Interactive

Where the fee money went

PPP lender processing fees, from the SBA to the 25 lenders that earned the most, to the companies those lenders paid, and onward where the records show it. Choose any lender, aggregator or recipient to see only its money, upstream and downstream. Each flow shows its amount, its evidence status and its source.

Year

20202021Both

Example: SBA → Lendistry → Harvest Small Business Finance → Womply

Selecting Lendistry shows one lender's fees end to end: the SBA fee, the servicing link to Harvest Small Business Finance, Harvest Small Business Finance's payments to Womply, and what Womply did with its receipts. The route is marked in yellow.

SBA → Lendistry: $521.1M · modeled
Lendistry → Harvest Small Business Finance: a link (loan servicing; loan purchase); any payment: amount and payer unknown (?).
Harvest Small Business Finance → Womply: $1.03B · documented

Legend

Transfer, documented (width = amount)
Transfer, reported (hatched)
Transfer, modeled (lighter)
Transfer, arithmetic from documented figures
Range: inner band = low end, outer band = high end
Relationship (contract, servicing, ownership): no money drawn
Unknown amount or untraced (dotted, ?)
Where the fee money sits (dotted box under a lender), tagged documented a record names where the money went; disclosed in aggregate the lender gives PPP income figures, no separate use; not broken out PPP fees appear only in words
Documented zero (hairline, $0)
Amount recorded but not comparable: thin grey line, not to scale (amount in its box or its details)
Unexplained (reconciliation item): a residual, never a transfer
Example route (yellow), when the example is selected

Top 25 lenders by gross SBA processing fees, and where the fees went

Width: fee dollars and onward payments, one scale for this panel only. Relationships are dashed and have no width; dotted stubs with ? mark flows the records do not trace. A dotted box under a lender names where its fee money sits, tagged by the evidence (see the legend). In this view Womply receives $1.95B: the collected fees of the 5 top-25 lenders that paid it. Womply's own per-payer table (to Apr. 14, 2022) shows $2.01B collected from 15 payers. The other $59.6M came from payers outside the top 25: DreamSpring $25.2M; SmartBiz Loans $22.3M; Sunshine State Economic Development $10.3M; Funding Circle $1.3M; 5 smaller payers (Lendio, Fundbox, TMC Financing, On Deck Capital, Kabbage) $511K; Blueacorn $0. Select Womply to see all 15.

Unexplained amounts: reconciliation items (never drawn as transfers)

What is left once the fees are traced loan by loan, and why. These are reconciliation items, not payments to anyone.

Short answer

Every dollar of Womply's documented cash, $2,008,556,579.88 collected to Apr. 14, 2022, is tied to a named payer.
Two parts of it are not backed by contract terms on the loans. Harvest paid $250.4M-$270.4M beyond its own loans' contract fees; the referral-fee arithmetic ties that money to the 189,259 Lendistry loans Harvest serviced. Another $61.3M came from payers whose contracts are not in the record.
Revenue exceeds collections by $86.65M. The unpaid Benworth award could account for all of it except $0.35M, but that is a possible explanation, not an established one.
Three amounts remain that no document explains: Harvest's reported SBA receipts exceed the statutory fees on its own loans by $111.3M; the closing-cash gap is $105.19M; and $0.35M of revenue over collections.
Unknown, not unexplained: the cash outcomes of the Benworth award ($86.30M of fees plus charges), the Blueacorn claim ($76.71M) and the Fountainhead claim (over $90M).

Reconciliation items
What it is	Amount	Kind	Why it remains
Money Harvest paid Womply beyond the contract fees on Harvest's own loans	$250,389,759.66 (no discount) to $270,389,759.66 ($20M discount)	explained by our inference, not by a contract	The referral fees Harvest paid ($95,031,459.27) equal 1% of the principal of Harvest's own Fast Lane loans plus the Lendistry loans it serviced ($94,710,106.44), so this looks like Womply's fees on the Lendistry loans. No contract covering those loans is in the record.
Benworth: fees the arbitrator awarded that were unpaid at Apr. 14, 2022	$86,299,892 fees (plus $25,363,697.68 finance charges, $5,883,708.58 attorneys' fees, $372,956.46 costs)	unpaid; decided in arbitration; cash outcome unknown	The case settled on Jan. 2, 2025 on confidential terms. The $65,373,490 by which Womply's claim exceeded the award is not owed.
Fountainhead: contract fees above what Womply collected	$42,198,982.26, or $22.2M after the full $20M early-pay discount; any API fee under the unpublished order form is extra	disputed; outcome unknown	Womply said it was owed "over $90 million", and Fountainhead said it had paid "greater than 80%" of that claim. The outcome of the arbitration is not in the record.
Capital Plus, through Blueacorn: claimed, nothing collected	$76,714,482.67	disputed; settled Nov. 14, 2022, amount not public	The claimed amount follows the contract formula exactly. The settlement amount is not public.
Cash from payers whose contracts are not in the record	DreamSpring $25,177,391.25; Sunshine $10,297,907.68; TMC $33,000.00; referral-only $25,814,931.28	payer known, terms unknown	DreamSpring's payments equal 54.6% of the statutory fees on its loans in the partnership window, and Sunshine State's 87.1%. TMC has no loans under its name in the SBA file.
Womply's revenue above its collections at Apr. 14, 2022	$86,652,649.73; after the Benworth candidate, $352,757.73	timing; our inference	Womply reports revenue net of discounts and disputed amounts, so it can include money not yet received. Its receivables are not in the record.
Harvest's reported SBA receipts above the statutory fees on its own loans	$111,317,945.13 (2021 loans); $72,276,016.62 (2020+2021)	a question about Harvest's figures, not Womply cash	Harvest's letter does not define the period or which loans it counted. The gap may be fees on Lendistry loans Harvest bought, but the record cannot settle it.
Harvest paid Womply more than its SBA receipts minus what it kept	$272,436,148.00	the same money as the first row; do not add it	Harvest's letter gives its receipts and the share it kept; Womply's table gives what Harvest paid. The difference is the Lendistry-loan money in the first row.
Closing cash not accounted for	$105,187,422.70	a gap between two balances	Womply's cash figure before the transfer and Atlas's figure for cash kept after closing come from opposing parties at different moments. The funds-flow exhibit is not in any record.
Loans in the count with weak or low attribution	31,822 loans (2.5%), about $94.2M statutory fees	how confidently loans are assigned to Womply	They are mostly Harvest loans under $5,000 made after Apr. 21 (12,034) and Lendistry loans it serviced itself (13,948). Little or no documented Womply money is tied to them.

Amounts are exact where the records give them; ranges show the effect of the $20M early-payment discount.

Corporate bridge: Womply's company cash (flows and stocks kept apart)

Flows are amounts over a period: revenue, costs, income, collections. Stocks are balances at a moment: cash at the closing, the escrow. They are never added to each other, distributions are never counted as earnings, and none of them is drawn as a width.

Flows

Flows: fiscal year 2021, from Womply's letter of May 20, 2022 (page numbers refer to the House Womply document release)
Line	Amount	Status
PPP referral fee revenue, 2021	$190,530,753.00	documented
PPP technology service revenue, 2021, net of early-payment discounts and disputed revenue	$1,901,743,577.89	documented
Total PPP net revenue, 2021	$2,092,274,330.89	documented
Gross revenue, whole business	$2,104,300,000	documented
Revenue not from PPP	$12,025,669.11	our arithmetic
Cost of revenue	$261,166,000	documented
Gross profit, as stated	$1,843,135,000	documented
Operating expenses	$160,692,000	documented
"Other income expenses" (what it contains is not stated)	$379,289,000	documented
Net income, as stated	$1,303,153,000	documented

Status: documented = a record states it; our arithmetic = calculated from the figures shown; one party's figure = stated by one side of a dispute; unknown = no record gives it.

Womply's letter adds up once gross profit is taken as gross revenue minus cost of revenue: net income is then exactly $1,303,153,000.

Collections: a different flow from revenue
Line	Amount	Status	Note
PPP revenue, 2020 and 2021	$2,095,209,229.61	documented	Of which 2020: $2,934,898.72.
Fees collected "to date" by payer, at Apr. 14, 2022	$2,008,556,579.88	documented	Covers 2020, 2021 and early-2022 receipts on 2020-21 loans.
Revenue not yet collected	$86,652,649.73	our arithmetic	Possibly the Benworth receivable: the arbitrator's $86,299,892.
Cash collected during calendar 2021	—	unknown
Collections after Apr. 14, 2022, including the Benworth, Blueacorn and Fountainhead outcomes	—	unknown

Womply's letter calls its $2.09B figure collected, but it matches Womply's revenue table. The per-payer collections at Apr. 14, 2022 are $2.01B. Neither is a billed figure.

Stocks

Stocks at the December 2021 closing, from the Atlas Technology Group v. Oto Analytics interim award, July 10, 2023
Line	Amount	Status	Note
Cash on the balance sheet at the closing, by Womply's reading	$1,413,347,000	one party's figure	Of which "generated by Womply's operations": $1,413,287,000.
Allocated to selling shareholders, before escrow contributions	$1,090,984,577.30	documented
Of which deposited in the Secondary Escrow Fund	$630,720,000	documented	Part of the allocation above, not added to it.
Most of the allocation that could have been left outside that escrow	$460,264,577.30	our arithmetic	A ceiling, not a verified payment.
Cash kept by the surviving company, by Atlas's figure	$217,175,000	one party's figure
Closing cash not accounted for	$105,187,422.70	our arithmetic	The two cash figures come from opposing parties at different moments.
Verified closing payments to shareholders, escrow releases and remaining escrow	—	unknown

Flows and stocks side by side

Womply's 2021 net income ($1,303,153,000) is a full-year flow. The closing cash is a balance in December 2021, before the year ended; it exceeds the net income by $110,194,000, and nothing in the record bridges the two.
The shareholder allocation is paid out of the closing cash. It is not income, and the escrow is part of it.
Awards against the surviving company are claims, not cash: FTC $26,000,000 (Apr. 3, 2024) and Atlas $34,866,758.99 to Aug. 11, 2023. Which funds paid them is unknown.
No 2021 income tax figure exists in any record.

The House Subcommittee's Womply document release is on this site: Womply batched documents (House release).

Bridge by lender: SBA fees to Womply contract fees, cash collected, unpaid amounts and residual

All 2021 loans that can be tied to Womply, by lender. SBA fees and contract fees apply the published schedules and contract terms to the SBA loan data; collected amounts are Womply's own table of Apr. 14, 2022. A residual is a reconciliation item, not a payment.

Bridge by lender
Lender	SBA processing fees	Loans	Womply fees under the contract	Collected by Apr. 14, 2022	Unpaid or disputed	Residual (collected minus entitlement)
Harvest	$930,658,635.24 · modeled	Harvest's own Fast Lane loans	$777,671,663.14 · modeled	$1,028,061,422.80 · documented		$250,389,759.66 · our arithmetic
Harvest	$32,931,363.35 · modeled	Harvest's other 2021 loans	$8,136,799.68 · modeled
Benworth	$686,007,833.64 · modeled	Benworth loans in Womply's partnership window	$623,947,551.69 · modeled	$464,991,236.65 · documented	awarded unpaid fees $86,299,892; claim excess rejected $65,373,490 · as stated in the records	$-86,300,142.35 · our arithmetic
Fountainhead	$620,473,019.10 · modeled	Fountainhead loans in Womply's partnership window	$496,379,672.48 · modeled	$454,180,690.22 · documented	Womply claimed over $90,000,000 unpaid (Sept. 2021) under the Agreement 'and a separate contract'; JAMS 1100-111-808 outcome unknown · as stated in the records	$-42,198,982.26 · our arithmetic
Fountainhead	$4,624,822.99 · modeled	Fountainhead loans before Feb. 9, 2021
Capital Plus	$205,109,847.22 · modeled	Capital Plus loans in Womply's partnership window	$84,045,085.07 · modeled	$0.00 · documented	$76,714,482.67 claimed; settled at mediation Nov. 14, 2022, amount not public · as stated in the records	$-76,714,482.67 · our arithmetic
Lendistry	$473,141,201.00 · modeled	Lendistry loans serviced by Harvest		0 as a named payer (no Lendistry row) · documented
Lendistry	$39,301,092.45 · modeled	Lendistry loans it serviced itself
DreamSpring	$46,102,191.30 · modeled	DreamSpring loans in Womply's partnership window		$25,177,391.25 · documented
Sunshine State	$11,821,162.48 · modeled	Sunshine State loans in Womply's partnership window		$10,297,907.68 · documented
TMC Financing		no identifiable loans		$33,000.00 · documented
Referral-only partners		no identifiable loans		$25,814,931.28 · documented

Status: modeled = the published fee schedule or contract terms applied to each SBA loan; documented = a record states it; our arithmetic = calculated from the figures shown.

