The 2021 fee schedule paid lenders $8.74 billion more than the 2020 rules would have

SBA paid PPP lenders $38.236 billion to originate 11.47 million loans. Most of that came in the second year, after a rule change tripled the fee on the smallest loans. Rerun the 2021 cohort under the leaner 2020 schedule and the fee bill for that year falls $8.74 billion — the measured price of the change, computed loan by loan. These are SBA's published fee schedules applied loan by loan to its loan file; SBA has not published what it actually paid each lender.

The fee lenders earned for making a PPP loan was set by a schedule, not a market. In 2020 that schedule was tiered by loan size and it fell as the loan grew: 5% on a loan of $350,000 or less, 3% on a loan above $350,000 and under $2 million, 1% on a loan of $2 million or more — the rate applied to the whole loan, not to slices of it. For loans made on or after December 27, 2020, section 340 of the Economic Aid Act rewrote the bottom tier to steer money at the smallest borrowers — on loans of $50,000 or less, the lesser of 50% of the loan or $2,500 in place of a flat 5%, with the tiers above $50,000 left alone. The rewrite made small loans far more profitable to originate and far more expensive for the government.

1. The bill, by year — and the counterfactual

The 2020 program disbursed more money but paid less in fees, because its schedule paid little on big loans and there were fewer tiny ones. The 2021 cohort was the reverse: smaller loans on average, under a schedule built to reward exactly that. Applying 2020's schedule to 2021's actual loans, the fee bill for 2021 drops from $20.07B to $11.33B, a $8.74 billion difference that is entirely the schedule change.

Same borrowers, same loan amounts, a different rulebook: the 2021 fee schedule is worth $8.74 billion.

2. Where the gap lives: the smallest loans

The gap is concentrated in loans of $50,000 or less, the segment the 2021 schedule was rewritten to favor. On a sub-$50,000 loan the average fee roughly tripled between the two schedules, from about $775 under 2020's rules to about $2,329 under 2021's. Multiply that by the 5.5 million small loans the 2021 cohort produced and the small-loan fee bill jumps from $4.25B to $12.76B.

3. Read the two schedules side by side

For a loan under $50,000 — the size a fee-per-loan lender wants to write as many of as possible — the 2020 rules paid a flat 5%; the 2021 rules paid the lesser of 50% of the loan or $2,500, which sits far above 5% until the two schedules meet at $50,000. The fees on the biggest loans barely moved.

4. The whole program, reconciled

Summing every loan's fee under the schedule it was actually paid under gives $38.236 billion on 11,468,206 loans and $792.6 billion disbursed — an effective rate of 4.82%. The two-year split is $18.17B in 2020 and $20.07B in 2021; the counterfactual reprices only the 2021 half.

Method & caveats

Every fee here is recomputed from the loan-level PPP file. Each loan is assigned to its vintage by approval date, then priced under the origination-fee schedule in force that year; the "counterfactual" column simply prices the 2021 loans under the 2020 schedule instead. Second Draw loans were paid under their own schedule: the lesser of 50% of the loan or $2,500 on loans of $50,000 or less, 5% above that through $350,000, and 3% above $350,000, with no 1% tier, because second draws were capped at $2 million (86 FR 3712). Each loan here is priced under the schedule that governed it, so a second-draw loan at the $2 million cap is paid 3%, not 1%. The reconciliation to $38.236 billion is the check that the schedule logic is right. The counterfactual answers one narrow question — what the 2021 fee rules cost, holding the loans fixed — and nothing about whether those loans should have been made.