives to require the loan reviewer to request a form of 
government identification when these indicators of identity theft were present.75  By the time 
SBA made this modest improvement, however, more than 1.3 million EIDL applications totaling 

13 
 
over $90 billion had been approved.76  Early in the Biden Administration, SBA included more 
detailed instructions that also directed the loan reviewer to call the applicant and further confirm 
their identity by asking for personally identifying information.77  The diligence SBA later 
required its loan officers to conduct, largely following reports of extensive vulnerabilities in the 
program, further demonstrates that earlier directives during the Trump Administration created 
intolerable fraud risks.   
 
 
4. 
Inadequate Training and High “Production Goals” Requiring Quick Review of 
Applications Also Likely Increased COVID-19 EIDL Fraud Vulnerabilities. 
 
Other aspects of the Trump Administration SBA’s early implementation of the COVID-19 
EIDL program likely increased fraud risk. Reports indicate that, in addition to being given 
directives to approve EIDL applications containing certain fraud indicators, that loan officers—
many of whom were just hired as SBA dramatically increased its processing staff—were given 
inadequate training on fraud prevention, particularly before SBA OIG released a critical public 
report of COVID-19 EIDL fraud vulnerabilities.78  This comports with a report the Select 
Subcommittee received from an SBA contract loan reviewer that trainings were low quality even 
as those hired often had little or no experience reviewing loan applications, and that fraud was 
rarely, if ever, mentioned in hours-long training sessions early in the program’s operation.  This 
lack of training regarding how to address indicators of fraud likely increased fraud vulnerability 
even for applications containing fraud alerts that SBA’s guidance directed reviewers to take action 
to address. 
 
Further, loan officers were given aggressive target goal rates that did not allow sufficient 
time to fully review applications and ensure applications were not fraudulent.  In October 2020, 
SBA OIG reported that loan officers were told to meet a “production goal” of reviewing and 
approving or denying four applications per hour, giving them only an average of 15 minutes to 
review and resolve issues in a COVID-19 EIDL application.  This led to “cursory reviews” that 
were less likely to detect fraudulent applications.79  SBA OIG’s report comports with information 

14 
 
the Select Subcommittee received from an SBA contract loan reviewer, who indicated that loan 
reviewers felt pressure to meet these “production goals,” which the loan reviewer referred to as 
“quotas,” at the expense of detecting fraudulent applications.  Given these high goal rates for 
review, even as SBA slowly improved its directives to loan reviewers regarding fraud alerts, the 
loan officers’ limited time to actually address indications of potential fraud likely contributed to 
the continued approval of fraudulent applications.    
  
5. 
The Select Subcommittee’s Analysis of DOJ Prosecutions of EIDL Fraud Indicates 
That the Majority of Fraud Was Committed During the Trump Administration’s 
Early Implementation of the COVID-19 EIDL Program. 
 
The Select Subcommittee conducted an analysis of all DOJ prosecutions of EIDL fraud 
thus far to shed light on the primary methods used to commit fraud against the program by 
examining cases where investigators gained sufficient information to bring criminal charges.  To 
date, DOJ has pursued 117 prosecutions of 177 defendants for COVID-19 EIDL fraud, involving 
at least $45 million in fraudulently obtained EIDL funds.80  The Select Subcommittee’s analysis 
of these prosecutions has revealed that the vast majority of confirmed EIDL fraud cases—nearly 
95 percent—involved applications submitted between late March and August 2020.81  Even as 
the Biden Administration continued to approve a significant number of EIDL loans, advance 
grants, and loan increases—totaling over $179 billion since February 2021—98 percent of EIDL 
fraud prosecutions to date have involved fraudulent applications submitted during the Trump 
Administration’s operation of the program.82   
 
The Select Subcommittee’s finding that the overwhelming share of DOJ prosecutions of 
COVID-19 EIDL fraud involve fraudulent applications submitted during the Trump 
Administration’s early implementation of the program is consistent with the evidence that the 
Trump Administration failed to employ even basic safeguards against fraud.83  This finding is 
also consistent with indications that, in early 2021, the Biden Administration began 
strengthening the program’s fraud controls by requiring that fraud indicators be addressed by 
loan officers (including with, as shown above, detailed directions to loan officers on actions that 
must be taken when identity theft indicators are present), validating applications against 
Department of the Treasury’s (Treasury’s) Do Not Pay List, obtaining Internal Revenue Service 
tax transcripts to verify EIDL applicant information, and checking Employer Identification 
Numbers (EINs).84 
 
 
The methods many applicants used to commit EIDL fraud further confirm that the 
indicators of potential fraud used by SBA OIG to identify billions of dollars in potential fraud 
were present in many cases of confirmed fraud, and the fraud controls added by the Biden 
Administration would likely have prevented payment in many such cases had they been 
implemented by the Trump Administration:  
 
 
51 percent of these prosecutions involved fictitious, inactive, or inoperative 
businesses, many of which lacked business registrations entirely, were shell 
companies registered after the pandemic began, or were publicly registered as 
“inactive.”85  The Biden Administration’s implementation of taxpayer EIN 
searches, requirement that fraud alerts be adequately addressed by loan reviewers, 

15 
 
and review of tax transcripts have likely made it much more difficult for fictitious 
and inactive businesses to obtain fraudulent EIDLs.   
 
 
22 percent of the prosecutions involved applicants that used stolen identities to 
submit fraudulent applications, and in some of these cases applicants used stolen 
identities in conjunction with fictitious business entities.86  SBA’s EIDL processing 
system generates fraud alerts that can prevent payment in many of these cases when 
loan reviewers are required to address those alerts before EIDL approval, as the 
Biden Administration now requires.   
 
 
10 percent of the prosecutions involved fraud rings where a central group of 
conspirators solicited personal information from many other individuals in order to 
submit dozens or hundreds of fraudulent applications.87  These cases show that 
large numbers of fraudulent applications often originated from a handful of IP 
addresses, generating a fraud indicator that loan reviewers could address to prevent 
fraudulent payments.88  While Trump Administration guidance merely directed 
loan officers to “review the file” to determine if a “packager” was involved before 
approving loans flagged from a high risk IP address, Biden Administration 
guidance required loan officers to contact applicants when this fraud indicator is 
present and directs them to contact SBA’s Fraud Review Team if fraud or identity 
theft is suspected.89 
  
B. 
The Trump Administration Awarded a $750 Million EIDL Processing 
Contract to a Small Company that Relied on a Subcontractor for Nearly All 
the Work Required Yet Still Accrued Windfall Profits at Taxpayers’ Expense. 
 
Information obtained by the Select Subcommittee demonstrates that the Trump 
Administration’s failure to rigorously assess the costs required to fulfill its automated EIDL 
processing and recommendation contract led the agency waste hundreds of millions of taxpayer 
dollars.  RER received over $340 million for the work of just six employees for one year, while 
its subcontractor Rocket received $233 million for the work of just 20 employees in that time.  
Rapid, another subcontractor, provided the vast majority of the labor needed, created the 
proprietary automated system used, and paid third party data fees—essentially bearing all the 
core costs required by the contract—but received only 20 percent of the funds paid by SBA.  
This waste was partly caused by SBA’s decision to award its pre-pandemic EIDL contract to a 
small business that lacked the ability to surge its loan processing capacity without delegating the 
vast majority of the work to a large firm subcontractor, even as SBA foresaw the possibility that 
the EIDL program could face a dramatic surge in demand for relief.  Given regulations requiring 
that prime small business contractors retain 50 percent of a contract’s revenue, the emergency 
modification to RER’s contract for the COVID-19 EIDL program resulted in the company 
receiving half the contract’s value while doing little of the work.  Ultimately, SBA failed to 
ensure taxpayers paid a reasonable price for the largest single contract awarded by the federal 
government to aid in the response to the pandemic’s economic impacts. 
 

16 
 
1. 
The Trump Administration’s 2018 Decision to Award Its Pre-Pandemic EIDL 
Processing Contract to Small Contractor RER Left SBA Unprepared for the 
Pandemic’s Surge in Demand for EIDL Relief. 
 