Source: the records cited on each flow: court filings, the House Subcommittee's document releases and report, SBA loan data, company filings and Justice Department releases. Compiled: Sept. 27, 2026. Units: U.S. dollars as recorded; ranges shown low to high. Scope: PPP lender processing fees in 2020 and 2021, and where the records show the recipients sent them. Loan principal and guarantees are not fee flows and are not drawn. Widths are comparable only within one panel. Nothing is balanced: an amount that is not recorded is shown as unknown, never as zero.

The data behind the chart

The table lists every flow in the data, drawn or not. When one party is selected, it lists only that party's flows.

Download the data:

Every flow

Every flow in the data (203 entries)
Id in the downloads	From	To	Flow type	Amount · status	Date or period	Status	Basis	What it represents	The record says	In the chart	Sources
E-SBA-BOFA-2020	SBA	Bank of America	fee	$946,528,326.30 · modeled	2020	modeled	owed	SBA PPP processing fees on Bank of America, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Bank of America, National Association'; 2020 approvals
E-SBA-BOFA-2021	SBA	Bank of America	fee	$544,610,351.50 · modeled	2021	modeled	owed	SBA PPP processing fees on Bank of America, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Bank of America, National Association'; 2021 approvals
E-SBA-BENWORTH-2020	SBA	Benworth Capital Partners	fee	$1,139,891.01 · modeled	2020	modeled	owed	SBA PPP processing fees on Benworth Capital's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Benworth Capital'; 2020 approvals
E-SBA-BENWORTH-2021	SBA	Benworth Capital Partners	fee	$696,269,537.02 · modeled	2021	modeled	owed	SBA PPP processing fees on Benworth Capital's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Benworth Capital'; 2021 approvals
E-SBA-BENWORTH-WOMPLYLOANS-REP	SBA	Benworth Capital Partners	fee	$680,000,000 · reported	2021	reported	paid			not drawn: another measure of the SBA → Benworth Capital Partners flow; shown with it, never added	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, award p. 30 (ECF p. 30 of 74): Benworth's position, '$680 million in lender processing fees that it has received from the SBA'; D.P.R. complaint para. 124: 'more than $680 million' on 305,790 Womply-referred loans
E-SBA-CAPPLUS-2021	SBA	Capital Plus Financial, LLC	fee	$937,325,953.93 · modeled	2021	modeled	owed	SBA PPP processing fees on Capital Plus Financial, LLC's 2021 loans		not drawn: another measure of the SBA → Capital Plus Financial, LLC flow; shown with it, never added	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Capital Plus Financial, LLC'; 2021 approvals
E-SBA-CAPPLUS-2021-DOC	SBA	Capital Plus Financial, LLC	fee	$929,229,749 · documented	FY2021-FY2023 (fiscal years to Oct. 31)	documented	recognized	Disclosed SBA PPP processing fees, Capital Plus Financial, LLC, 2021 loans		drawn	Crossroads FY2021 annual disclosure (PPP administrative fees $868,422,947) + Crossroads Impact Corp FY2023 audited statements (FY2022 $50,774,445; FY2023 $10,032,357); on-site: https://pandemicdarlings.com/court-filings/crossroads-capital-plus-otc-filings/2022-01-01-crossroads-fy2021-annual-disclosure/ and https://pandemicdarlings.com/source-documents/crossroads-impact-corp-fy2023-audited-consolidated-financials/. About $10.6M was still deferred at FY2023 (lifetime about $939.8M); model $937.3M. All loans approved in 2021.
E-SBA-CAPPLUS-FY2021-DOC	SBA	Capital Plus Financial, LLC	fee	$868,422,947 · documented	fiscal year Nov. 1, 2020 - Oct. 31, 2021	documented	owed			not drawn: another measure of the SBA → Capital Plus Financial, LLC flow; shown with it, never added	Crossroads Systems, Inc. OTC annual disclosure FY2021 (fiscal year ended Oct. 31, 2021), audited statements, statement of operations: 'PPP administrative fees 868,422,947'
E-SBA-CAPPLUS-WOMPLYLOANS-REP	SBA	Capital Plus Financial, LLC	fee	$186,882,948 · reported	2021	reported	paid			not drawn: another measure of the SBA → Capital Plus Financial, LLC flow; shown with it, never added	First Amended Complaint, Oto Analytics, Inc. d/b/a Womply v. Capital Plus Financial, LLC, Crossroads Systems, Inc., Eric Donnelly, BA Fin Orion, LLC d/b/a Blueacorn and Barry Calhoun, N.D. Tex. 3:21-cv-02636 Doc. 20 (Dec. 23, 2021), para. 76 ('on information and belief'); 86,521 Womply-referred loans, para. 72
E-SBA-CELTIC-2020	SBA	Celtic Bank	fee	$175,176,125.46 · modeled	2020	modeled	owed	SBA PPP processing fees on Celtic Bank Corporation's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Celtic Bank Corporation'; 2020 approvals
E-SBA-CELTIC-2021	SBA	Celtic Bank	fee	$57,882,816.29 · modeled	2021	modeled	owed	SBA PPP processing fees on Celtic Bank Corporation's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Celtic Bank Corporation'; 2021 approvals
E-SBA-CITIZENS-2020	SBA	Citizens Bank	fee	$165,617,686.57 · modeled	2020	modeled	owed	SBA PPP processing fees on Citizens Bank, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Citizens Bank, National Association (locations 434162 Providence RI; 70644 Abilene TX)'; 2020 approvals
E-SBA-CITIZENS-2021	SBA	Citizens Bank	fee	$127,551,114.10 · modeled	2021	modeled	owed	SBA PPP processing fees on Citizens Bank, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Citizens Bank, National Association (locations 434162 Providence RI; 70644 Abilene TX)'; 2021 approvals
E-SBA-CROSSRIVER-2020	SBA	Cross River Bank	fee	$293,983,258.23 · modeled	2020	modeled	owed	SBA PPP processing fees on Cross River Bank's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Cross River Bank'; 2020 approvals
E-SBA-CROSSRIVER-2021	SBA	Cross River Bank	fee	$740,634,868.77 · modeled	2021	modeled	owed	SBA PPP processing fees on Cross River Bank's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Cross River Bank'; 2021 approvals
E-SBA-CUSTOMERS-2020	SBA	Customers Bank	fee	$111,456,266.81 · modeled	2020	modeled	owed	SBA PPP processing fees on Customers Bank (Customers Bancorp)'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Customers Bank'; 2020 approvals
E-SBA-CUSTOMERS-2021	SBA	Customers Bank	fee	$446,751,151.18 · modeled	2021	modeled	owed	SBA PPP processing fees on Customers Bank (Customers Bancorp)'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Customers Bank'; 2021 approvals
E-SBA-DREAMSPRING-2020	SBA	DreamSpring	fee	$3,459,230.90 · modeled	2020	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'DreamSpring' (fees_PPP1)
E-SBA-DREAMSPRING-2021	SBA	DreamSpring	fee	$50,763,985.34 · modeled	2021	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'DreamSpring' (fees_PPP2_FD + fees_PPP2_SD)
E-SBA-FIFTHTHIRD-2020	SBA	Fifth Third Bank	fee	$165,922,643.53 · modeled	2020	modeled	owed	SBA PPP processing fees on Fifth Third Bank's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Fifth Third Bank (locations 58036, 58039, 58063, all Cincinnati OH)'; 2020 approvals
E-SBA-FIFTHTHIRD-2021	SBA	Fifth Third Bank	fee	$106,823,311.88 · modeled	2021	modeled	owed	SBA PPP processing fees on Fifth Third Bank's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Fifth Third Bank (locations 58036, 58039, 58063, all Cincinnati OH)'; 2021 approvals
E-SBA-FOUNTAINHEAD-2020	SBA	Fountainhead SBF	fee	$15,524,081.15 · modeled	2020	modeled	owed	SBA PPP processing fees on Fountainhead SBF LLC's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Fountainhead SBF LLC'; 2020 approvals
E-SBA-FOUNTAINHEAD-2021	SBA	Fountainhead SBF	fee	$625,097,842.09 · modeled	2021	modeled	owed	SBA PPP processing fees on Fountainhead SBF LLC's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Fountainhead SBF LLC'; 2021 approvals
E-SBA-FUNDBOX-2020	SBA	Fundbox	fee	$14,643,362.52 · modeled	2020	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'Fundbox, Inc.' (fees_PPP1)
E-SBA-FUNDINGCIRCLE-2020	SBA	Funding Circle	fee	$13,730,330.12 · modeled	2020	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'FC Marketplace, LLC (dba Funding Circle)' (fees_PPP1)
E-SBA-FUNDINGCIRCLE-2021	SBA	Funding Circle	fee	$29,162,916.82 · modeled	2021	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'FC Marketplace, LLC (dba Funding Circle)' (fees_PPP2_FD + fees_PPP2_SD)
E-SBA-HARVEST-2020	SBA	Harvest Small Business Finance	fee	$39,041,928.51 · modeled	2020	modeled	owed	SBA PPP processing fees on Harvest Small Business Finance, LLC's 2020 loans		not drawn: another measure of the SBA → Harvest Small Business Finance flow; shown with it, never added	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Harvest Small Business Finance, LLC'; 2020 approvals
E-SBA-HARVEST-2021	SBA	Harvest Small Business Finance	fee	$963,589,998.59 · modeled	2021	modeled	owed	SBA PPP processing fees on Harvest Small Business Finance, LLC's 2021 loans		not drawn: another measure of the SBA → Harvest Small Business Finance flow; shown with it, never added	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Harvest Small Business Finance, LLC'; 2021 approvals
E-SBA-HARVEST-FY2021-DOC	SBA	Harvest Small Business Finance	fee	$1,074,907,943.72 · documented	all PPP loans (2020-2021)	documented	paid	SBA fees received, all PPP loans (documented total)		drawn	Locke Lord (for Harvest Small Business Finance, LLC) letter to Chairman Clyburn, Aug. 31, 2022, p. 3, resp. 4(a): 'SBA paid Harvest $1,074,907,943.72 in fees from the SBA for PPP loans for which it was the lender' (House Select Subcommittee release 'Criminal_Section_Batched_Docs_With_Redactions.pdf'; Womply ledger edge the SBA → Harvest Small Business Finance entry of $1,074,907,944). Exceeds the model's $1,002.6M by $72.3M, unexplained.
E-HARVEST-RETAINED	SBA	Harvest Small Business Finance	retained	$319,282,668.92 · documented	FY2021	documented	retained			not drawn: another measure of the SBA → Harvest Small Business Finance flow; shown with it, never added	House Select Subcommittee document release 'Criminal_Section_Batched_Docs_With_Redactions.pdf': Locke Lord (for Harvest Small Business Finance, LLC) letter to Chairman Clyburn, Aug. 31, 2022 (external), Harvest letter p. 3: 'Harvest ultimately retained $319,282,668.92 in fees from the SBA'
E-SBA-ITRIA-2020	SBA	Itria Ventures	fee	$5,823,161.98 · modeled	2020	modeled	owed	SBA PPP processing fees on Itria Ventures LLC (Biz2Credit affiliate)'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Itria Ventures LLC'; 2020 approvals
E-SBA-ITRIA-2021	SBA	Itria Ventures	fee	$467,581,644.08 · modeled	2021	modeled	owed	SBA PPP processing fees on Itria Ventures LLC (Biz2Credit affiliate)'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Itria Ventures LLC'; 2021 approvals
E-SBA-JPMORGAN-2020	SBA	JPMorgan Chase Bank	fee	$1,033,208,375.08 · modeled	2020	modeled	owed	SBA PPP processing fees on JPMorgan Chase Bank, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'JPMorgan Chase Bank, National Association (location IDs 194093 Chicago IL, 48270 Columbus OH)'; 2020 approvals
E-SBA-JPMORGAN-2021	SBA	JPMorgan Chase Bank	fee	$666,975,043.33 · modeled	2021	modeled	owed	SBA PPP processing fees on JPMorgan Chase Bank, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'JPMorgan Chase Bank, National Association (location IDs 194093 Chicago IL, 48270 Columbus OH)'; 2021 approvals
E-SBA-KABBAGE-2020	SBA	Kabbage	fee	$145,997,287.22 · modeled	2020	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'Kabbage, Inc.' (fees_PPP1)
E-SBA-KABBAGE-2021	SBA	Kabbage	fee	$42,100,929.05 · modeled	2021	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'Kabbage, Inc.' (fees_PPP2_FD + fees_PPP2_SD)
E-SBA-KEYBANK-2020	SBA	KeyBank	fee	$244,007,549.84 · modeled	2020	modeled	owed	SBA PPP processing fees on KeyBank N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'KeyBank National Association'; 2020 approvals
E-SBA-KEYBANK-2021	SBA	KeyBank	fee	$135,287,186.12 · modeled	2021	modeled	owed	SBA PPP processing fees on KeyBank N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'KeyBank National Association'; 2021 approvals
E-SBA-LENDISTRY-2020	SBA	Lendistry	fee	$8,639,905.97 · modeled	2020	modeled	owed	SBA PPP processing fees on BSD Capital, LLC dba Lendistry's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'BSD Capital, LLC dba Lendistry'; 2020 approvals
E-SBA-LENDISTRY-2021	SBA	Lendistry	fee	$512,442,293.45 · modeled	2021	modeled	owed	SBA PPP processing fees on BSD Capital, LLC dba Lendistry's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'BSD Capital, LLC dba Lendistry'; 2021 approvals
E-SBA-LENDISTRY-2021-HARVESTSERVICED	SBA	Lendistry	fee	$473,141,201 · modeled	2021 (approved 2021-05-22 to 2021-06-29)	modeled	owed			not drawn: another measure of the SBA → Lendistry flow; shown with it, never added	SBA FOIA data, Lendistry-originated loans by servicer and approval date (our count), 189,259 loans, principal $3,376,670,384.00; ServicingLenderName = Harvest Small Business Finance, LLC
E-SBA-LENDISTRY-2021-OWNSERVICED	SBA	Lendistry	fee	$39,301,092.45 · modeled	2021 (Jan.-July)	modeled	owed			not drawn: another measure of the SBA → Lendistry flow; shown with it, never added	SBA FOIA data, Lendistry-originated loans by servicer and approval date (our count), 13,948 loans, principal $434,856,653.50; ServicingLenderName = Lendistry SBLC, LLC
E-SBA-MTBANK-2020	SBA	Manufacturers and Traders Trust Company	fee	$206,295,480.58 · modeled	2020	modeled	owed	SBA PPP processing fees on Manufacturers and Traders Trust Company (M&T Bank)'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Manufacturers and Traders Trust Company (location 46391 Buffalo NY)'; 2020 approvals
E-SBA-MTBANK-2021	SBA	Manufacturers and Traders Trust Company	fee	$131,593,187.80 · modeled	2021	modeled	owed	SBA PPP processing fees on Manufacturers and Traders Trust Company (M&T Bank)'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Manufacturers and Traders Trust Company (location 46391 Buffalo NY)'; 2021 approvals
E-SBA-PNC-2020	SBA	PNC Bank	fee	$392,000,388.53 · modeled	2020	modeled	owed	SBA PPP processing fees on PNC Bank, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'PNC Bank, National Association (location 44449)'; 2020 approvals
E-SBA-PNC-2021	SBA	PNC Bank	fee	$214,847,083.51 · modeled	2021	modeled	owed	SBA PPP processing fees on PNC Bank, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'PNC Bank, National Association (location 44449)'; 2021 approvals
E-SBA-PRESTAMOS-2020	SBA	Prestamos CDFI	fee	$1,250,674.03 · modeled	2020	modeled	owed	SBA PPP processing fees on Prestamos CDFI, LLC's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Prestamos CDFI, LLC'; 2020 approvals
E-SBA-PRESTAMOS-2021	SBA	Prestamos CDFI	fee	$1,053,823,691.55 · modeled	2021	modeled	owed	SBA PPP processing fees on Prestamos CDFI, LLC's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Prestamos CDFI, LLC'; 2021 approvals
E-SBA-READYCAP-2020	SBA	ReadyCap Lending	fee	$102,523,263.90 · modeled	2020	modeled	owed	SBA PPP processing fees on ReadyCap Lending, LLC (Ready Capital Corp.)'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Readycap Lending, LLC'; 2020 approvals
E-SBA-READYCAP-2021	SBA	ReadyCap Lending	fee	$204,933,996.62 · modeled	2021	modeled	owed	SBA PPP processing fees on ReadyCap Lending, LLC (Ready Capital Corp.)'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Readycap Lending, LLC'; 2021 approvals
E-SBA-REGIONS-2020	SBA	Regions Bank	fee	$156,805,944.69 · modeled	2020	modeled	owed	SBA PPP processing fees on Regions Bank's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Regions Bank'; 2020 approvals
E-SBA-REGIONS-2021	SBA	Regions Bank	fee	$111,645,203.62 · modeled	2021	modeled	owed	SBA PPP processing fees on Regions Bank's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Regions Bank'; 2021 approvals
E-SBA-SUNSHINE-2020	SBA	Sunshine State Economic Development	fee	$173,632.25 · modeled	2020	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'Sunshine State Economic Development Corporation' (fees_PPP1)
E-SBA-SUNSHINE-2021	SBA	Sunshine State Economic Development	fee	$12,040,794.83 · modeled	2021	modeled	owed			drawn	Fee model (the published fee schedule applied to each SBA loan): every loan in the SBA file priced on its schedule (85 FR 20811; 86 FR 3692; 86 FR 3712); fees_PPP1 = DateApproved < 2021-01-01, fees_PPP2_FD + fees_PPP2_SD = 2021, lender_fees.csv row 'Sunshine State Economic Development Corporation' (fees_PPP2_FD + fees_PPP2_SD)
E-SBA-TDBANK-2020	SBA	TD Bank	fee	$298,280,044.47 · modeled	2020	modeled	owed	SBA PPP processing fees on TD Bank, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'TD Bank, National Association'; 2020 approvals
E-SBA-TDBANK-2021	SBA	TD Bank	fee	$199,633,473.69 · modeled	2021	modeled	owed	SBA PPP processing fees on TD Bank, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'TD Bank, National Association'; 2021 approvals
E-SBA-HUNTINGTON-2020	SBA	The Huntington National Bank	fee	$200,998,233.29 · modeled	2020	modeled	owed	SBA PPP processing fees on The Huntington National Bank's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'The Huntington National Bank (location 57328; plus 1 loan at location 121736 approved after 2021-06-09)'; 2020 approvals
E-SBA-HUNTINGTON-2021	SBA	The Huntington National Bank	fee	$99,840,497.24 · modeled	2021	modeled	owed	SBA PPP processing fees on The Huntington National Bank's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'The Huntington National Bank (location 57328; plus 1 loan at location 121736 approved after 2021-06-09)'; 2021 approvals
E-SBA-TRUIST-2020	SBA	Truist Bank	fee	$407,750,437.81 · modeled	2020	modeled	owed	SBA PPP processing fees on Truist Bank's 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Truist Bank (location IDs 225134 NC; 18574 GA, 1 loan)'; 2020 approvals
E-SBA-TRUIST-2021	SBA	Truist Bank	fee	$180,706,071.53 · modeled	2021	modeled	owed	SBA PPP processing fees on Truist Bank's 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Truist Bank (location IDs 225134 NC; 18574 GA, 1 loan)'; 2021 approvals
E-SBA-USBANK-2020	SBA	U.S. Bank	fee	$284,948,435.07 · modeled	2020	modeled	owed	SBA PPP processing fees on U.S. Bank, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'U.S. Bank, National Association (location 53803)'; 2020 approvals
E-SBA-USBANK-2021	SBA	U.S. Bank	fee	$221,990,265.63 · modeled	2021	modeled	owed	SBA PPP processing fees on U.S. Bank, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'U.S. Bank, National Association (location 53803)'; 2021 approvals
E-SBA-WELLSFARGO-2020	SBA	Wells Fargo Bank	fee	$420,681,466.53 · modeled	2020	modeled	owed	SBA PPP processing fees on Wells Fargo Bank, N.A.'s 2020 loans		not drawn: another measure of the SBA → Wells Fargo Bank flow; shown with it, never added	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Wells Fargo Bank, National Association'; 2020 approvals
E-SBA-WELLSFARGO-2021	SBA	Wells Fargo Bank	fee	$269,384,721.42 · modeled	2021	modeled	owed	SBA PPP processing fees on Wells Fargo Bank, N.A.'s 2021 loans		not drawn: another measure of the SBA → Wells Fargo Bank flow; shown with it, never added	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record 'Wells Fargo Bank, National Association'; 2021 approvals
E-SBA-WELLSFARGO-2020-DOC	SBA	Wells Fargo Bank	fee	$420,000,000 · documented	2020	documented	owed	Disclosed SBA PPP processing fees, Wells Fargo Bank, N.A., 2020 loans		drawn	Wells Fargo & Co. Form 10-K 2020 (acc. 0000072971-21-000197): 'deferred approximately $420 million of SBA processing fees' on $10.5B funded through Dec. 31, 2020; same figure in DEF 14A 2021 (acc. 0001193125-21-082907). Model: $420.7M.
E-SBA-WELLSFARGO-2021-DOC	SBA	Wells Fargo Bank	fee	$270,000,000 · documented	2021	documented	owed	Disclosed SBA PPP processing fees, Wells Fargo Bank, N.A., 2021 loans		drawn	Wells Fargo & Co. Form 10-Q Q2 2021 (acc. 0000072971-21-000267): 'funded approximately $3.5 billion of PPP loans in the first half of 2021 and deferred approximately $270 million of related SBA processing fees'. Model: $269.4M.
X-SBA-WOMPLY-PPP1	SBA	Womply	loan principal (non-fee)	Relationship, no width drawn: recorded amount $3,103,440 · documented	approved Apr. 13, 2020	documented				not drawn: outside the PPP fee flow (out_of_fee_scope); shown only in the separate explanatory panel	SBA PPP loan-level FOIA data, release of Sept. 30, 2024 (public_150k_plus_240930.csv, public_up_to_150k_*_240930.csv), public_150k_plus_240930.csv, LoanNumber 5187557106 (OTO ANALYTICS, INC; lender and servicer Harvest Small Business Finance, LLC; LoanStatus 'Exemption 4'; no forgiveness shown); USAspending ASST_NON_5187557106_073
X-SBA-WOMPLY-PPP2	SBA	Womply	loan principal (non-fee)	Relationship, no width drawn: recorded amount $1,999,997 · documented	approved Feb. 7, 2021	documented				not drawn: outside the PPP fee flow (out_of_fee_scope); shown only in the separate explanatory panel	SBA PPP loan-level FOIA data, release of Sept. 30, 2024 (public_150k_plus_240930.csv, public_up_to_150k_*_240930.csv), public_150k_plus_240930.csv, LoanNumber 4959988403 (OTO ANALYTICS INC.; second draw, PPS; Harvest); USAspending ASST_NON_4959988403_073
X-SBA-WOMPLY-EIDL-LOAN	SBA	Womply	loan principal (non-fee)	Relationship, no width drawn: recorded amount $150,000 · documented	signed June 1, 2020	documented				not drawn: outside the PPP fee flow (out_of_fee_scope); shown only in the separate explanatory panel	USAspending.gov API v2 searches, 2026-09-27 (recipient autocomplete, recipient list, spending_by_award for contracts, IDVs, grants, direct payments, loans, other; subawards) (external), ASST_NON_6101357807_073: OTO ANALYTICS, INC, 548 Market Street 73871, San Francisco; Direct Loan, CFDA 59.008 Disaster Assistance Loans; face value $150,000; subsidy cost $20,430
X-SBA-WOMPLY-EIDL-ADVANCE	SBA	Womply	grant (non-fee)	$10,000 · documented	June 11, 2020	documented	paid			not drawn: outside the PPP fee flow (out_of_fee_scope); shown only in the separate explanatory panel	USAspending.gov API v2 searches, 2026-09-27 (recipient autocomplete, recipient list, spending_by_award for contracts, IDVs, grants, direct payments, loans, other; subawards) (external), ASST_NON_EIDLGT:3600167673_073: recipient 'WOMPLY', 548 Market Street 73871, San Francisco; CFDA 59.072 Economic Injury Disaster Loan Emergency Advance; obligation and outlay $10,000
E-SBA-ZIONS-2020	SBA	Zions Bancorporation	fee	$220,686,902.85 · modeled	2020	modeled	owed	SBA PPP processing fees on Zions Bancorporation, N.A.'s 2020 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record ''Zions Bank, A Division of' (single location 72601; name truncated in the SBA file)'; 2020 approvals
E-SBA-ZIONS-2021	SBA	Zions Bancorporation	fee	$140,673,144.10 · modeled	2021	modeled	owed	SBA PPP processing fees on Zions Bancorporation, N.A.'s 2021 loans		drawn	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan (85 FR 20811; 86 FR 3692; 86 FR 3712), lender of record, lender of record ''Zions Bank, A Division of' (single location 72601; name truncated in the SBA file)'; 2021 approvals