In 2018, SBA determined to solicit its EIDL processing and loan recommendation 
contract as a small business set aside.90  Although the volume of EIDL applications in recent 
years had averaged only 65,000 annually, SBA made clear that it envisioned a catastrophic event 
could dramatically increase the volume of loan recommendations required.91  SBA specifically 
articulated that the required processing could be orders of magnitude larger than it had been in 
recent history, requiring SBA to “make a million decisions in a short period,” and that this would 
require the contractor recommend decisions at a rate of “12 loans per minute.”92 
 
SBA told the Select Subcommittee that the contract was solicited as a small business set 
aside in accordance with the Federal Acquisition Regulations (FAR) “Rule of Two,” which 
requires that agencies set contracts aside for small businesses when there is a “reasonable 
expectation” that two or more small businesses are likely to offer the solicited services 
“competitive in terms of fair market prices, quality, and delivery.”93  SBA ultimately awarded 
the contract to RER, a small business.94  Despite SBA’s determination that the contract was 
appropriate to set aside for a small business contractor, the agency assessed that the ultimate 
small business contractor would need to engage a large firm as a subcontractor to meet contract 
requirements.95   
 
This reasonable assessment should have led SBA to question whether any such small 
firm contractor/large firm subcontractor arrangement could have been expected to successfully 
handle the surge in demand that SBA foresaw in the case of a catastrophic event.  Those 
concerns should have been particularly acute in the case of awarding a loan recommendation 
contract to a company like RER, which was not itself a financial technology company that 
specialized in providing automated loan recommendations to aid underwriting.  RER, instead, 
had experience providing more general support and consulting services support to a range of 
federal agencies.96  To meet SBA’s requirement that a large firm partner with the small business 
that obtained the contract, RER partnered with Rocket Loans (Rocket), company that did 
specialize in providing lending services in partnership with a bank through an online platform 
that quickly generated loan offers in response to applications using proprietary technology.97  
SBA OIG found strong indications that Rocket performed the “primary and vital” services 
required for the pre-pandemic contract, including by providing the recommendation software 
required for the automated loan recommendations that the contract centered on.98 
 
At the onset of the pandemic, demand for EIDLs surged and SBA’s existing application 
portal and RER’s existing processing system (which was provided by Rocket) were not capable 
of effectively handling the dramatically increased volume of applications from small 
businesses.99  The application volume was even greater than the “million [EIDL applications] in 
a short period” that SBA foresaw as a possibility, with 4.5 million EIDL applications submitted 
by April 10, 2020.100  In order to handle this increased volume, SBA began working with Rapid, 
a new RER subcontractor (and corporate affiliate of Rocket), to build a new system to handle 
processing the increased volume of EIDL applications.101 
 

17 
 
Given that SBA foresaw that a catastrophic event could lead to a dramatic increase in 
application volume, SBA’s decision to issue the EIDL loan recommendation contract as a small 
business set aside to RER may have violated the FAR given the indications that RER would not 
be “competitive in terms of … quality, and delivery” particularly when faced with a catastrophic 
event.102  SBA should have been aware that RER lacked capacity to significantly contribute in 
such an event given that SBA OIG found that RER’s pre-pandemic contract proposal, teaming 
agreement with Rocket, and SBA’s Award Decision Memorandum contained clear indications 
that Rocket, not RER, would provide the “primary and vital” services required by the contract.103  
It is certainly possible that some small businesses—particularly those that specialized in lending 
technology services—may have been capable of providing loan recommendation services to 
SBA without undue reliance on a large firm partner, and with capacity to scale those services in 
the event of catastrophe, but RER did not have the capability to provide those core services.104   
 
There are also indications that SBA failed to take other steps necessary to ensure that the 
cost of the original contract was reasonable.  SBA OIG found that SBA failed to properly assess 
what labor costs and other direct costs would be involved in carrying out the contract to ensure 
that the price paid to RER was “fair and reasonable in accordance with [Federal Acquisition 
Regulations] and agency policy,” and as RER’s proposed price exceeded a previous independent 
government estimate by 55 percent.105   
 
As discussed below, an additional concern with issuing a contract that where an 
emergency small firm contractor/large firm subcontractor arrangement was foreseen stems from 
regulations and a statutory provision requiring 50 percent of small business set aside services 
contract revenue to be retained by the prime contractor and not paid to large business 
subcontractors.106  If a catastrophic event occurred that created an enormous surge in the needed 
services, that small business could receive an enormous windfall from a contract expanded under 
emergency conditions even as its large business subcontractor handled nearly all the additional 
workload.  
 
2. 
After the Onset of the Pandemic, SBA Expanded RER’s Contract to $750 Million 
for COVID-19 EIDL Services—the Largest Contract Awarded by the Federal 
Government to Respond to the Economic Impact of the Pandemic—Without A 
Competitive Process or Taking Reasonable Costs into Account. 
 
With the onset of the pandemic in March 2020, SBA began to work with RER and its 
new subcontractor, Rocket-affiliate Rapid, to develop a system for processing EIDL applications 
and receiving loan recommendations from Rapid’s system.107  SBA modified RER’s contract 
through a non-competitive process to dramatically increase the contract’s ceiling to $600 million, 
and later to $750 million.  It ultimately paid out at least $740 million.108  This substantial 
contract was the largest individual contract awarded across the federal government in 2020 for 
goods or services needed to support the response to the pandemic’s economic impacts—dwarfing 
other technical support contracts for the economic response to the pandemic and surpassed by 
only a handful of contracts related to the public health response to the pandemic, such as 
contracts to manufacture or distribute coronavirus vaccines.109  SBA told the Select 

18 
 
Subcommittee that it was necessary to modify the existing contract, rather than use a competitive 
bid process, in order to respond quickly to the coronavirus crisis.110 
 
 
In expanding RER’s contract, however, SBA OIG found that SBA carried forward the 
problems with its initial RER contract by failing to properly assess the labor costs and other 
direct costs necessary to carry out the contract to ensure that that the government was paying a 
fair and reasonable price.111  Documents obtained by the Select Subcommittee show SBA’s 
agreement with RER and the agency’s justification of its contract costs continued to be based on 
an assessment of the cost per EIDL application recommendation without consideration of actual 
labor costs required.  SBA continued to assess the cost of the contract on this per loan basis even 
though the Rapid loan recommendation system was automated and the COVID-19 EIDL contract 
allowed that automated system to operate at scale with relatively little additional labor.112   
 
 
Under the Trump Administration, SBA asserted that the approximately $41 per EIDL 
application that SBA paid for automated loan recommendation services has been a reasonable 
taxpayer value.113  Indeed, SBA assessed that its $750 million contract with RER “saved the 
American taxpayer billions of dollars,” by comparing the rate SBA paid per COVID-19 EIDL 
recommendation to the rate it paid at a much smaller scale for EIDL recommendations before the 
pandemic.114  This method of assessing the reasonableness of the cost of the contract fails to 
consider the reasonable costs that the contractor would actually incur by providing the service 
paid for.  Rapid’s loan recommendation system was automated, and documents obtained by the 
Select Subcommittee show it processed each EIDL application in less than a second, with 
processing continuing overnight with little or no human intervention.115  Although Rapid 
employees did work to create the system, maintain it, and to make adjustments and solve 
problems, essentially no labor was required to process each additional loan application through 
Rapid’s system, but SBA paid RER and its subcontractors on a per application basis.116  The 
Select Subcommittee obtained information that confirms SBA OIG’s assessment that SBA failed 
to assess the labor costs required for the EIDL processing contract.  As of March 2021, by which 
time SBA had paid RER $740 million, RER, Rocket, and Rapid together had only employed 189 
people in total who had worked on the contract in the previous year (including former employees 
who worked for only part of this period).117   
 
While there are costs other than labor incurred in creating an automated platform, 
maintaining it, and paying third party data providers (for example, for credit and fraud check 
services), SBA did not appear to consider these costs rigorously to ensure that the agency paid a 
reasonable price for loan recommendation services.  Documents obtained by the Select 
Subcommittee show the third-party data fees Rapid’s system incurred when processing EIDL 
applications were a small fraction of what SBA paid RER and its subcontractors.  The credit risk 
assessment, identity verification, fraud detection, public records search, bank account validation, 
and email verification service fees for EIDL applications processed through February 2, 2021, 
cost only $39 million, which was only 5 percent of the $738 million SBA paid RER through that 
time.118  Moreover, SBA also paid a flat fee of at least $2.3 million each month—totaling more 
than $25 million—in addition to the fixed fee per loan recommendation to cover other staffing, 
data, and technology costs RER and its subcontractors might incur.119   
 
RER, for its part, attempts to justify the reasonableness of its contract by comparing the 

19 
 
$41 per application processed that it received to the higher fees charged by banks for originating 
Paycheck Protect Program loans and SBA’s costs for fulling processing loans in other, smaller 
disasters.120  This comparison is faulty.  RER wrongly equates the automated processing it and its 
subcontractor Rapid provided—with no manual review of applications—to the full service 
provided by a traditional bank originating loans and to SBA when it handled the full loan 
evaluation, consideration, and approval process.  The comparison is particularly inapt because 
SBA expended significant additional resources beyond those included in RER’s contract to 
employ approximately 8,000 loan officers, Team Leads, and other staffers (over 5,000 of whom 
were SBA employees, with contract workers making up the remainder) to manually review EIDL 
applications after they were processed by Rapid’s automated system.121  SBA spent hundreds of 
millions of additional dollars internally to conduct the labor-intensive work of reviewing EIDL 
applications after they were processed through Rapid’s automated system.122  These substantial 
costs incurred to review EIDL applications after they were processed by Rapid’s system were 
separately borne by SBA, not by RER or its subcontractors. 
 
3. 
RER Received a Windfall of More Than $340 Million—After Paying Its 
Subcontractors and Hard Costs—for the Work of Just Six Employees.  
 