V3-JPMORGAN-NOPROFIT	JPMorgan Chase Bank	Programs that help small businesses	relationship (stated intention)	Relationship, no width drawn · documented	May 1, 2020	documented	stated intention		Finally, the firm does not intend to earn a profit from PPP and remains fully committed to supporting programs that help small businesses	drawn	JPMorgan Chase press release, "Chase approved to fund about $29 billion to 239,000 businesses through the Paycheck Protection Program" (May 1, 2020), press release, final paragraph
U-JPMORGAN-UNTRACED	JPMorgan Chase Bank	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees sat inside Consumer & Community Banking net interest income. Whether origination costs consumed them cannot be checked from public documents.	JPMorgan Chase's 10-K for 2020 says PPP processing fees are deferred and accreted into interest income and that their effect on 2020 interest income was 'not material'. The 10-K for 2021 says forgiveness of about $34 billion of PPP loans 'resulted in accelerated recognition in interest income of the associated deferred processing fees, primarily in CCB'. On May 1, 2020 the firm said it 'does not intend to earn a profit from PPP'; CFO Jennifer Piepszak told analysts on July 14, 2020 that 'the profit will be near zero'. No filing, call or release states the fee total, the cost total or a donation. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021; press release May 1, 2020. Not found: A PPP fee dollar figure; a cost figure; a donation.	drawn, not to scale	JPMorgan Chase Form 10-K for 2020 (filed Feb 23, 2021), p.113 — Notes – Loans (PPP) JPMorgan Chase Form 10-K for 2021, p.109 — Notes – Loans (PPP); p.64 — CCB segment results – Net interest income JPMorgan Chase Form 10-Q for Q3 2021 (filed Nov 2, 2021), CCB segment results JPMorgan Chase Bank earnings call, Q2 2020 (Jul 14, 2020) (external), CFO Jennifer Piepszak, Q&A JPMorgan Chase Form 10-K for 2022 (filed Feb 21, 2023), MD&A / notes Chase approved to fund about $29B to 239,000 businesses via PPP, press release body (Wayback capture)
E-BOFA-BOFA_PLEDGE_RECIPIENTS-DONATION	Bank of America	Small businesses, communities and nonprofits	donation	Relationship, no width drawn · documented	pledge May 4, 2020; repeated May 26-27, 2021	documented	pledged	Pledge only; amount given not found in 10-Qs Q1-Q3 2020 and Q1-Q2 2021, 10-Ks 2020-2021, 8-K releases, DEF 14A 2021, House statement Sept 21, 2022		drawn	Bank of America press release, May 4, 2020 (Wayback capture of 2022-02-08); Brian Moynihan written testimony, May 26, 2021, p. 5, testimony p. 5: "any net proceeds related to PPP fees will be dedicated to support small businesses and the communities and nonprofits we serve"
U-BOFA-UNTRACED	Bank of America	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were recognised in Consumer Banking net interest income in 2020–2021. The pledge has no public accounting.	Bank of America's May 4, 2020 release says 'net proceeds related to PPP fees will be dedicated to support small businesses and the communities and nonprofits we serve'. On the July 17, 2020 call CFO Paul Donofrio put PPP's contribution to net interest income at 'a little under $100 million' for the quarter and said 'I would not expect much, if any, profitability out of PPP'. The 10-K for 2021 attributes part of a $231 million rise in Consumer Banking net interest income to accelerated fee recognition. No filing states the fee total, the net proceeds or a donation made from them; the $250 million committed to CDFIs for PPP lending (10-Q Q2 2020) is capital, not fees. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; earnings calls 2020–2021; press release May 4, 2020. Not found: A PPP fee total; the 'net proceeds'; any donation from them.	drawn, not to scale	Bank of America Receives Approval for 265,500 SBA Paycheck Protection Program Loans to Date for Small Businesses (Bank of America press release, May 4, 2020), press release body (Wayback capture) Bank of America earnings call, Q2 2020 (Jul 17, 2020) (external), CFO Paul Donofrio, Q&A Bank of America Form 10-K for 2020 (filed Feb 24, 2021), p.111 — Notes – Outstanding Loans and Leases (PPP) Bank of America Form 10-Q for Q2 2020 (filed Jul 31, 2020), p.5 — MD&A – Community partners Bank of America Form 10-K for 2021, p.37 — Consumer Banking segment Bank of America Form 10-K for 2022 (filed Feb 22, 2023), p.29 — MD&A – Net interest income
E-HARVEST-WOMPLY-COLLECTED	Harvest Small Business Finance	Womply	referral/tech fee	$1,028,061,422.80 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $95,031,459.27; technology service $933,029,963.53 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-HARVEST-WOMPLY-LETTER	Harvest Small Business Finance	Womply	referral/tech fee	$537,453,971.86 to $755,625,274.80 · documented	FY2021	documented	paid			not drawn: another measure of the Harvest Small Business Finance → Womply flow; shown with it, never added	House Select Subcommittee document release 'Criminal_Section_Batched_Docs_With_Redactions.pdf': Locke Lord (for Harvest Small Business Finance, LLC) letter to Chairman Clyburn, Aug. 31, 2022 (external), Harvest letter Aug. 31, 2022, p. 3: SBA paid Harvest $1,074,907,943.72 in fees 'for PPP loans for which it was the lender'; Harvest 'ultimately retained $319,282,668.92'; 'based on its contractual agreement with Womply, a majority of those fees were paid to Womply'
E-HARVEST-WOMPLY-EXCESS	Harvest Small Business Finance	Womply	referral/tech fee	$272,436,148 · arithmetic	to Apr. 14, 2022	arithmetic	paid			not drawn: another measure of the Harvest Small Business Finance → Womply flow; shown with it, never added	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply's $1,028,061,422.80 collected from Harvest minus the Harvest letter's $755,625,274.80 (fees received on Harvest-lender loans less fees retained) Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-HARVEST-WOMPLY-CONTRACTMODEL	Harvest Small Business Finance	Womply	referral/tech fee	$785,808,462.82 · modeled	2021	modeled	billed	Womply fees: published contract terms applied loan by loan (loan-level ledger)		not drawn: another measure of the Harvest Small Business Finance → Womply flow; shown with it, never added	Loan-level ledger: Womply fees by lender and round (download), womply_fees_contract_reading_usd Womply-Harvest agreements in the House Select Subcommittee's Womply release: Referral Agreements of Apr. 6, 2020 and Jan. 7, 2021 and letter amendment of Jan. 29, 2021 (PDF pp. 290-299); A&R PPP Loan Referral Agreements of Mar. 1, 2021 (pp. 330-334) and Apr. 21, 2021 (pp. 335-339, House_Select_000003780-84); A&R Womply Developer Order Form, Apr. 21, 2021 (pp. 341-344, House_Select_000003786-89), Apr. 21, 2021 terms applied to 399,755 Harvest-originated 2021 loans up to $50,000 (modeled fees $932,644,444.23) Womply-Harvest agreements in the House Select Subcommittee's Womply release: Referral Agreements of Apr. 6, 2020 and Jan. 7, 2021 and letter amendment of Jan. 29, 2021 (PDF pp. 290-299); A&R PPP Loan Referral Agreements of Mar. 1, 2021 (pp. 330-334) and Apr. 21, 2021 (pp. 335-339, House_Select_000003780-84); A&R Womply Developer Order Form, Apr. 21, 2021 (pp. 341-344, House_Select_000003786-89) (original) (external)
U-HARVEST-UNTRACED	Harvest Small Business Finance	Retained by Harvest	destination	$319,282,668.92 (fiscal 2021) · documented	2020-2021 fees	documented		Retained by Harvest. As partnership income the $319.3 million passed to Harvest's members. What they did with it is not public.	Harvest's counsel told the House Select Subcommittee (Locke Lord letter, August 31, 2022, p. 3) that 'SBA paid Harvest $1,074,907,943.72 in fees', that 'a majority of those fees were paid to Womply' (drawn above: $1,028.1 million collected by April 14, 2022, Womply's response p. 3), and that Harvest 'ultimately retained $319,282,668.92 in fees from the SBA in Fiscal Year 2021'. The same letter reports partnership gross receipts of $1,165.3 million for 2021 against $65.9 million for 2020. Harvest is a private LLC taxed as a partnership; it files no SEC, FDIC or IRS accounts. Checked: House Select Subcommittee release of Aug. 31, 2022 (Locke Lord letter); Womply's response to the Subcommittee, Apr. 14, 2022. Not found: Any account of the retained $319.3 million after it left Harvest.	drawn, not to scale	Criminal Section Batched Docs With Redactions, letter p. 3, responses 4(a) and 4(b) Womply documents released with "We Are Not the Fraud Police" (House Select Subcommittee on the Coronavirus Crisis, Dec. 1, 2022), response p. 3 (PDF p. 16)
E-PRESTAMOS-BLUEACORN-REFERRAL	Prestamos CDFI	Blueacorn	referral/tech fee	$700,000,000 · documented	Jan 1, 2021 - Feb 28, 2022 (cash-flow statement period)	documented	paid	LSP fees paid by Prestamos to Blueacorn out of SBA processing fees		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022), p. 23 and nn. 152-153 (Blueacorn simplified cash-flow statement, BA-SSCC-0000121-22), p. 23: "Prestamos paid Blueacorn $700 million and Capital Plus paid Blueacorn $386 million"
E-PRESTAMOS-PRESTAMOS_RETAINED-RETAINED	Prestamos CDFI	Chicanos Por La Causa (parent nonprofit)	retained	up to $355,074,365.58 · arithmetic · not to scale	2021	arithmetic	retained	Upper bound on fees Prestamos kept; its costs and any other partner payments are not public		drawn, not to scale	Prestamos's total in the fee ranking less its payments to Blueacorn (our arithmetic)
U-PRESTAMOS-UNTRACED	Prestamos CDFI	Kept by Chicanos Por La Causa (parent nonprofit)	destination	Amount not separately stated · unknown	2020-2021 fees	unknown		Kept by Chicanos Por La Causa (parent nonprofit). The fees landed in the nonprofit's fiscal 2022 surplus and stayed there as net assets. The fiscal 2022 timing fits recognition at forgiveness or on receipt.	By contract Blueacorn took 70 percent of the SBA fee on every Prestamos loan (Blueacorn's response to the House, p. 3); the House staff report puts that at $700 million (p. 23), drawn above. The rest stayed inside the nonprofit parent. Chicanos Por La Causa's Form 990 for the year ended June 30, 2022 shows program service revenue of $377.8 million against $74.2 million the year before, 'loan revenue' of $284.6 million, revenue less expenses of $245.5 million, and net assets rising from $101.2 million to $352.6 million; Schedule R lists Prestamos CDFI LLC with total income of $293,650,813 and year-end assets of $2.12 billion. Net assets were $387.0 million at June 30, 2024. The 990 has no PPP line and no statement of use. Checked: CPLC Form 990 for fiscal 2020, 2022 and 2024 (IRS copies); ProPublica e-file summary 2011–2024; House staff report, Dec. 1, 2022; Blueacorn's House responses. Not found: The fiscal 2021 Form 990 PDF; CPLC's audited statements; any stated use of the money.	drawn, not to scale	Chicanos Por La Causa, Inc. Form 990 for fiscal year ended June 30, 2022 (EIN 86-0227210, IRS copy), PDF p. 1 (Part I); PDF p. 9 (Part VIII); PDF p. 87 (Schedule R Part I, 'Additional Data') Chicanos Por La Causa, Inc. Form 990 for fiscal year ended June 30, 2020 (EIN 86-0227210, IRS copy), PDF p. 1 Chicanos Por La Causa, Inc. Form 990 for fiscal year ended June 30, 2024 (EIN 86-0227210, IRS copy), PDF p. 1 ProPublica Nonprofit Explorer record, Chicanos Por La Causa, Inc. (EIN 86-0227210), retrieved September 30, 2026, JSON Blueacorn Batched Docs With Redactions, response letter p. 3 (text extract line 284) We Are Not the Fraud Police: How Fintechs Facilitated Fraud in the Paycheck Protection Program, printed p. 23 The House report is a partisan staff document released by the Democratic majority's staff in the final weeks of the 117th Congress, with no public hearing and no sworn testimony; an arbitrator refused it as "rank hearsay" that relied on companies then in arbitration with Womply, and a federal judge declined to take judicial notice of its findings (about the report).