The breakdown of SBA funds received by RER, Rocket, and Rapid compared with the 
resources expended by each firm clarifies the dramatic extent to which RER’s $750 million 
contract far exceeded reasonable costs.  RER subcontracted with Rocket, which further 
subcontracted with Rapid.  Evidence the Select Subcommittee obtained from these companies 
makes clear that Rapid provided the vast majority of resources necessary to carry out SBA’s 
contract but received only a fraction of the taxpayer funds paid for those services.  Rocket and, 
especially, RER consequently received a windfall in taxpayer dollars relative to their costs or 
work rendered for the taxpayers.   
 
Out of the $738 million SBA paid on its contract through February 2021, RER received 
$357 million (48%), Rocket received $233 million (32%), and Rapid received $148 million 
(20%).123  But Rapid employed 163 people working on the SBA contract (86 percent of all 
contract personnel which contributed to contract), incurred $39 million in direct costs paid to 
third party data providers associated with running fraud and other checks on EIDL applications 
through its automated system, and provided its proprietary technology that Rocket asserted 
Rapid spent nine years and nearly a million hours developing.124  The Select Subcommittee’s 
review of email communications between SBA and the contractors shows extensive engagement 
with Rapid employees surrounding the development and operation of the COVID-19 EIDL 
recommendation system, usually without including any employees from prime contractor RER. 
 
RER, by contrast, assigned only six employees to work on this contract for which it 
pocketed $357 million after paying its subcontractors.125  RER also did not provide the complex 
proprietary technology necessary for the contract’s execution or directly incur costs for third 
party data services used by Rapid’s system.  Instead, RER’s small staff assigned to work on this 
contract largely performed “contractual administrative duties” like negotiating with SBA and 
sending the agency invoices and data concerning the number of applications processed, and high 
level “project management.”126  RER represented to the Select Subcommittee that it paid 51% of 
the “hard costs” identified by Rocket on invoices for services including credit checks and other 

20 
 
third-party data, but these costs totaled only $31.7 million in the invoices RER produced.127  
Subtracting RER’s share of the hard costs paid and payments to subcontractors, the company still 
received more than $340 million for the work of six employees in less than a year.  
  
 
Rocket identified only 20 employees who worked on the SBA contract through March 
2021, for which it pocketed $233 million.128  The invoices Rocket received from Rapid show, 
moreover, that Rapid paid the costs incurred through third party data providers (for services like 
credit checks and fraud detection data) out of the $148 million Rapid received.129  The public 
filings of Rocket’s parent company show that as Rocket received this windfall, its revenues 
surged 15-fold, from less than $25 million in 2019 to more than $393 million in 2020.130  In 
2021, with the large majority of the COVID-19 EIDL contract payments already paid out in the 
prior year, Rocket’s revenue declined to $95 million.131  Rocket’s parent reported that the 
company lost $200 million in income in 2021 “mainly as a result of a reduction in revenues 
earned from processing economic injury disaster loans offered by the Small Business 
Administration in response to the COVID-19 pandemic,” further demonstrating the enormous 
revenue Rocket derived from the EIDL contract that it dedicated few employees to.132  
 
 

21 
 
Documents obtained by the Select Subcommittee also demonstrate that Rapid employees 
conducted the large majority of detailed discussions with SBA about developing and operating 
the automated EIDL processing and recommendation system.133  In one email, SBA staff raised 
concerns with RER about the frequency of RER’s subcontractors direct communications with 
SBA and demanded that RER assert its role as SBA’s prime contractor.134  Specifically, an SBA 
procurement executive wrote to RER’s Chief Executive Officer that “RER Solutions is the prime 
[contractor] and must assert its position as the prime – the subcontractors are running around 
RER and communicating without regard to RER,” and also noted that Rapid employees were 
holding meetings with SBA that changed agency directions without RER’s involvement.135  
Federal Acquisition Regulations require that the prime contractor, not agency officials, manage 
their subcontractors work, a provision that may have been violated by Rapid’s extensive direct 
contacts with SBA officials without RER’s involvement.136 
 
When the Select Subcommittee asked SBA staff about the apparent windfall of nearly 
$350 million RER received while it assigned only six employees to the contract and its 
subcontractor did most of the work required, SBA contracting staff responded that they 
determined what mattered was the quality of the work not the just the number of employees 
engaged.137  Yet they also stated that they did not have insight into the share of work performed 
by each contractor and subcontractor, making it unclear, even if they were disbursing funds 
based on work quality, which company should be given credit (and therefore money) for the 
quality of which aspects of the work.138 
 
SBA staff also cited the fact that RER was required to receive more than 50 percent of 
federal contract funds—regardless of the amount of work the company performed relative to its 
subcontractors—in order to comply with the federal acquisition regulations mentioned above 
intended to prevent so-called “pass through” small business set aside contracts, where a large 
firm receives the majority of the revenue.139  As a factual matter, this does appear to be correct, 
and there is no emergency exception for circumstances where a catastrophic event requires an 
agency to dramatically expand the contract on an emergency basis while the small business 
contractor needs to rely on a large firm to handle the increased workload.140  (SBA regulations 
do contain a minor exception to the 50 percent requirement for certain “direct costs,” which 
explains why RER received slightly less that 50 percent of the contract’s total value).141   
 
Yet the fact that SBA’s discretion was limited by this requirement is no defense of the 
waste of taxpayer funds.  This overpayment was foreseeable at the time of the initial decision in 
2018 to award the contract to RER given agency officials’ knowledge that the company would 
need to rely on one or more large subcontractors to perform the core loan recommendation 
services even on the initial pre-pandemic contract, and would consequently need to rely on large 
subcontractors even more heavily to fulfill an expanded contract to handle a surge in EIDL 
applications following a catastrophe.142  SBA should have anticipated that in the event of such a 
crisis, under the existing law, RER would likely reap a significant windfall in revenue even as 
large firm subcontractors completed nearly all the necessary work.  Yet the contract was awarded 
anyway, and in the nearly eighteen months between the initial award and the onset of the 
pandemic, SBA appears to have made no effort to prevent this wasteful outcome.  In following 
one regulation, SBA appears to have violated another: to obtain a “fair and reasonable price.”143 
 
 

22 
 
IV. 
RECOMMENDATIONS  
 
A. 
SBA OIG Should Continue to Assess the Precise Extent of Fraud Committed 
Against the COVID-19 EIDL Program. 
 
SBA OIG previously identified tens of billions of dollars in EIDL funds approved in 
response to applications containing serious fraud alerts and has identified other indicia of the 
extent of fraud committed against the program including applications associated with identity 
theft and returned loan statements.  However, taxpayers still do not know the precise extent of 
fraud committed against the program.  In the coming year, most COVID-19 EIDL loans will start 
to enter repayment, which will offer an opportunity for SBA and SBA OIG to accurately assess 
the full extent of fraud in the loan portion of the program.  Identifying the amount of fraud 
committed against the EIDL program is vital both to efforts to recover taxpayer dollars and to 
avoiding fraud vulnerabilities in future emergencies.  SBA and SBA OIG should also continue to 
refer instances of fraud identified with evidence of who perpetrated the fraud to DOJ for 
prosecution and/or civil actions to recover taxpayer funds or use SBA’s own authority to bring 
civil actions to recover taxpayer funds.  
  
B. 
SBA Should Identify All COVID-19 EIDL Applications Approved Early in 
the Trump Administration’s Implementation of the Program that Contained 
Serious Identity Theft Fraud Alerts in Order to Aid in Relieving Identity 
Theft Victims From Fraudulently Incurred Debts. 
 
Identity theft was a significant source of fraud committed against the EIDL program and 
is a method of fraud that jeopardizes the credit and financial standing of individuals whose 
identities were stolen.  SBA has indicated that in 2021 it set up a process for handling identity 
theft complaints, including by releasing victims from liability and referring cases to law 
enforcement.144  To aid these efforts, SBA should identify all approved EIDL loans that 
contained fraud alerts suggestive of possible identity theft before SBA updated its guidance to 
loan reviewers in June 2020 to require action to verify applicants’ identities.  
 
C. 
In Future Noncompetitive Contracts for Automated Technological Services, 
SBA Should Consider the Labor and Other Costs Actually Necessary to 
Provide the Services Required. 
 
SBA assessed the reasonableness of the cost of its contract with RER for automated 
EIDL application processing and recommendation services based on the cost of processing each 
application without considering the relatively small labor and non-labor costs actually required to 
fulfill the contract.  This led to a contract award that resulted in RER receiving over $340 million 
for the work of only six employees and Rocket receiving $233 million for the work of only 20 
employees, as a third company, Rapid, provided the processing system, paid a significant share 
of the costs and employed the large majority of employees working to fulfill the contract.  In 
future contracts, particularly those that include automated technological services, SBA should 
include an assessment of the actual costs contractors will incur in providing the solicited services 
to ensure that taxpayers pay reasonable and fair price. 
 

23 
 
 
1 Select Subcommittee on the Coronavirus Crisis, Press Release:  Clyburn and Velázquez Ramp up 
Investigation into SBA Loan Program Plagued by Fraud (Feb. 11, 2021) (online at 
https://coronavirus.house.gov/news/press-releases/clyburn-and-vel-zquez-ramp-investigation-sba-loan-program-
plagued-fraud); Select Subcommittee on the Coronavirus Crisis, Press Release:  Chairs Launch Investigation into 
$500 Million Contract in SBA Emergency Loan Program Plagued by Errors and Delays (July 30, 2020) (online at 
https://coronavirus.house.gov/news/press-releases/chairs-launch-investigation-500-million-contract-sba-emergency-
loan-program).  
2 Memorandum from Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis, 
The Biden Administration’s Efforts to Root Out Fraud in Pandemic Relief Programs and Bring Wrongdoers to 
Justice (June 13, 2022) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/The%20Biden%20Administration%27s%
20Efforts%20to%20Root%20Out%20Fraud%20in%20Pandemic%20Relief%20Programs%20and%20Bring%20Wr
ongdoers%20to%20Justice.pdf); Small Business Administration, Office of Inspector General, Inspection of Small 
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) 
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from 
Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis, Lowering the Guardrails:  How 
the Trump Administration Failed to Prevent Billions in Pandemic Small Business Fraud (Mar. 25, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-03-25%20Staff%20Memo%20-
%20Small%20Business%20Fraud.pdf).  
3 15 U.S.C. § 636; 13 C.F.R. § 123.5 (2022). 
4 Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation 
Services (Oct. 4, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).  
5 Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation 
Services (Oct. 4, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf). 
6 Id. 
7 Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf).  
8 Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation 
Services (Oct. 4, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf). 
9 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (July 9, 2021); 48 C.F.R. § 19.502-2.  
10 Small Business Administration, Solicitation/Contract/Order for Commercial Items (Dec. 14, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Briefing by Staff, Small Business Administration, 
to Staff, Select Subcommittee on the Coronavirus Crisis (July 9, 2021). 
11 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Small Business Administration, Solicitation/Contract/Order for 
Commercial Items (Dec. 14, 2018) (online at 

24 
 
 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf). 
12 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).   
13 RER Solutions Inc., Excerpt of Subcontract Agreement (Apr. 1, 2019) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Solutions%20Inc.%20Excerpt%
20of%20Subcontract%20Agreement_Redacted.pdf); Small Business Administration, Office of Inspector General, 
Evaluation of SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at 
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf); Rocket Loans, Our Loans (online 
at www.rocketloans.com/) (accessed May 27, 2022); Rocket Companies, Inc., Press Release:  Rocket Companies 
Announces Fourth Quarter and Full Year 2021 Results (Feb. 24, 2022) (online at www.prnewswire.com/news-
releases/rocket-companies-announces-fourth-quarter-and-full-year-2021-results-
301490108.html#:~:text=Full%20Year%20Financial%20Highlights&text=Generated%20total%20revenue%2C%20
net%20of%20%2412.9%20billion%20and%20Adjusted%20Revenue,on%20sale%20margin%20of%203.13%25).  
14 Contractor Performance Assessment Report, RER Solutions, Inc. (July 7, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20306%20prior%20contract%20as
sessment_Redacted.pdf). 
15 Contractor Performance Assessment Report, RER Solutions, Inc. (July 1, 2015) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20309%20prior%20contract%20as
sess_Redacted.pdf). 
16 Rocket Companies, Securities and Exchange Commission Form 10-K (Mar. 1, 2022) (online at 
https://ir.rocketcompanies.com/financials/sec-filings/default.aspx). 
17 Id. 
18 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf). 
19 Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf). 
20 Id. 
21 Coronavirus Preparedness and Response Supplemental Appropriations Act, Pub. L. No. 116-123 (2020); 
Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136, (2020); Paycheck Protection Program and 
Health Care Enhancement Act, Pub. L. 116-139 (2020); Consolidated Appropriations Act, 2021, Pub. L. 116-260 
(2020); American Rescue Plan Act, Pub. L. No. 117-2 (2021). 
22 Small Business Administration Office of Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).  
23 Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136 (2020). 
24 Coronavirus Preparedness and Response Supplemental Appropriations Act, Pub. L. No. 116-123 (2020); 
Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136, (2020); Paycheck Protection Program and 
Health Care Enhancement Act, Pub. L. 116-139 (2020); Consolidated Appropriations Act, 2021, Pub. L. 116-260 
(2020); American Rescue Plan Act, Pub. L. No. 117-2 (2021). 
25 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Government Accountability Office, Economic Injury Disaster Loan 
Program:  Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July 
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf).  

25 
 
 
26 Small Business Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL 
Advances, Supplemental Targeted Advances (Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-
04/COVID-19%20EIDL%20TA%20STA_04282022_Public-508.pdf); As Pandemic Aid Was Rushed to Main 
Street, Criminals Seized on Covid Relief Programs, CNBC (Apr. 15, 2021) (online at 
www.cnbc.com/2021/04/15/as-pandemic-aid-was-rushed-to-main-street-criminals-seized-on-ppp-eidl-.html); 
Government Accountability Office, COVID-19 Loans:  SBA Has Begun to Take Steps to Improve Oversight and 
Fraud Risk Management (Apr. 20, 2021) (GAO-21-498T) (online at www.gao.gov/products/gao-21-498t). 
27 Small Business Administration, Disaster Assistance Update EIDL Advance (July 15, 2020) (online at  
www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-19%20Advance%207.15.20-508.pdf); Small Business 
Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL Advances, Supplemental 
Targeted Advances (Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-04/COVID-
19%20EIDL%20TA%20STA_04282022_Public-508.pdf);  Targeted advances were $10,000 grants available to 
small businesses in low-income communities that saw more than a 30% reduction in revenue for an eight-week or 
longer period during the pandemic, and supplemental targeted advances were $5,000 additional grants available to 
businesses in low-income areas that saw a more than 50% economic loss for an eight-week period during the 
pandemic. Small Business Administration, About Targeted EIDL Advance and Supplemental Targeted Advance 
(online at www.sba.gov/funding-programs/loans/covid-19-relief-options/covid-19-economic-injury-disaster-
loan/about-targeted-eidl-advance-supplemental-targeted-advance) (accessed June 9, 2022). 
28 Small Business Administration, Office of Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Email from Chief Executive 
Officer, RER Solutions, Inc., to Senior Loan Officer, Small Business Administration (Mar. 20, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf). 
29 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf); Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select 
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 
24, 2020) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf). 
30 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Government Accountability Office, Economic Injury Disaster Loan 
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July 
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); Email from Chief Executive Officer, RER 
Solutions, Inc., to Senior Loan Officer, Small Business Administration (Mar. 20, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf). 
31  USASpending, Contract Summary RER Solutions, Inc. (online at 
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20, 
2022); Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020) (online 
at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf).  
32 Id.  
33 Coronavirus Contracts Tracking Federal Purchases to Fight the Coronavirus, ProPublica (online at 
https://projects.propublica.org/coronavirus-contracts/contracts) (accessed May 19, 2022); In 2021, SBA modestly 
increased the ceiling on the COVID-19 EIDL contract to $800 million, but as of SBA OIG’s recent report only 
slightly more than $750 million had actually been paid to RER and its subcontractors.  USASpending, Contract 
Summary RER Solutions, Inc. (online at 
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20, 
2022); Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 

26 
 
 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).  
34 Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions Needed 
to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Evaluation of 
SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at 
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf). 
35 Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis 
(Mar. 3, 2021); Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf). 
36 Rapid Financial Services, LLC, Rapid Decision Release Note (May 6, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20Decision%20Release%20Note
%205.6.2020.pdf); Decision Logic, How It Works (online at www.decisionlogic.com/HowItWorks.aspx) (accessed 
May 19, 2022).  
37 Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief 
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the 
Coronavirus Crisis (Mar. 3, 2021) 
38 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf). 
39 Id.; Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (Feb. 2, 2022).  
40 Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis 
(Mar. 3, 2021); Screenshot of Rapid Loan Officer Portal, Briefing by Rapid Financial Services, LLC, to Staff, Select 
Subcommittee on the Coronavirus Crisis (Mar. 3, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Screenshot%20Loan%20Officer%20Porta
l%2C%20Sumary%20%26%20Fraud%20Badge.pdf). 
41 Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis 
(Mar. 3, 2021); Screenshot of E-Tran Overview, Briefing by Rapid Financial Services, LLC, to Staff, Select 
Subcommittee on the Coronavirus Crisis (Mar. 3, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Screenshot%20%20E-
Tran%20Diagram.pdf). 
42 Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf); Letter from 
Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and 
Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf). 
43 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf). 
44 Id. 