E-CROSSRIVER-BLUEVINE-REFERRAL	Cross River Bank	BlueVine	referral/tech fee	Relationship, no width drawn · unknown	2020-2021	unknown	paid	Cross River payments to BlueVine: relationship documented, amount not public		drawn	BlueVine letters to the Select Subcommittee (Akin Gump, Aug. 20, 2021 and Sept. 9, 2022), letter of Sept. 9, 2022, items 1-2: "the fees it paid BlueVine for its services during the PPP"
E-CROSSRIVER-CROSS_RIVER_OTHER_PARTNERS-REFERRAL	Cross River Bank	Intuit	referral/tech fee	Relationship, no width drawn · unknown	2020-2021	unknown	paid	Cross River payments to Intuit (QuickBooks) and ApplePie Capital: relationship documented, amount not public		drawn	Cross River PPP support page, "directly through Cross River, through ApplePie or BlueVine, or through Kabbage"; "through Intuit QuickBooks"
E-CROSSRIVER-KABBAGE-REFERRAL	Cross River Bank	Kabbage	referral/tech fee	Relationship, no width drawn · unknown	2020	unknown	paid	Cross River payments to Kabbage, Inc. (now KServicing): relationship documented, amount not public		drawn	Kabbage first-day declaration, In re Kabbage, Inc. d/b/a KServicing, Bankr. D. Del. No. 22-10951, Doc. 13, para. 32 (LPA of Apr. 13, 2020: market "as CRB's agent", subservice), para. 32
E-CROSSRIVER-WOMPLY-COLLECTED	Cross River Bank	Womply	referral/tech fee	$1,583,902.99 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $1,583,902.99; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
U-CROSSRIVER-UNTRACED	Cross River Bank	Kept as bank capital	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as bank capital. The fee income was amortised into interest income and retained in the bank as capital.	Cross River publishes no PPP fee figure. Its Call Report data (FDIC, CERT 58410) show interest income of $324.4 million in 2020 and $678.9 million in 2021 against $160.6 million in 2019, and net income of $91.1 million (2020) and $372.0 million (2021) against $42.8 million (2019). The bank declared no cash dividends in any year 2019–2023; equity grew from $251.0 million (2019) to $730.5 million (2021) and $1,049.5 million (2022). What it paid Kabbage, BlueVine and its other partners is not public. Checked: FDIC Call Report data 2019Q4–2023Q4; FDIC institution record; press. Not found: A PPP fee figure; the partner fee splits; a pledge or donation (CRB Group, the private parent, publishes no statements).	drawn, not to scale	FDIC BankFind Cross River Bank CERT58410 financials 2019Q4-2023Q4, fields CERT,REPDTE,ASSET,NETINC,INTINC,EINTEXP,NONII,NONIX,ILNDOM,EQ,EQCDIV (Cash dividends declared) FDIC BankFind institution record, Cross River Bank (search result, September 30, 2026) Fdic Cross River Bank Cert58410 Financials 2019q4 2022q4
E-CAPPLUS-BLUEACORN-LSP	Capital Plus Financial, LLC	Blueacorn	referral/tech fee	$386,000,000 · reported	Jan 1, 2021 - Feb 28, 2022	reported	paid	Capital Plus payments to Blueacorn		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022), p. 23 and nn. 152-153, "Capital Plus paid Blueacorn $386 million"
E-CAPPLUS-BLUEACORN-CLAIM	Capital Plus Financial, LLC	Blueacorn	claim	Relationship, no width drawn: recorded amount $80,000,000 · documented	accrued as of FY2023 (Oct. 31, 2023)	documented	billed	Accrued, unpaid Blueacorn fees		drawn	Crossroads Impact Corp FY2023 audited financial statements, note 19, "the Company had accrued $80 million in fees due to BlueAcorn. While the Company disputes that these amounts are owed..."
E-CAPPLUS-CAPITAL_PLUS_LSPS-REFERRAL	Capital Plus Financial, LLC	Capital Plus Financial, LLC's lending service partners	referral/tech fee	$623,526,413 · documented	fiscal years ended Oct. 31, 2021-2023	documented	billed	Capital Plus fees to LSPs (Blueacorn and others)		drawn	Crossroads FY2021 annual disclosure (income statement, notes 6 and 8); Crossroads Impact Corp FY2023 audited consolidated financial statements
E-CAPPLUS-CAPITAL_PLUS_RETAINED-RETAINED	Capital Plus Financial, LLC	Capital Plus Financial, LLC: net PPP income	retained	$256,860,836 · documented · not to scale	fiscal year ended Oct. 31, 2021	documented	profit	"Net Income from PPP", a line in the Crossroads group's FY2021 disclosure; the whole amount sits in Capital Plus Financial, LLC's column (includes interest; not the same basis as fees)		drawn, not to scale	Crossroads FY2021 annual disclosure
E-CAPPLUS-CROSSROADS-INTERCO	Capital Plus Financial, LLC	Crossroads Systems, Inc. (now Crossroads Impact Corp.)	relationship (intercompany balance)	Balance, not a transfer: $304,252,816 · documented	balance at 2021-10-31	documented	balance on a date (not a payment)	A balance owed to Capital Plus in Crossroads' own schedules. No company record calls it a loan; two lawsuits (Fin Cap in Tarrant County; YXS in N.D. Tex.) allege it was a $335 million loan. No documented cash transfer		not drawn: a balance, not a payment; shown only in the tables and details	Crossroads FY2021 annual disclosure, Supplemental Schedule I (unaudited): Capital Plus 'Intercompany receivables' $304,252,816; Crossroads Systems, Inc. 'Intercompany payables' $304,252,816; eliminated in consolidation, Schedule I, Oct. 31, 2021 Crossroads Impact Corp. OTC quarterly disclosure, quarter ended July 31, 2022, Supplemental Schedule I
V3-CAPPLUS-PREFERRED-DIV-FY2021	Capital Plus Financial, LLC	Holders of Capital Plus Financial, LLC preferred units	dividend (preferred units)	$630,000 · documented · not to scale	FY2021 (Nov. 2020 - Oct. 2021)	documented	paid		During the year ended October 31, 2021, CPF paid preferred dividends totaling $630,000	drawn, not to scale	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), note 16 (non-controlling interests, CPF preferred equity)
V3-BENWORTH-BENWORTHPR-171M	Benworth Capital Partners	Benworth Capital Partners PR	servicing fees (related company)	$171,000,000 · documented	summer 2021	documented	paid		Benworth had transferred $171 million to Benworth Puerto Rico, a related company located in Puerto Rico.	drawn	Arbitrator Order No. 5, JAMS arbitration Oto Analytics v. Benworth (Jan. 17, 2023), filed as D.P.R. No. 3:23-cv-01034, Doc. 163-2, Order No. 5; Navarro deposition Vol. II 54:11-22 (Doc. 163-1 p. 5)
V3-BENWORTH-BENWORTHPR-FRBSF	Benworth Capital Partners	Benworth Capital Partners PR	servicing fees (related company)	at least $50,000,000 · reported	2021-2023	reported	transferred		Between 2021 and 2023, Benworth FL transferred over $50 million to Benworth PR	not drawn: another measure of the Benworth Capital Partners → Benworth Capital Partners PR flow; shown with it, never added	Complaint, Federal Reserve Bank of San Francisco v. Benworth Capital Partners LLC et al., D.P.R. No. 3:24-cv-01313, Doc. 1 (July 10, 2024), para. 57 and n. 10
V3-BENWORTH-NAVARRO-DIV-2021-23	Benworth Capital Partners	Bernardo Navarro	dividend	at least $48,240,502.75 · reported · not to scale	partly 2021-2023	reported	paid (alleged)		Mr. Navarro caused Benworth FL to pay dividends to himself as sole shareholder of at least $48,240,502.75, a portion of which was paid between 2021 and 2023.	drawn, not to scale	Complaint, Federal Reserve Bank of San Francisco v. Benworth Capital Partners LLC et al., D.P.R. No. 3:24-cv-01313, Doc. 1 (July 10, 2024), para. 58
V3-BENWORTH-NAVARRO-DIV-2024	Benworth Capital Partners	Bernardo Navarro	dividend	at least $804,860.89 · reported · not to scale	Jan. 1 - May 23, 2024	reported	paid (alleged)		He also caused Benworth FL to pay dividends to himself of at least $804,860.89 between January 1, 2024 and May 23, 2024.	drawn, not to scale	Complaint, Federal Reserve Bank of San Francisco v. Benworth Capital Partners LLC et al., D.P.R. No. 3:24-cv-01313, Doc. 1 (July 10, 2024), para. 58
E-BENWORTH-WOMPLY-COLLECTED	Benworth Capital Partners	Womply	referral/tech fee	$464,991,236.65 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $35,871,289.05; technology service $429,119,947.60 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-BENWORTH-WOMPLY-PAID	Benworth Capital Partners	Womply	referral/tech fee	$464,991,487 · documented	2021	documented	paid			not drawn: another measure of the Benworth Capital Partners → Womply flow; shown with it, never added	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, award p. 29 (ECF p. 29 of 74): 'In total, Benworth has paid Womply $464,991,487 in fees'; components p. 30: referral $35,881,239, API $59,157,250, technology $369,952,999 (components sum to $464,991,488)
E-BENWORTH-WOMPLY-BILLED	Benworth Capital Partners	Womply	referral/tech fee	$616,664,869 · arithmetic	2021	arithmetic	billed			not drawn: another measure of the Benworth Capital Partners → Womply flow; shown with it, never added	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, p. 29 paid $464,991,487 + p. 5 demand 'at least $151,673,382' = $616,664,869
E-BENWORTH-WOMPLY-ENTITLED	Benworth Capital Partners	Womply	referral/tech fee	$551,291,379 · documented	2021	documented	owed			not drawn: another measure of the Benworth Capital Partners → Womply flow; shown with it, never added	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, p. 52: technology fees owed $529,876,104 against payments; damages referral $4,348,275 + API $17,067,000 + technology $64,884,617 = $86,299,892; 464,991,487 + 86,299,892 = 551,291,379
E-BENWORTH-WOMPLY-AWARD	Benworth Capital Partners	Womply	claim	$117,920,254.72 · documented · not to scale	award June 26, 2024	documented	owed			drawn, not to scale (panel 3)	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, p. 73: fees $86,299,892; finance charges $25,363,697.68 (to May 30, 2024); attorneys' fees $5,883,708.58; costs $372,956.46
E-BENWORTH-WOMPLY-SETTLEMENT	Benworth Capital Partners	Womply	claim	Amount unknown · unknown · not to scale	Jan. 2, 2025	unknown	paid			drawn, not to scale (panel 3)	Reconciliation of the court and House records (our arithmetic), (dismissal on confidential terms)
U-BENWORTH-UNTRACED	Benworth Capital Partners	Kept by Benworth (private; no public accounts)	destination	Amount unknown · unknown	2020-2021 fees	unknown		Kept by Benworth (private; no public accounts). What remained after those payments stayed in a private company; no record shows its use.	Benworth put its SBA receipts at '$680 million in lender processing fees' (JAMS award, p. 30). Court records trace part of the money, drawn above: $465.0 million collected by Womply (Womply's response, p. 3); '$171 million' transferred 'to Benworth Puerto Rico, a related company' (Arbitrator Order No. 5), which the Federal Reserve Bank of San Francisco's 2024 complaint puts at 'over $50 million' between 2021 and 2023; dividends to the sole shareholder of at least $48.2 million (2021–23) plus $0.8 million in 2024 (complaint paras. 57–58). Benworth files no public accounts; the January 2025 settlement terms are not public. Checked: JAMS Corrected Final Award, June 26, 2024; Arbitrator Order No. 5, Jan. 17, 2023; FRBSF complaint, July 10, 2024; Womply's response, Apr. 14, 2022. Not found: Benworth's own accounts; the 2025 settlement terms.	drawn, not to scale	2024 06 24 Willkie Womply Benworth Arbitration Award, pp. 30, 73 JAMS Order No. 5, Order re: Womply's Emergency Request to Disclose Protected Materials and Womply's Motion to Produce, Jan. 17, 2023 (D.P.R. 23-cv-01034, Dkt. ..., Order No. 5 Frbsf Complaint — Frbsf v. Benworth Capital Partners PR LLC et al. (No. 3:24-cv-01313) (N.D. Cal. No. 3:24-cv-03975), paras. 57-58 (as quoted in v3/NEW-FLOWS.csv) Womply documents released with "We Are Not the Fraud Police" (House Select Subcommittee on the Coronavirus Crisis, Dec. 1, 2022), response p. 3 (PDF p. 16)