27 
 
 
45 SBA dramatically increased its number processing staff and contractors at a salary range that suggests the 
costs were hundreds of millions of dollars.  Government Accountability Office, Economic Injury Disaster Loan 
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July 
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); USAJOBS, Loan Specialist (General) – 
Virtual, Small Business Administration, Office of Disaster Assistance (ODA) Processing and Disbursement Center 
(PDC) (online at www.usajobs.gov/job/563879000) (accessed May 20, 2022). 
46 Government Accountability Office, Small Business Administration:  Actions Needed to Improve 
COVID-19 Loans' Internal Controls and Reduce Their Susceptibility to Fraud (Mar. 24, 2021) (GAO-21-472T) 
(online at www.gao.gov/products/gao-21-472t); Small Business Administration, Office of Inspector General, 
Inspection of Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic 
(Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Select 
Subcommittee on the Coronavirus Crisis, Hearing on Rooting Out Fraud in Small Business Relief Programs (Mar. 
25, 2021) (online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-rooting-out-
fraud-small-business-relief-programs). 
47 Project on Government Oversight, “A Disaster”:  Small Business Administration Scrambling to Stop 
Pandemic Loan Fraud (Sept. 9, 2020) (online at www.pogo.org/investigation/2020/09/a-disaster-small-business-
administration-scrambling-to-stop-pandemic-loan-fraud). 
48 Select Subcommittee on the Coronavirus Crisis, Press Release:  Chairs Launch Investigation into $500 
Million Contract in SBA Emergency Loan Program Plagued by Errors and Delays (July 30, 2020) (online at 
https://coronavirus.house.gov/news/press-releases/chairs-launch-investigation-500-million-contract-sba-emergency-
loan-program). 
49 Select Subcommittee on the Coronavirus Crisis, Press Release:  Clyburn and Velázquez Ramp up 
Investigation into SBA Loan Program Plagued by Fraud (Feb. 11, 2021) (online at 
https://coronavirus.house.gov/news/press-releases/clyburn-and-vel-zquez-ramp-investigation-sba-loan-program-
plagued-fraud ); Select Subcommittee on the Coronavirus Crisis, Press Release:  Chairs Clyburn and Velázquez 
Seek Key Disaster Loan Program Documents Withheld by Trump Administration (May 11, 2021) (online at 
https://coronavirus.house.gov/news/press-releases/chairs-clyburn-and-vel-zquez-seek-key-disaster-loan-program-
documents-withheld). 
50 Id. 
51 Select Subcommittee on the Coronavirus Crisis, Hearing on Rooting Out Fraud in Small Business Relief 
Programs (Mar. 25, 2021) (online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-
rooting-out-fraud-small-business-relief-programs). 
52 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf). 
53 Memorandum from Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis, 
The Biden Administration’s Efforts to Root Out Fraud in Pandemic Relief Programs and Bring Wrongdoers to 
Justice (June 13, 2022) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/The%20Biden%20Administration%27s%
20Efforts%20to%20Root%20Out%20Fraud%20in%20Pandemic%20Relief%20Programs%20and%20Bring%20Wr
ongdoers%20to%20Justice.pdf); Small Business Administration, Office of Inspector General, Inspection of Small 
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) 
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from 
Majority Staff to Members of the Select Subcommittee on the Coronavirus, Lowering the Guardrails:  How the 
Trump Administration Failed to Prevent Billions in Pandemic Small Business Fraud (Mar. 25, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-03-25%20Staff%20Memo%20-
%20Small%20Business%20Fraud.pdf).  
54 Select Subcommittee on the Coronavirus Crisis, Testimony of Inspector General Hannibal “Mike” Ware, 
Small Business Administration, Hearing on Rooting Out Fraud in Small Business Relief Programs (Mar. 25, 2021) 
(online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-rooting-out-fraud-small-
business-relief-programs). 

28 
 
 
55 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf).  
56 Small Business Administration, SBA’s Handling of Identity Theft in the COVID-19 Economic Injury 
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).  
57 Small Business Administration, Office of Inspector General, SBA’s Emergency EIDL Grants to Sole 
Proprietors and Independent Contractors (Oct. 7, 2021) (online at www.sba.gov/sites/default/files/2021-
10/SBA%20OIG%20Report%2022-01%20.pdf).  
58 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Inspection of 
Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) 
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).  
59 Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business 
Administration (Mar. 30, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf); Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on 
the Coronavirus Crisis (Feb. 2, 2022). 
60 Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business 
Administration (Mar. 30, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf). 
61 Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business 
Administration (Mar. 30, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf); Small Business Administration, Office of Inspector General, Inspection of Small 
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) 
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).  
62 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf). 
63 Small Business Administration, Office of Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf). 
64 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (Feb. 2, 2022). 
65 SBA did curtail its use of batch approval in August 2020 after SBA OIG issued a critical report on EIDL 
fraud, but 3.3 million EIDLs had already been approved by this time. Small Business Administration, Office of 
Inspector General, Inspection of Small Business Administration’s Initial Disaster Assistance Response to the 
Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf).  As of June 10, 2021, SBA data shows that 3.8 million EIDL 
applications had been approved in total.  Data provided to the Select Subcommittee by Rapid shows that as of June 
11, 2021, approximately 2.2 million applications had been approved following a recommendation for manual 
review, and approximately 1.6 million applications had been recommended directly to SBA Team Leads for 
approval, indicating that all or almost all applications sent directly to Team Leads for batch approval were ultimately 
approved.  Small Business Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL 
Advances, Supplemental Targeted Advances (June 10, 2021) (online at www.sba.gov/sites/default/files/2021-
06/COVID-19%20EIDL%20TA%20STA_6.10.2021_Public-508_0.pdf); Email from Counsel, Rapid Financial 
Services LLC, to Staff, Select Subcommittee on the Coronavirus Crisis (June 23, 2021) (online at 

29 
 
 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Counsel%20for%20Rapid%20t
o%20SSCC%20Staff_Redacted.pdf). 
66 Email from Counsel, Rapid Financial Services LLC, to Staff, Select Subcommittee on the Coronavirus 
Crisis (June 23, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Counsel%20for%20Rapid%20t
o%20SSCC%20Staff_Redacted.pdf). 
67 Small Business Administration, Office of Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from Director, 
Office of Grants Management, Small Business Administration, to Chief Financial Officer, Small Business 
Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select 
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 
11, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); One SBA staff member told the Select Subcommittee that, to their recollection, 
applications with fraud flags were not included in batches, but this conflicts with the memorandum to provided to 
SBA’s contractor and subcontractors to implement the batch policy, the findings of the SBA OIG, and the 
representations made to the Select Subcommittee by RER Solutions about the instructions it received regarding the 
rules for inclusion in batches.  Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on 
the Coronavirus Crisis (Feb. 2, 2022). 
68 Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief 
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf). 
69 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (Feb. 2, 2022).  
70 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf).  
71 Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief 
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Government Accountability Office, Economic Injury Disaster Loan Program:  Additional 
Actions Needed to Improve Communication With Applicants and Address Fraud Risks (July 2021) (GAO-21-589) 
(online at www.gao.gov/assets/gao-21-589.pdf). 
72 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (July 29, 2021). 
73 Small Business Administration, SBA’s Handling of Identity Theft in the COVID-19 Economic Injury 
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).  
74 Small Business Administration, SBA Rapid Decision Reference Guide (May 15, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
205.15.20_Redacted.pdf). 
75 Id. 
76 Small Business Administration, Disaster Assistance Update Nationwide EIDL Loans (June 12, 2020) 
(online at www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-19%20Loan%206.12.20-508_0.pdf); Small 

30 
 
 
Business Administration, SBA Rapid Decision Reference Guide (June 12, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
206.12.20_Redacted.pdf). 
77 Small Business Administration, SBA Rapid Decision Reference Guide (April 20, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
204.20.21_Redacted.pdf). 
78 Project on Government Oversight, “A Disaster”:  Small Business Administration Scrambling to Stop 
Pandemic Loan Fraud (Sept. 9, 2020) (online at www.pogo.org/investigation/2020/09/a-disaster-small-business-
administration-scrambling-to-stop-pandemic-loan-fraud). 
79 Small Business Administration, Office of the Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Response to Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf). 
80 Complaint, United States v. Nobbe, No. 1:20-MJ-3236 (S.D. Fla. July 24, 2020), ECF No. 1; Complaint, 
United States v. One, No. 0:20-MJ-6325 (S.D. Fla. Aug. 6, 2020), ECF No. 1; Indictment, United States v. Lewis, 
No. 1:20-CR-3361 (M.D.N.C. Aug. 8, 2020), ECF No. 1; Complaint, United States v. Casutt, No. 2:20-MJ-666 
(D. Nev. Aug. 10, 2020), ECF No. 1; Affidavit, United States v. Redfern, No. 1:20-MJ-256 (M.D.N.C. Aug. 25, 
2020), ECF No. 2; Complaint, United States v. Stanley, et al., No. 1:20-MJ-3470 (S.D. Fla. Aug. 26, 2020), ECF 
No. 3; Information, United States v. Horner, No. 4:21-CR-00242 (M.D. Pa. Aug. 31, 2021), ECF No. 1; Complaint, 
United States v. Lavanture, No. 1:20-MJ-452 (N.D.N.Y. Sept. 9, 2020), ECF No. 1; Complaint and Affidavit, 
United States v. Trapp, No. 1:20-MJ-915 (E.D.N.Y. Oct. 6, 2020), ECF No. 1; Complaint, United States v. 
Carpenter, et al., No. 2:20-CR-179 (W.D. Tenn. Oct. 6, 2020), ECF No. 1; Complaint, United States v. Hsu, No. 
2:20-MJ-691 (W.D. Wash. Oct. 26, 2020), ECF No. 1; Complaint, United States v. Ayvazyan, et al., No. 2:20-CR-
579 (C.D. Cal. Nov. 3, 2020), ECF No. 1; Indictment, United States v. Williams, No. 1:20-CR-105 (S.D. Ga. Nov. 5, 
2020), ECF No. 1; Indictment, United States v. Nelson, et al., No. 1:20-CR-103 (S.D. Ga. Nov. 5, 2020), ECF No. 1; 
Indictment, United States v. Plummer, No. 1:20-CR-106 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United 
States v. Coleman, No. 1:20-CR-107 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United States v. Mack, No. 
1:20-CR-104 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United States v. Williams, No. 1:20-CR-109 (S.D. 
Ga. Nov. 19, 2020), ECF No.1; Indictment, United States v. Jones, No. 3:20-CR-30073 (C.D. Ill. Dec. 2, 2020), 
ECF No. 1; Indictment, United States v. Garrido-Baez, No. 3:20-CR-30072 (C.D. Ill. Dec. 2, 2020), ECF No. 1; 
Complaint, United States v. Kanyike, No. 2:20-MJ-5936 (C.D. Cal. Dec. 8, 2020), ECF No.1; Indictment, United 
States v. Jones, No. 3:20-CR-438 (W.D.N.C. Dec. 16, 2020), ECF No. 1; Indictment, United States v. Smith, No. 20-
CR-922 (N.D. Ill. Dec. 17, 2020), ECF No. 1; Complaint, United States v. Cruz, No. 1:21-CR-10019 (D. Mass. Dec. 
18, 2020), ECF No. 4; Complaint, United States v. Clawson, No. 3:20-MJ-294 (D. Or. Dec. 21, 2020), ECF No. 1; 
Complaint, United States v. Unitan, No. 3:20-MJ-293 (D. Or. Dec. 21, 2020), ECF No. 1; Complaint, United States 
v. Caraballo, No. 1:21-MJ-2014 (S.D. Fla. Jan. 6, 2021), ECF No. 1; Affidavit, United States v. Pape, et al., 
No. 5:21-MJ-0007 (E.D. Tex. Jan. 12, 2021), ECF No. 2; Complaint, United States v. Oworae, No. 4:21-MJ-4014 
(D. Mass. Jan. 20, 2021), ECF No. 1; Complaint, United States v. Burden, No. 4:21-MJ-70194 (N.D. Cal. Feb. 3, 
2021), ECF No. 1; Indictment, United States v. Bolen, No. 3:21-CR-30013 (C.D. Ill. Feb. 3, 2021), ECF No. 1; 
Indictment, United States v. Prioleau, No. 3:21-CR-49-MOC (W.D.N.C. Feb. 17, 2021), ECF No. 1; Indictment, 
United States v. Clifron, No. 3:21-CR-46 (W.D.N.C. Feb. 17, 2021), ECF No. 1; Information, United States v. 
Kirkland, No. 6:21-CR-2 (S.D. Ga. Feb. 19, 2021), ECF No. 1; Indictment, United States v. Bella, No. 1:21-CR-31 
(W.D.N.Y. Feb. 23, 2021), ECF No. 1; Complaint, United States v. Cordor, No. 4:21-CR-40016 (D. Mass. Mar. 4, 
2021), ECF No. 4; Complaint, United States v. Spierdowis, No. 1:21-MJ-1074 (D. Mass. Mar. 4, 2021), ECF No. 1; 
First Superseding Indictment, United States v. Grigoryan, et al., No. 2:20-CR-579 (C.D. Cal. Mar. 9, 2021), ECF 
No. 154; Indictment, United States v. Kornaker, No. 1:21-CR-37 (W.D.N.Y. Mar. 10, 2021), ECF No. 13; 
Indictment, United States v. Fiege, No. 0:21-CR-55-MJD-LIB (D. Minn. Mar. 11, 2021), ECF No. 1; Indictment, 
United States v. Lawson, et al., No. 3:21-CR-6 (N.D. Ga. Mar. 16, 2021), ECF No. 1; Complaint, United States v. 
Ayers, et al., No. 7:21-MJ-3110 (S.D.N.Y. Mar. 23, 2021), ECF No. 2; Complaint, United States v. Hannah, 
No. 2:21-9168 (D.N.J. Mar. 23, 2021), ECF No. 1; Complaint, United States v. Venant, No. 8:21-MJ-1295 (M.D. 
Fla. Mar. 26, 2021), ECF No. 1; Complaint, United States v. Kwak, et al., No. 1:21-CR-199 (N.D. Ga. Apr. 1, 2021), 
ECF No. 1; Affidavit, United States v. Brooks, No. 8:21-MJ-695 (D. Md. Apr. 2, 2021), ECF No. 2; Complaint, 
United States v. Onah, No. 3:21-MJ-191 (N.D.N.Y. Apr. 2, 2021), ECF No. 1; Indictment, United States v. Isbaih, 
No. 1:21-CR-208 (N.D. Ill. Apr. 5, 2021), ECF No. 1; Indictment, United States v. Bella, et al., No. 1:21-CR-247 
(S.D.N.Y. Apr. 14, 2021), ECF No. 3; Indictment, United States v. Hilaire, No. 1:21-CR-39WES-PAS (D.R.I. Apr. 