E-WELLSFARGO-WELLS_2021_PLEDGE-DONATION	Wells Fargo Bank	Charitable recipients	donation	Relationship, no width drawn · documented	pledged Q1-Q3 2021 10-Qs	documented	pledged	Pledge only		drawn	Wells Fargo & Co. Form 10-Q Q2 2021 and Q3 2021 (acc. 0000072971-21-000317): "committed to donate any net profits from processing fees received from PPP loans funded in 2021"
E-WELLSFARGO-WELLS_OPEN_FOR_BUSINESS_FUND-DONATION	Wells Fargo Bank	Open for Business Fund grantees	donation	$420,000,000 · documented	donated as recognized, Q3 2020 - Q4 2021	documented	paid	Wells donation of its 2020 PPP fees		drawn	Wells Fargo & Co. Form 10-K 2021 (acc. 0000072971-22-000096): "In 2021, we fulfilled this approximately $420 million commitment"; 4Q21 results presentation ("Fulfilled our ~$420 million commitment")
U-WELLSFARGO-UNTRACED	Wells Fargo Bank	Kept as interest income (2021 round)	destination	approximately $270 million of 2021 fees deferred · documented	2020-2021 fees	documented		Kept as interest income (2021 round). The 2020 fees were given away in full. The 2021 fees were recognised as interest income; a 'net profit' donation from them was never reported.	Wells Fargo deferred approximately $420 million of processing fees on the $10.5 billion it funded in 2020 and 'voluntarily committed to donate all of the gross processing fees received in 2020'; the 10-K for 2021 states 'In 2021, we fulfilled this approximately $420 million commitment' (drawn above as the Open for Business Fund). For loans funded in 2021 it deferred approximately $270 million of fees and 'committed to donate any net profits from processing fees received from PPP loans funded in 2021'. That second pledge appears in the Q1–Q3 2021 10-Qs and in neither the 2021 nor the 2022 annual report; the 2022 report mentions only 'lower donation expense due to higher donations of PPP processing fees in 2021'. Checked: 10-Qs Q2 2020–Q3 2021; annual reports 2020, 2021, 2022; press release July 9, 2020; 3Q 2021 results deck; Q2 2021 earnings call. Not found: Fulfilment or amount of the 2021 'net profits' pledge.	drawn, not to scale	Wells Fargo & Company Form 10-Q for Q2 2020 (filed Aug 4, 2020), Overview – Recent Developments – PPP Wells Fargo & Company Form 10-Q for Q3 2020 (filed Nov 2, 2020), Overview – Recent Developments – PPP Wells Fargo & Company 2020 Annual Report (Ex. 13 to Form 10-K), Overview – Recent Developments – PPP Wells Fargo & Company Form 10-Q for Q1 2021 (filed May 5, 2021), p.4 — Overview – Recent Developments – PPP Wells Fargo & Company Form 10-Q for Q2 2021 (filed Jul 28, 2021), p.4 — Overview – Recent Developments – PPP Wells Fargo & Company Form 10-Q for Q3 2021 (filed Nov 1, 2021), p.4 — Overview – Recent Developments – PPP Wells Fargo & Company 2021 Annual Report (Ex. 13 to Form 10-K), Overview – Recent Developments – PPP Wells Fargo & Company 2022 Annual Report (Ex. 13 to Form 10-K) (filed Feb 21, 2023), p.16 — Consumer Banking and Lending – noninterest expense Wells Fargo Bank earnings call, Q2 2021 (Jul 14, 2021) (external), prepared remarks Wells Fargo Launches $400 Million Small Business Recovery Effort (Business Wire, July 9, 2020), CEO Charlie Scharf quote (Wayback capture) Wells Fargo 3Q21 Financial Results presentation (October 14, 2021), results deck – Open for Business Fund (pdftotext line 35)
E-FOUNTAINHEAD-WOMPLY-COLLECTED	Fountainhead SBF	Womply	referral/tech fee	$454,180,690.22 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $34,762,363.26; technology service $419,418,326.96 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-FOUNTAINHEAD-WOMPLY-UNPAID	Fountainhead SBF	Womply	claim	at least $90,000,000 · reported · not to scale	2021	reported	owed			drawn, not to scale (panel 3)	Affidavit of Womply's counsel (Cheney), Fountainhead SBF v. Oto Analytics (Sept. 13, 2021), paras. 6-8: 'over $90 million in fees'; JAMS arbitration No. 1100-111-808 filed June 15, 2021; Fountainhead complaint p. 3 n. 1: paid 'greater than 80%' of Womply's claim
E-FOUNTAINHEAD-WOMPLY-OUTCOME	Fountainhead SBF	Womply	claim	Amount unknown · unknown · not to scale	2021-2022	unknown	paid			drawn, not to scale (panel 3)	Affidavit of Womply's counsel (Cheney), Fountainhead SBF v. Oto Analytics (Sept. 13, 2021), JAMS No. 1100-111-808
E-FOUNTAINHEAD-WOMPLY-CONTRACTMODEL	Fountainhead SBF	Womply	referral/tech fee	$496,379,672.48 · modeled	2021	modeled	billed	Womply fees: published contract terms applied loan by loan (loan-level ledger)		not drawn: another measure of the Fountainhead SBF → Womply flow; shown with it, never added	Loan-level ledger: Womply fees by lender and round (download), womply_fees_contract_reading_usd PPP Loan Referral Agreement between Oto Analytics, Inc. d/b/a Womply and Fountainhead SBF, Feb. 9, 2021 (House_Select_000003690-94), in the House Select Subcommittee's Womply release, PDF pp. 285-289, Feb. 9, 2021 terms applied to 269,466 Fountainhead 2021 loans (modeled fees $625,097,842.09) PPP Loan Referral Agreement between Oto Analytics, Inc. d/b/a Womply and Fountainhead SBF, Feb. 9, 2021 (House_Select_000003690-94), in the House Select Subcommittee's Womply release, PDF pp. 285-289 (original) (external)
U-FOUNTAINHEAD-UNTRACED	Fountainhead SBF	Retained by Fountainhead (private; no filed accounts)	destination	Amount unknown · unknown	2020-2021 fees	unknown		Retained by Fountainhead (private; no filed accounts). By arithmetic on the modeled total, roughly $186 million stayed with Fountainhead. The sale appears not to have closed.	Womply reported collecting $454.2 million from Fountainhead by April 14, 2022 (drawn above). Fountainhead is a private SBA lender with no filed accounts. Crossroads announced an agreement in principle to buy Fountainhead on December 16, 2021; Crossroads' fiscal 2022 and 2023 statements and 2022 proxy do not mention Fountainhead and its media room carries no closing release. Checked: Womply's House filings (Apr. 14, 2022); Crossroads release of Dec. 16, 2021 and media-room index; Crossroads fiscal 2021–2023 statements. Not found: Fountainhead's accounts; any use of the retained share; a closing or termination of the Crossroads deal.	drawn, not to scale	Womply documents released with "We Are Not the Fraud Police" (House Select Subcommittee on the Coronavirus Crisis, Dec. 1, 2022), response p. 3 (PDF p. 16) Crossroads Systems to Acquire Leading Small Business Lender, Fountainhead (Crossroads press release, December 16, 2021), web page Crossroads media room news release index (captured September 30, 2026), web page
U-PNC-UNTRACED	PNC Bank	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	PNC's 10-Qs say the PPP processing fee 'is deferred and accreted into Net interest income using the effective yield method, over the contractual life of the loan'. On the October 15, 2021 call CFO Rob Reilly said the 'net interest income contribution from PPP was about a $100 million' in the third quarter; on January 18, 2022 he guided to 'a decline of approximately $75 million in PPP-related interest income'. No filing gives an annual PPP fee figure. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: An annual PPP fee figure; a donation or pledge.	drawn, not to scale	PNC Form 10-Q for Q2 2020 (filed Aug 4, 2020), p.59 — Notes – Loans (accounting policy) PNC Bank earnings call, Q3 2021 (Oct 15, 2021) (external), CFO Rob Reilly, Q&A PNC Bank earnings call, Q4 2021 (Jan 18, 2022) (external), CFO Rob Reilly, guidance PNC Form 10-K for 2021, p.41 — MD&A – outlook (no PPP fee figure in the filing) PNC Form 10-K for 2022, p.3 — Risk factors (no PPP fee figure in the filing)
U-TRUIST-UNTRACED	Truist Bank	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	Truist's Q2 2020 10-Q calls it the 'third largest PPP lender' with $12.0 billion of PPP loans. Later filings attribute part of net interest income to 'higher fees on PPP loans' (2021) and 'higher margin fees tied to PPP loan forgiveness' (10-K 2021), then 'lower PPP revenue' (10-K 2022), never with a dollar amount. Its $50 million Truist Cares pledge is described as philanthropic support, not as PPP fee money. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: A PPP fee figure; a fee-donation statement.	drawn, not to scale	Truist Form 10-Q for Q2 2020 (filed Aug 4, 2020), p.50 — MD&A – crisis response Truist Form 10-Q for Q2 2021 (filed Aug 6, 2021), p.42 — MD&A – Net interest income Truist Form 10-K for 2021, p.48 — Segment results Truist Form 10-K for 2022 (filed Feb 28, 2023), p.42 — MD&A – Net interest income and NIM Truist Bank earnings call, Q4 2021 (Jan 18, 2022), prepared remarks
E-CUSTOMERS-CUSTOMERS_RETAINED-RETAINED	Customers Bank	Customers Bancorp	retained	$424,100,000 · documented · not to scale	FY2020-FY2022	documented	recognized	Disclosed PPP income; not a net or retained figure	Customers recognized interest income, including net origination fees, of $79.4 million, $279.2 million and $65.5 million for the years ended December 31, 2022, 2021 and 2020, respectively.	not drawn: the records support it as a table entry only, not as a drawn flow	Customers Bancorp, Inc. Form 10-K (Dec. 31, 2020), Notes – Loans receivable, PPP Customers Bancorp, Inc. Form 10-K (Dec. 31, 2021), Notes – Loans receivable, PPP Customers Bancorp, Inc., Form 10-K for the fiscal year ended December 31, 2022, Notes – Loans receivable, PPP
E-CUSTOMERS-KABBAGE-REFERRAL	Customers Bank	Kabbage	referral/tech fee	$58,000,000 · documented	2021 loans; settlement Oct. 27, 2022	documented	billed	Customers fees owed to KServicing, as settled		drawn	Customers Bancorp Form 8-K, Oct. 27, 2022, Item 8.01
E-CUSTOMERS-KABBAGE-REFERRAL-2	Customers Bank	Kabbage	referral/tech fee	$22,055,340 · documented	Nov. 2022 - Mar. 2023	documented	paid	Cash paid by Customers to KServicing under the settlement		drawn	In re Kabbage, Inc. d/b/a KServicing, Bankr. D. Del. 22-10951 (CTG), Doc. 732 (Mar. 28, 2023) para. 2 ("the total Settlement Payment is therefore determined to be $22,055,340.00"); Doc. 671-4 Ex. D (settlement payment calculation: "Rec'd from CUBI 11/14 $19,469,355", "Rec'd from CUBI 11/16 $1,030,328")
E-CUSTOMERS-KABBAGE-REFERRAL-3	Customers Bank	Kabbage	referral/tech fee	$35,944,660 to $37,500,317 · documented	2021-2022	documented	retained	Holdbacks counted toward the $58M		drawn	Bankr. D. Del. 22-10951, Doc. 671-4 Ex. D ("Disputed KServicing Holdbacks $37,500,317 / $35,944,660")
E-CUSTOMERS-KABBAGE-REFERRAL-4	Customers Bank	Kabbage	referral/tech fee	Relationship, no width drawn · unknown	2020	unknown	paid	2020 fees shared with Kabbage: amount not split		drawn	DOJ complaint-in-intervention, U.S. v. Frohwein et al. (Dec. 20, 2024), as summarized on /profiles/kabbage-kservicing/ ("more than $217 million" 2020 PPP processing fees incl. loans funded through Customers and Cross River)
E-CUSTOMERS-READYCAP-REFERRAL	Customers Bank	ReadyCap Lending	referral/tech fee	$43,300,000 · documented	2020 ($27.8M recognized at origination, $15.5M over servicing/forgiveness)	documented	paid	LSP fees paid to Ready Capital on 2020 loans		drawn	Ready Capital Corp. Form 10-K 2020 (acc. 0001558370-21-003005), PPP note (external), "The Company received a fee for providing such services, which represents one-half of the total fees received by the third-party from the SBA, less any agent fees paid directly by the third-party for referrals... approximately $2.5 billion of PPP loans... for $43.3 million in total fees."