31 
 
 
16, 2021), ECF No. 1; Complaint, United States v. Zimmerman, No. 2:21-MJ-8050 (D.N.J. Apr. 21, 2021), ECF 
No. 1; Indictment, United States v. Pounds, et al., No. 5:21-CR-317-PAB (N.D. Ohio Apr. 29, 2021), ECF No. 1; 
Complaint, United States v. Bennett, et al., No. 1:21-MJ-7102 (D.N.J. May 14, 2021), ECF No. 1; Indictment, 
United States v. Taylor, No. 3:21-CR-132-FDW (W.D.N.C. May 18, 2021), ECF No. 3; Indictment, United States v. 
Foreman, et al., No. 1:21-CR-165 (D. Colo. May 18, 2021), ECF No. 1; Indictment, United States v. Lysne, 
No. 3:21-CR-167 (D. Or. May 19, 2021), ECF No. 1; Complaint, United States v. Hannesyan, No. 2:21-CR-284 
(C.D. Cal. May 24, 2021), ECF No. 1; Information, United States v. Lain, No. 1:21-CR-175 (D. Colo. May 26, 
2021), ECF No. 1; Indictment, United States v. Aquino, No. 1:21-CR-144 (E.D. Cal. May 27, 2021), ECF No. 1; 
Indictment, United States v. Vaughn, No. 6:21-CR-34 (E.D. Ky. May 27, 2021), ECF No. 1; Indictment, United 
States v. Cherry, No. 4:20-CR-27 (E.D. Mich. May 29, 2021), ECF No. 1; Complaint, United States v. Klasinc, 
No. 1:21-CR-5835 (S.D.N.Y. June 5, 2021), ECF No. 1; Indictment, United States v. Ahiekpor, No. 2:20-CR-00094 
(S.D. Ohio June 23, 2020), ECF No. 22; Complaint, United States v. Sanay, et al., No. 1:21-MJ-668 (E.D.N.Y. June 
8, 2021), ECF No. 1; Information, United States v. Zaghab, No. 21-CR-188 (D. Colo. June 8, 2021), ECF No. 1; 
Information, United States v. Carter, No. 1:21-CR-204 (D. Md. June 9, 2021), ECF No. 1; Indictment, United States 
v. Porch, et al., No. 4:21-CR-23 (M.D. Ga. June 9, 2021), ECF No. 1; Information, United States v. Bush, No. 3:21-
CR-74 (E.D. Tenn. June 10, 2021), ECF No. 1; Information, United States v. Grubb, No. 1:21-CR-175 (M.D. Pa. 
June 22, 2021), ECF No. 1; Indictment, United States v. Soto, No. 1:21-CR-49-CFC (D. Del. July 6, 2021), ECF 
No. 2; Indictment, United States v. Miller, No. 1:21-CR-10228-FDS (D. Mass. July 7, 2021), ECF No. 9; 
Indictment, United States v. Bolte, No. 1:21-CR-46-SPW (D. Mont. July 8, 2021), ECF No. 2; Indictment, United 
States v. Henson, et al., No. 2:21-CR-601DJH (D. Ariz. Aug. 3, 2021), ECF No. 3; Complaint, United States v. 
Mansouri, No. 1:21-MJ-5143 (W.D.N.Y. Aug. 3, 2021), ECF No. 1; Indictment, United States v. Eldabbagh, 
No. 1:21-CR-523 (D.D.C. Aug. 17, 2021), ECF No. 1; Indictment, United States v. Bruey, et al., No. 2:21-CR-74 
(M.D. Fla. Aug. 25, 2021), ECF No. 3; Information, United States v. Curry, No. 1:21-CR-20415 (S.D. Fla. Aug. 5, 
2021), ECF No. 1; Information, United States v. Savath, No. 1:21-CR-10269 (D. Mass. Sept. 13, 2021), ECF No. 1; 
Indictment, United States v. Capps, No. 6:21-CR-10073 (D. Kan. Sept. 8, 2021), ECF No. 1; Information, United 
States v. Howell, No. 3:21-CR-00109 (E.D. Tenn. Aug. 18, 2021), ECF No. 1; Complaint, United States v. Larkins, 
No. 21-8190 (D.N.J. Sept. 15, 2021), ECF No. 1; Information, United States v. Blackman, No. 2:21-CR-00724 
(D.N.J. Sept. 16, 2021), ECF No. 55; Complaint, United States v. Okeke, et al., No. 1:21-MJ-1092 (E.D.N.Y. Sept. 
23, 2021), ECF No. 1; Indictment, United States v. Jones, No. 2:21-CR-00417 (W.D. Pa. Sept. 28, 2021), ECF No. 
3; Information, United States v. Cavanaugh, No. 2:21-CR-00155 (D. Me. Sept. 29, 2021), ECF No. 1; Complaint, 
United States v. Carter, et al., No. 21-MJ-9734 (S.D.N.Y Oct. 14, 2021), ECF No. 1; Indictment, United States v. 
Knight, No. 2:21-CR-00043 (S.D. Ga. Oct. 5, 2021), ECF No. 3; Indictment, United States v. Casey, No. 1:20-CR-
10202 (D. Mass. Sept. 23, 2021), ECF No. 1; Indictment, United States v. Levons, No. 3:21-CR-00340 (M.D. Pa. 
Nov. 2, 2021), ECF No. 1; Indictment, United States v. Sparks, et al., No. 2:21-CR-00189-JLR (W.D. Wash. Nov. 
10, 2021), ECF No. 1; Complaint, United States v. Kaeding, No. 1:21-MJ-04220 (S.D. Fla. Nov. 17, 2021), ECF No. 
1; Complaint, United States v. Shibley, No. 2:20-MJ-00385-MLP (W.D. Wash. June 29, 2020), ECF No. 1; 
Complaint, United States v. Osborne, No. 2:21-CR-00456 (E.D. Pa. Nov. 23, 2021), ECF No. 1; Complaint, United 
States v. Kantar, No. 2:21-MJ-02124 (W.D. Pa. Nov. 30, 2021), ECF No. 1; Third Superseding Indictment, United 
States v. Greenberg, No. 20-CR-00097 (M.D. Fla. Mar. 31, 2021), ECF No. 90; Indictment, United States v. Ilori, 
No. 1:21-cr-00746 (S.D.N.Y. Dec. 8, 2021), ECF No. 6; Indictment, United States v. Encarnacion, No. 2:21-mj-
13427 (D.N.J. Dec. 13, 2021), ECF No. 1; Information, United States v. Saintvil, No. 1:21-cr-00013 (N.D. Fla. 
March 23, 2021), ECF No. 1; Complaint, United States v. Lloyd, No. 6:21-mj-00001 (D. Or. Jan. 5, 2021), ECF No. 
1; Superseding Information, United States v. Fernandez, No. 1:21-cr-10046 (D. Mass. July 9, 2021), ECF No. 37; 
Information, United States v. Dorsey, No. 8:21-cr-00370 (D.S.C. Sept. 16, 2021), ECF No. 1; Information, United 
States v. Thornton, No. 6:21-cr-00098 (M.D. Fla. Jan. 19, 2021), ECF No. 1; Information, United States v. Eustache, 
No. 6:21-cr-00098 (M.D. Fla. July 8, 2021), ECF No. 1; Indictment, United States v. Tifekchian, No. 3:21-cr-00244 
(D. Or. July 13, 2021), ECF No. 1; Complaint, United States v. Laventure, No. 1:20-cr-00290 (N.D.N.Y. Mar. 3, 
2020), ECF No. 1; Complaint, United States v Darius, No. 2:22-mj-10018 (D.N.J. Jan. 25, 2022), ECF No. 1; 
Complaint, United States v. Garcias, No. 2:21-mj-09344 (D.N.J June 23, 2021), ECF. No. 1; Affidavit in Support of 
Complaint, United States v. Phillips, No. 1:21-mj-03581 (D. Md. Dec. 22, 2021), ECF No. 2; Information, United 
States v. Rivera, No. 1:22-cr-20028 (S.D. Fla. Jan. 28, 2022), ECF No. 1; Complaint, United States v. Budamala, 
No. 2:22-cr-00077 (C.D. Cal. Feb. 24, 2022), ECF No. 1; Complaint, United States v. Schoepflin et al., No. 2:22-cr-
00121 (C.D. Cal Apr. 1, 2022), ECF No. 1; Indictment, United States v. Rickerson, No. 5:22-cr-00013 (W.D.N.C 
Mar. 5, 2022), ECF No. 3; Indictment, United States v. Hutchins, No. 1:22-cr-00042 (W.D.N.Y Mar. 24, 2022), ECF 
No. 1; Complaint, United States v. Daniel Tisone, No. 2:22-cr-00038 (M.D. Fla. Mar. 30, 2022), ECF No. 3; 

32 
 
 
Indictment, United States v. Rybin, No. 4:22-cr-00056 (S.D. Ga. Apr. 14, 2022), ECF No. 1; Indictment, United 
States v. Israyelyan, No. 2:21-cr-00425 (C.D. Cal. Sept. 10, 2021), ECF No. 1.  
81 111 of the 117 DOJ prosecutions for EIDL fraud involved applications submitted in the first five months 
of the program under the Trump Administration.  
82 Small Business Administration, Disaster Assistance Update Nationwide EIDL Loans (Feb. 1, 2021) 
(online at www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-
19%20Loan%20%20Approvals%20by%20State%2002.01.2021_FOIA-508_0.pdf); Small Business Administration, 
Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL Advances, Supplemental Targeted Advances 
(Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-04/COVID-
19%20EIDL%20TA%20STA_04282022_Public-508.pdf). 
83 Small Business Administration, Office of the Inspector General, Serious Concerns of Potential Fraud in 
EIDL Program Pertaining to the Response to COVID-19 (July 28, 2020) (online at www.sba.gov/document/report-
20-16-serious-concerns-potential-fraud-eidl-program-pertaining-response-covid-19); Small Business 
Administration, Office of the Inspector General, Inspection of Small Business Administration’s Initial Disaster 
Response to Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf). 
84 Government Accountability Office, SBA Has Begun to Take Steps to Improve Oversight and Fraud Risk 
Management (Apr. 20, 2021) (GAO-21-498T) (online at https://gao.gov/assets/gao-21-498t.pdf); Small Business 
Administration, Office of the Inspector General, Top Management and Performance Challenges Facing the Small 
Business Administration Fiscal Year 2022 (Oct. 15, 2021) (online at www.sba.gov/sites/default/files/2021-
10/SBA%20OIG%20Report%2022-02.pdf). 
85 See, e.g., Complaint, United States v. Casutt, No. 2:20-MJ-666-BNW (D. Nev. Aug. 10, 2020), ECF 
No. 1; Complaint, United States v. Williams, No. 1:20-CR-00109-JRH-BKE (S.D. Ga. Nov. 19, 2020), ECF No. 1; 
Complaint, United States v. Jones, No. 3:20CR438 (W.D.N.C. Dec. 16, 2020), ECF No. 1; Complaint, United States 
v. Smith, No. 20CR922 (N.D. Ill. Dec. 17, 2020), ECF No. 1. 
86 See, e.g., Complaint, United States v. Mack, No. 1:20-CR-00104-DHB-BKE (S.D. Ga. Nov. 5, 2020), 
ECF No. 1; Complaint, United States v. Unitan, No. 3:20-MJ-00293 (D. Ore. Dec. 21, 2020), ECF No. 1; 
Complaint, United States v. Zimmerman, No. 2:21-MJ-08050-JSA (D.N.J. Apr. 21, 2021), ECF No. 1; Complaint, 
United States v. Miller, No. 1:21-CR-10228-FDS (D. Mass. July 27, 2021), ECF No. 1. 
87 See, e.g., Complaint, United States v. Pape, et al., No. 5:21-MJ-00007-CMC (E.D. Tex. Jan. 12, 2021), 
ECF No. 1; Complaint, United States v. Lawson, et al., No. 3:21-CR-00006-TCB-RGV (N.D. Ga. Mar. 16, 2021), 
ECF No. 1; Complaint, United States v. Pounds, et al., No. 5:21-CR-00317-PAB (N.D. Ohio Apr. 29, 2021), ECF 
No. 1. 
88 Only about a quarter of the DOJ fraud cases involved EIDLs obtained for real, operational businesses 
that subsequently misused EIDL funds or that inflated revenue and employee numbers to obtain larger awards than 
they were eligible for.   
89 Small Business Administration, SBA Rapid Decision Reference Guide (May 15, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
205.15.20_Redacted.pdf); Small Business Administration, SBA Rapid Decision Reference Guide (Apr. 20, 2021) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
204.20.21_Redacted.pdf). 
90 Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation 
Services (Oct. 4, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf). 
91 Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation 
Services (Oct. 4, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf). 