U-CUSTOMERS-UNTRACED	Customers Bank	Kept as interest income	destination	$424.1 million PPP interest income incl. net fees, 2020–2022 · arithmetic from the 10-Ks (not fee-only)	2020-2021 fees	arithmetic		Kept as interest income. The remainder was retained as net interest income. No donation pledge was found.	Customers Bancorp's 10-Ks state interest income including net origination fees from PPP loans of $65.5 million (2020), $279.2 million (2021) and $79.4 million (2022), recognised as forgiveness accelerated the deferred fees. Payments out of that stream are drawn above: $58 million owed to Kabbage/KServicing under the October 27, 2022 settlement (8-K) and roughly $43 million of 2020 fees passed to Ready Capital (its 10-K); the 10-K for 2021 records servicing fees paid to third-party servicers and the 10-K for 2022 the legal costs of the settlement with 'a third party PPP service provider'. Checked: 10-K 2020, 2021, 2022; 10-Q Q2 2021; 8-K October 27, 2022; KServicing bankruptcy docket. Not found: A net or retained PPP figure; a donation or pledge.	drawn, not to scale	Customers Bancorp, Inc. Form 10-K (Dec. 31, 2020), Notes – Loans receivable, PPP Customers Bancorp, Inc. Form 10-K (Dec. 31, 2021), Notes – Loans receivable, PPP; MD&A – Non-interest expense – Loan servicing Customers Bancorp, Inc., Form 10-K for the fiscal year ended December 31, 2022, Notes – Loans receivable, PPP; MD&A – Non-interest expense – Professional services Customers Bancorp, Inc. Form 10-Q (June 30, 2021), Notes – Loans receivable, PPP
R-LENDISTRY-HARVEST-SERVICING	Lendistry	Harvest Small Business Finance	relationship (loan servicing)	Relationship, no width drawn · documented	2021-05-22 to 2021-06-29	documented				drawn	SBA PPP loan-level FOIA data, release of Sept. 30, 2024 (public_150k_plus_240930.csv, public_up_to_150k_*_240930.csv), ServicingLenderName = Harvest Small Business Finance, LLC on 189,259 loans with OriginatingLender = BSD Capital, LLC dba Lendistry (93% of Lendistry's 203,207 2021 loans)
R-LENDISTRY-HARVEST-PURCHASE	Lendistry	Harvest Small Business Finance	relationship (loan purchase)	Relationship, no width drawn · documented	May-June 2021	documented				drawn	Affidavit, United States v. Pierre-Canel, D. Mass. No. 1:25-mj-01005, Doc. 4-1 (filed Jan. 17, 2025) (external), Doc. 4-1 p. 9 para. 42: 'Harvest Small Business Finance LLC purchased this loan from Lendistry before the wire was sent' (one loan; application filed with Lendistry May 20, 2021, para. 36)
E-LENDISTRY-HARVEST-FEE	Lendistry	Harvest Small Business Finance	referral/tech fee	Amount unknown · unknown	2021	unknown	paid			drawn	Reconciliation of the court and House records (our arithmetic), no document
R-LENDISTRY-WOMPLY-ROUTE	Lendistry	Womply	relationship (referral route)	Relationship, no width drawn · reported	2021	reported				not drawn: Womply's Lendistry money sits inside Harvest's collected amount (loan-level ledger); no separate Lendistry-to-Womply flow is drawn	House Select Subcommittee press release, Dec. 1, 2022 (clyburn-fintech-fraud-ppp-doj-sba) (original: coronavirus-democrats-oversight.house.gov) (external), press release Dec. 1, 2022: 'Multiple Womply lending partners, including Dreamspring, Lendistry, Fountainhead and Benworth'; House report p. 49 and nn. 433-434 (Lendistry CEO email of June 8, 2021 to Harvest and Womply on 'applicants coming through Harvest', House_Select_000013805, the House Womply document release PDF p. 460); womply.com (2026): 'Partners included Harvest... and Lendistry'
E-LENDISTRY-WOMPLY-FEE	Lendistry	Womply	referral/tech fee	Amount unknown · unknown	2021	unknown	paid			not drawn: Womply's Lendistry money sits inside Harvest's collected amount (loan-level ledger); no separate Lendistry-to-Womply flow is drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply's per-payer collection table (Apr. 14, 2022, PDF p. 16) has no Lendistry row Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
U-LENDISTRY-UNTRACED	Lendistry	Kept by Lendistry (private; no public accounts)	destination	Amount unknown · unknown	2020-2021 fees	unknown		Kept by Lendistry (private; no public accounts). The fees stayed with a private company whose accounts are not public.	Lendistry (B.S.D. Capital, Inc.) is a private for-profit CDFI: no SEC report, no Call Report, and no Form 990 filer under Lendistry, 'Center by Lendistry' or 'BSD Capital'. Its 2021 loans ran through Harvest's servicing and Womply's platform (both drawn above); the Lendistry–Harvest and Lendistry–Womply terms are in no public document. $473.1 million of the modeled fees sit on loans Harvest serviced between May 22 and June 29, 2021. Checked: SEC EDGAR (no filer); FDIC (not a bank); IRS Form 990 search via ProPublica, three name variants (no filer); House staff report. Not found: Any Lendistry financial statement; the fee split with Harvest or Womply.	drawn, not to scale	ProPublica Nonprofit Explorer search "lendistry" (0 results, September 30, 2026), JSON ProPublica Nonprofit Explorer search "center by lendistry" (0 results, September 30, 2026), JSON ProPublica Nonprofit Explorer search "bsd capital" (0 results, September 30, 2026), JSON We Are Not the Fraud Police: How Fintechs Facilitated Fraud in the Paycheck Protection Program, printed p. 23 The House report is a partisan staff document released by the Democratic majority's staff in the final weeks of the 117th Congress, with no public hearing and no sworn testimony; an arbitrator refused it as "rank hearsay" that relied on companies then in arbitration with Womply, and a federal judge declined to take judicial notice of its findings (about the report).
U-USBANK-UNTRACED	U.S. Bank	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	U.S. Bancorp's 2020 annual report credits 'higher loan fees driven in part by loans made under the SBA's Paycheck Protection Program'; the 2021 report credits 'higher loan fees driven by accelerated loan forgiveness from the SBA PPP'. The only number is guidance: on the October 14, 2021 call management expected 'PPP fees to decline $60 million to $70 million in the fourth quarter compared with the third quarter'. Checked: Annual reports (10-K Exhibit 13) 2020, 2021, 2022; six 10-Qs 2020–2021; earnings calls 2020–2021. Not found: An annual PPP fee figure; a donation or pledge.	drawn, not to scale	U.S. Bancorp 2020 Annual Report (Ex. 13 to Form 10-K), MD&A – Net interest income U.S. Bancorp 2021 Annual Report (Ex. 13 to Form 10-K) (filed Feb 22, 2022), MD&A – Net interest income U.S. Bancorp 2022 Annual Report (Ex. 13 to Form 10-K) (filed Feb 27, 2023), MD&A U.S. Bancorp Form 10-Q for Q3 2021 (filed Nov 2, 2021), p.31 — MD&A – Net interest income U.S. Bank earnings call, Q3 2021 (Oct 14, 2021) (external), prepared remarks
U-TDBANK-UNTRACED	TD Bank	Kept as U.S. Retail interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as U.S. Retail interest income. The fees were kept as U.S. Retail net interest income.	Toronto-Dominion's 2021 annual report (Form 40-F) says 'the Bank receives fees on PPP loans generally ranging from 1-5% of the loan's value at origination. The fees are amortized over the life of the loan, with any unamortized amount upon forgiveness being recognized immediately as income', reports about 133,000 loans funded, and credits U.S. Retail net interest income with 'accelerated fee amortization from PPP loan forgiveness'; the 2022 report notes 'lower income from PPP loan forgiveness'. No U.S.-dollar fee figure appears in the fiscal 2020–2022 reports. An outside estimate reported by The Globe and Mail on July 12, 2020 (Honigsberg and Hu) put TD's 2020 fees at US$238–398 million. Checked: Form 40-F MD&A for fiscal 2020, 2021, 2022; fiscal 2021 financial statements; The Globe and Mail, July 12, 2020. Not found: A U.S.-dollar PPP fee figure; a donation or pledge.	drawn, not to scale	TD Bank Group 2020 Annual Report MD&A (Form 40-F Ex. 99.2), p.20 — U.S. Retail – business highlights TD Bank Group 2021 Annual Report MD&A (Form 40-F Ex. 99.2), p.4 — Significant events / U.S. Retail; p.22 — U.S. Retail – results TD Bank Group 2022 Annual Report MD&A (Form 40-F Ex. 99.2) (filed Dec 1, 2022), p.23 — U.S. Retail – results TD Bank Group 2021 Consolidated Financial Statements (Form 40-F Ex. 99.3) (filed Dec 2, 2021), notes TD Bank press (The Globe and Mail), Jul 12, 2020 (external), article body (paywall-truncated capture)
E-ITRIA-BIZ2CREDIT-RELATION	Itria Ventures	Biz2Credit	relationship (servicing/channel)	Relationship, no width drawn · reported	2020-2021	reported		Intra-group relationship; no fee transfer documented		drawn	/profiles/itria-ventures/ and /profiles/biz2credit/
U-ITRIA-UNTRACED	Itria Ventures	Kept by Itria / Biz2Credit (private; no public accounts)	destination	Amount unknown · unknown	2020-2021 fees	unknown		Kept by Itria / Biz2Credit (private; no public accounts). The fees stayed with a private company whose accounts are not public.	Itria Ventures and Biz2Credit are private and publish no PPP fee figure. The FTC's 2024 complaint notes that lenders received SBA fees but gives no Itria total; California's DFPI consent order has no fee figures. The one documented payment out is the $33 million judgment Biz2Credit and Itria were ordered to pay the FTC in March 2024 for misrepresenting processing times, a penalty rather than a fee flow. Checked: FTC complaint and order, March 2024; FTC release, Mar. 18, 2024; California DFPI consent order; House staff report. Not found: Any Itria or Biz2Credit financial statement; a fee figure.	drawn, not to scale	FTC Actions on Deceptive Pandemic Loan Promises: $59 Million, release Complaint — FTC v. Biz2Credit (S.D.N.Y.) California Department of Business Oversight consent order, Itria Ventures LLC Mar. 2020
U-KEYBANK-UNTRACED	KeyBank	Kept as interest income	destination	Amount not stated in full · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income; the quarters not disclosed and scheduled amortisation account for the gap to the $379 million model.	KeyCorp gave quarterly figures on its calls and no total in its 10-Ks: forgiveness 'accelerated about $28 million of additional fee recognition' in Q4 2020; 'PPP loan fees, including the impact of forgiveness, totaled $50 million' in Q2 2021, up $2 million from Q1; $45 million in Q3 2021. The four quarters disclosed sum to about $171 million. Checked: 10-K 2020, 2021, 2022; seven 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: An annual PPP fee total; a donation or pledge.	drawn, not to scale	KeyCorp Form 10-K for 2020 (filed Feb 22, 2021), Line of business results – Consumer Bank KeyBank earnings call, Q4 2020 (Jan 21, 2021) (external), prepared remarks KeyBank earnings call, Q2 2021 (Jul 20, 2021) (external), prepared remarks KeyBank earnings call, Q3 2021 (Oct 21, 2021) (external), prepared remarks KeyCorp, Form 10-K for 2021 (filed Feb. 22, 2022), Line of business results – Commercial Bank KeyCorp Form 10-K for 2022 (filed Feb 22, 2023), MD&A
E-ZIONS-ZIONS_FOUNDATION-DONATION	Zions Bancorporation	Zions foundation	donation	$30,000,000 · documented	Q3 2020	documented	paid	Zions donation of $30 million of its PPP fees to its foundation	The decrease in adjusted PPNR is primarily a result of a $30 million charitable contribution to our foundation, which was associated with the PPP lending activity.	drawn	Zions Bancorporation, N.A. Form 10-Q for Q3 2020 (filed Nov 4, 2020), p.11 — MD&A – Executive summary Zions Bancorporation, N.A. Form 10-Q for Q2 2020 (filed Aug 5, 2020), p.9 — MD&A – Executive summary Zions Bancorporation earnings call, Q2 2020 (Jul 20, 2020) (external), prepared remarks