33 
 
 
92 Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf). 
93 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (July 9, 2021); 48 C.F.R. § 19.502-2.  
94 Small Business Administration, Solicitation/Contract/Order for Commercial Items (Dec. 14, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Briefing by Staff, Small Business Administration, 
to Staff, Select Subcommittee on the Coronavirus Crisis (July 9, 2021). 
95 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).  
96 Contractor Performance Assessment Reports, RER Solutions, Inc. (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Contractor%20Assessment%20
Reports%20all%20produced_Redacted.pdf). 
97 RER Solutions, Inc., Excerpt of Subcontract Agreement (Apr. 1, 2019) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Solutions%20Inc.%20Excerpt%
20of%20Subcontract%20Agreement_Redacted.pdf); Small Business Administration, Office of Inspector General, 
Evaluation of SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at 
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf); Rocket Companies, Securities 
and Exchange Commission Form 10-K (Mar. 1, 2022) (online at https://ir.rocketcompanies.com/financials/sec-
filings/default.aspx); Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for 
Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at 
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf).  
98 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf). 
99 Small Business Administration, Office of Inspector General, Inspection of Small Business 
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at 
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).  
100 Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf); Small Business 
Administration, Office of Inspector General, Inspection of Small Business Administration’s Initial Disaster 
Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf).  
101 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Inspection of 
Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) 
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf). 
102 Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted%20%23.pdf  ); Small Business 
Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster Assistance Loan 
Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); 48 C.F.R. § 19.502-2.  

34 
 
 
103 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf). 
104 Id.  
105 Id.  
106 15 U.S.C. § 657s; 13 C.F.R. § 125.6. 
107 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Email from Chief Executive Officer, RER Solutions, Inc., to Senior 
Loan Officer, Small Business Administration (Mar. 20, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf). 
108 In 2021, SBA modestly increased the contract’s ceiling to $800 million to complete COVID EIDL 
processing services. USASpending, Contract Summary RER Solutions, Inc. (online at 
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20, 
2022).  Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).  
109 Coronavirus Contracts Tracking Federal Purchases to Fight the Coronavirus, ProPublica (online at 
https://projects.propublica.org/coronavirus-contracts/contracts) (accessed May 19, 2022); USASpending, Contract 
Summary RER Solutions, Inc. (online at 
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20, 
2022).  
110 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (July 9, 2021). 
111 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).  
112 Small Business Administration, Contractor Performance Assessment Report (Oct. 29, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Contractor%20Performance%20Assessm
ent%20Report%20RER%20EIDL_Redacted.pdf); Small Business Administration, Solicitation/Contract/Order for 
Commercial Items (Dec. 14, 2018) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Small Business Administration, Amendment of 
Solicitation/Modification of Contract (May 15, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf). 
113 Small Business Administration, Contractor Performance Assessment Report (Oct. 29, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Contractor%20Performance%20Assessm
ent%20Report%20RER%20EIDL_Redacted.pdf). 
114 Id. 
115 Email from Chief Technology Officer, Rapid Financial Services, LLC, to Chief Executive Officer, RER 
Solutions, Inc. (Apr. 13, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Rapid%20CTO%20to%20RER
%20CEO%204.13.20_Redacted.pdf).  
116 Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf); Letter from 

35 
 
 
Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and 
Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf). 
117 Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 11, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); Letter from Counsel, Rapid Financial Services, LLC, to Chairman James E. 
Clyburn, Select Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small 
Business (Mar. 7, 2021) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2021-
03-07%20Rapid%20Finance%20Letter%20highlighted.pdf); Rocket Loans Specific Responses to Committees’ 
Document Requests (Feb. 25, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Exhibit%20A%20-
%20Rocket%20Loans%20Response%20to%20Subcommittee%202.25.2021%20Rocket%2020%20employees.pdf). 
118 Email from Counsel, RER Solutions, Inc., to Staff, Select Subcommittee on the Coronavirus Crisis (July 
2, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20from%20Cousel%20RER%20t
o%20SSCC%207.2.21_Redacted.pdf). 
119 Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020) 
(online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf). 
120 Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf). 
121 Government Accountability Office, Economic Injury Disaster Loan Program:  Additional Actions 
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at 
www.gao.gov/assets/gao-21-589.pdf). 
122 SBA dramatically increased its number processing staff and contractors at a salary range that suggests 
the costs were hundreds of millions of dollars.  Government Accountability Office, Economic Injury Disaster Loan 
Program:  Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July 
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); USAJOBS, Loan Specialist (General) – 
Virtual, Small Business Administration, Office of Disaster Assistance (ODA) Processing and Disbursement Center 
(PDC) (online at www.usajobs.gov/job/563879000) (accessed May 20, 2022).  
123 The precise numbers, based on invoices and information provided by the companies are a total of 
$738,294,057.09 paid by SBA to RER, with $232,931,265.65 paid to and kept by Rocket, and $148,024,480.79 paid 
to Rapid. Cite all invoices and Rapid’s 3.7.21 letter.  RER Solutions, Inc. Invoices to SBA Office of Disaster 
Assistance, Contract 73351019D0001 (May 11, 2020 - Feb. 1, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf). 
124 Letter from Counsel, Rapid Financial Services, LLC, to Chairman James E. Clyburn, Select 
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 
7, 2021) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2021-03-
07%20Rapid%20Finance%20Letter%20highlighted.pdf); Letter from Counsel, Rocket Loans, to Chairman James E. 
Clyburn, Select Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small 

36 
 
 
Business (Nov. 24, 2020) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-
11-24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf). 
125 RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract 73351019D0001 (May 11, 
2020 - Feb. 1, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf); Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 11, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); Small Business Administration, Office of Inspector General, Evaluation of 
SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at 
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf). 
126 Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the 
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf); Letter from 
Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and 
Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf). 
127 Rapid, as a subcontractor to subcontractor Rocket, sent its invoices to Rocket.  Rocket then sent its 
invoices to RER.  Consequently the “hard costs” in Rocket’s invoices to RER duplicate third party processing fees 
that were actually paid by Rapid. Email from Counsel, RER Solutions, Inc., to Staff, Select Subcommittee on the 
Coronavirus Crisis (July 2, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20from%20Cousel%20RER%20t
o%20SSCC%207.2.21_Redacted.pdf); RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract 
73351019D0001 (May 11, 2020 - Feb. 1, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf). 
128 After repeated requests that Rocket identify the number of employees that contributed to its work on the 
COVID-19 EIDL contract, Rocket stated that “at least” 20 employees contributed and included its executives (who 
presumably divided their time substantially between the SBA contract and other company matters) in the list of 
identified employees.  The Select Subcommittee sees no indication in the documents produced that significantly 
more than 20 Rocket employees contributed, and the company’s inability to identify other employees beyond those 
20 strongly suggest any additional employees who worked on the COVID-19 EIDL contract did not make 
significant contributions.  Rocket Loans Specific Responses to Committees’ Document Requests (Feb. 25, 2021) 
(online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Exhibit%20A%20-
%20Rocket%20Loans%20Response%20to%20Subcommittee%202.25.2021%20Rocket%2020%20employees.pdf). 
129 RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract 73351019D0001 (May 11, 
2020 - Feb. 1, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at 

37 
 
 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf). 
130 Rocket Companies, Securities and Exchange Commission Form 10-K (Mar. 1, 2022) (online at 
https://ir.rocketcompanies.com/financials/sec-filings/default.aspx). 
131 Id. 
132 Id.  
133 See, e.g., Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small 
Business Administration (Mar. 30, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted%20%23.pdf). 
134 Chief Executive Officer, RER Solutions, Inc., to Senior Procurement Executive and Head of the 
Contracting Activity, Office of the Chief Financial Officer, Small Business Administration (Apr. 22, 2020) (online 
at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/cricizing%20RER%20asking%20it%20as
sert%20that%20it%20is%20the%20prime%201.27.2022.set%205%2027-29_Redacted.pdf). 
135 Id. 
136 F.A.R. Part 42.02(e)(2); Chief Executive Officer, RER Solutions, Inc., to Senior Procurement Executive 
and Head of the Contracting Activity, Office of the Chief Financial Officer, Small Business Administration (Apr. 
22, 2020) (online at 
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/cricizing%20RER%20asking%20it%20as
sert%20that%20it%20is%20the%20prime%201.27.2022.set%205%2027-29_Redacted.pdf). 
137 Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus 
Crisis (July 9, 2021). 
138 Id. 
139 Id.; 13 C.F.R. § 125.6. 
140 15 U.S.C. § 657s; 13 C.F.R. § 125.6. 
141 13 C.F.R. § 125.6. 
142 Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster 
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf). 
143 F.A.R. Part 15.402. 
144 Small Business Administration, SBA’s Handling of Identity Theft In the COVID-19 Economic Injury 
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).

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