U-ZIONS-UNTRACED	Zions Bancorporation	Kept as interest income	destination	Amount not separately stated · unknown (PPP interest income $146M, $235M, $47M in 2020–2022, not fee-only)	2020-2021 fees	unknown		Kept as interest income. About $30 million went to the Zions foundation, roughly 7 percent of some $460 million of PPP revenue; the balance was retained as net interest income.	In the Q2 2020 10-Q Zions 'announced $30 million in future charitable contributions from the loan processing fees received from the PPP loans'; CFO Paul Burdiss said it would donate '$30 million during the second half of the year out of a current total of about $220 million in total fee income from the PPP program', and the Q3 2020 10-Q records the '$30 million charitable contribution to our foundation, which was associated with the PPP lending activity' as a third-quarter 2020 expense (new node above: Zions foundation, $30 million). Total interest income from PPP loans was $146 million in 2020 ($26 million accelerated on forgiveness), $235 million in 2021 ($138 million accelerated) and $47 million in 2022 ($31 million accelerated), with $2 million of net deferred fees left at end-2022; management put cumulative 'PPP-related revenue' at $380 million by Q3 2021 with $83 million to come. Checked: 10-K 2020, 2021, 2022; 10-Qs Q2 2020–Q1 2021; earnings calls Q2 2020 and Q3 2021. Not found: A fee-only total; any donation beyond the $30 million.	drawn, not to scale	Zions Bancorporation, N.A. Form 10-Q for Q2 2020 (filed Aug 5, 2020), p.9 — MD&A – Executive summary Zions Bancorporation earnings call, Q2 2020 (Jul 20, 2020) (external), prepared remarks Zions Bancorporation, N.A. Form 10-Q for Q3 2020 (filed Nov 4, 2020), p.11 — MD&A – Executive summary Zions Bancorporation, N.A. Form 10-K for 2020 (filed Feb 25, 2021), p.32 — MD&A – Executive summary; p.34 — MD&A – SBA Paycheck Protection Program Zions Bancorporation, N.A. Form 10-Q for Q1 2021 (filed May 6, 2021), MD&A – PPP loans table (Q1 2021 / FY2020 / total) Zions Bancorporation, N.A., Form 10-K for 2021 (filed Feb. 25, 2022), MD&A – Executive summary Zions Bancorporation, N.A. Form 10-K for 2022 (filed Feb 23, 2023), p.29 — MD&A – Loans Zions Bancorporation earnings call, Q3 2021 (Oct 18, 2021) (external), prepared remarks
U-MTBANK-UNTRACED	Manufacturers and Traders Trust Company	Kept as interest income	destination	Amount not stated in full · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	M&T quantified PPP fees only quarter by quarter. Forgiveness 'resulted in the accelerated recognition of $29 million of PPP loan fees into net interest income' in Q4 2020; the Q3 2021 10-Q attributes a 145-basis-point widening of the loan margin 'predominantly to fees from PPP loan payoffs'; the Q4 2021 call cites 'a $30 million decline in interest income and fees from PPP loans'; the 10-K for 2022 notes 'a lower level of PPP fee income resulting from repayment of loans by the SBA'. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: An annual PPP fee total; a donation or pledge.	drawn, not to scale	Manufacturers and Traders Trust Company earnings call, Q4 2020 (Jan 21, 2021) (external), prepared remarks M&T Bank Form 10-Q for Q3 2021 (filed Nov 5, 2021), MD&A – Business Banking segment Manufacturers and Traders Trust Company earnings call, Q4 2021 (Jan 20, 2022) (external), prepared remarks M&T Bank Form 10-K for 2021 (filed Feb 16, 2022), MD&A M&T Bank Form 10-K for 2022, MD&A – Business Banking segment
E-READYCAP-CUSTOMERS-RELATION	ReadyCap Lending	Customers Bank	relationship (servicing/channel)	Relationship, no width drawn · documented	2020	documented		Attribution note: SBA fee on Readycap-originated 2020 loans went to the purchaser		drawn	Ready Capital Corp. Form 10-K 2020 (acc. 0001558370-21-003005), PPP note (external), "one-half of the total fees received by the third-party from the SBA"
E-READYCAP-READYCAP_COSTS-EXPENSE	ReadyCap Lending	PPP direct operating costs	expense	$17,841,000 · documented	FY2020-FY2021	documented	paid	Documented PPP costs		drawn	Ready Capital Corp. Form 10-K 2021 (acc. 0001558370-22-002392), PPP note (2021 and 2020 columns) (external), "Direct operating expenses $ 8,241 $ 9,600" (in thousands)
E-READYCAP-READYCAP_RETAINED-RETAINED	ReadyCap Lending	Ready Capital	retained	$157,803,000 · documented · not to scale	FY2020-FY2023	documented	profit	Disclosed net PPP income (not fee-only)		not drawn: the records support it as a table entry only, not as a drawn flow	Ready Capital Corporation, Form 10-K for 2020 SEC EDGAR; CIK 0001527590 — "approximately $2.7 billion" PPP facilitate..., Notes to consolidated financial statements, Paycheck Protection Program note (printed p. 155); PPP income table: 2020 total PPP related income $38,498k, net PPP related income $23,419k Ready Capital Corporation, Form 10-K for 2021 SEC EDGAR — "As of December 31, 2021, we had $941.5 million outstanding..., Note 20, Other income and operating expenses - Paycheck Protection Program (printed p. 154-155); dividends declared per share of common stock $1.66 (2021), $1.30 (2020), $1.60 (2019) (Selected financial data) Ready Capital Corporation Form 10-K for the fiscal year ended December 31, 2022, Note 20 - Paycheck Protection Program (printed p. 149-150) Ready Capital Corporation Form 10-K for 2023, Note 20 - Paycheck Protection Program income table
U-READYCAP-UNTRACED	ReadyCap Lending	Kept as net PPP income	destination	$157.8 million net PPP income, 2020–2023 · documented (not fee-only)	2020-2021 fees	documented		Kept as net PPP income. As a REIT the company distributes its earnings as dividends ($1.30 a share in 2020, $1.66 in 2021) with no PPP-specific use. The SBA file credits ReadyCap with 34,221 2020 loans it sold, so the $307.5 million model overstates what it kept.	Ready Capital's 10-Ks disclose the PPP economics and no use of funds. In 2020 it originated $114.7 million of loans and earned about $5.2 million of fees; the $2.5 billion it sourced under an April 28, 2020 lender-service agreement was sold to a third party (Customers Bank, per the SBA file) for $43.3 million. Its 2021 originations of $2.2 billion carry 'total net fees of $123.7 million ... deferred over the expected life of the loans and ... recognized as interest income' (10-K 2021, Note 20). Net PPP related income was $23.4 million (2020), $56.1 million (2021), $65.5 million (2022) and $12.8 million (2023). Checked: 10-K for 2020, 2021, 2022, 2023; EDGAR submissions index. Not found: A stated use of the PPP income.	drawn, not to scale	Ready Capital Corporation, Form 10-K for 2020 SEC EDGAR; CIK 0001527590 — "approximately $2.7 billion" PPP facilitate..., Notes to consolidated financial statements, Paycheck Protection Program note (printed p. 155); PPP income table: 2020 total PPP related income $38,498k, net PPP related income $23,419k Ready Capital Corporation, Form 10-K for 2021 SEC EDGAR — "As of December 31, 2021, we had $941.5 million outstanding..., Note 20, Other income and operating expenses - Paycheck Protection Program (printed p. 154-155); dividends declared per share of common stock $1.66 (2021), $1.30 (2020), $1.60 (2019) (Selected financial data) Ready Capital Corporation Form 10-K for the fiscal year ended December 31, 2022, Note 20 - Paycheck Protection Program (printed p. 149-150) Ready Capital Corporation Form 10-K for 2023, Note 20 - Paycheck Protection Program income table SEC EDGAR submissions index, Ready Capital Corporation (CIK 0001527590), retrieved September 30, 2026
U-HUNTINGTON-UNTRACED	The Huntington National Bank	Kept as interest income	destination	Amount not stated in full · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	Huntington's 10-K for 2022 states 'Net interest income for 2022 included $21 million in accelerated PPP loan fees recognized upon forgiveness payments from the SBA, compared to $126 million in 2021'; the 2021 10-Qs give $45 million (Q1), $30 million (Q2) and $30 million (Q3), and Q4 2020 was $5 million. By December 2021 the SBA had forgiven $9.4 billion of the $11.4 billion Huntington and TCF originated. These are the accelerated part only; scheduled amortisation of the fees is not separately disclosed. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021 (no call transcripts). Not found: A total PPP fee figure; a donation or pledge.	drawn, not to scale	Huntington Bancshares Incorporated Form 10-K for 2022 (filed Feb 17, 2023), p.49 — MD&A – Net interest income Huntington Bancshares Incorporated, Form 10-K for 2021 (filed Feb. 18, 2022), p.48 — MD&A – Economic overview Huntington Bancshares Incorporated, Form 10-K for 2020 (filed Feb. 26, 2021), p.48 — MD&A – Economic overview Huntington Bancshares Incorporated Form 10-Q for Q1 2021 (filed Apr 30, 2021), p.12 — MD&A – Net interest income Huntington Bancshares Incorporated Form 10-Q for Q2 2021 (filed Aug 6, 2021), p.12 — MD&A – Net interest income Huntington Bancshares Incorporated Form 10-Q for Q3 2021 (filed Nov 5, 2021), p.12 — MD&A – Net interest income
U-CITIZENS-UNTRACED	Citizens Bank	Kept as interest income	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	Citizens Financial's 10-K for 2020 credits Consumer Banking net interest income growth partly to 'the impact of the PPP loan program' and notes higher expenses 'tied to higher mortgage origination volumes and PPP loans'. Later filings only carve PPP balances out of loan tables: $4.2 billion at end-2020, $787 million at end-2021, $121 million at end-2022. No filing puts a number on the fees. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: A PPP fee figure; a donation or pledge.	drawn, not to scale	Citizens Financial Group Form 10-K for 2020 (filed Feb 23, 2021), MD&A – Business segments Citizens Financial Group Form 10-K for 2021 (filed Feb 23, 2022), MD&A – Commercial loans by industry (footnote) Citizens Financial Group Form 10-K for 2022 (filed Feb 17, 2023), MD&A – Commercial loans by industry (footnote) Citizens Financial Group Form 10-Q for Q2 2021 (filed Aug 3, 2021), MD&A – Consumer Banking
U-FIFTHTHIRD-UNTRACED	Fifth Third Bank	Kept as interest income	destination	Amount not stated as fees · unknown (PPP interest income $97M, $189M, $43M in 2020–2022, not fee-only)	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	Fifth Third's 10-K for 2021 says 'Interest income recognized from PPP loans also positively impacted net interest income by $189 million for the year ended December 31, 2021 compared to $97 million for the year ended December 31, 2020'; the 10-K for 2022 says it 'decreased to $43 million'. On the January 21, 2021 call management said 2020's roughly $100 million included 'only $10 million in accelerated forgiveness fees' and expected about $60 million of accelerated fees in 2021. The three years total $329 million, which includes the 1 percent coupon as well as fees. Checked: 10-K 2020, 2021, 2022; six 10-Qs 2020–2021; eight earnings calls 2020–2021. Not found: A fee-only total; a donation or pledge.	drawn, not to scale	Fifth Third Bancorp, Form 10-K for 2021 (filed Feb. 25, 2022), p.60 — MD&A – Net interest income Fifth Third Bancorp Form 10-K for 2022 (filed Feb 24, 2023), p.65 — MD&A – Net interest income Fifth Third Bancorp Form 10-Q for Q2 2021 (filed Aug 6, 2021), p.11 — MD&A – Net interest income Fifth Third Bank earnings call, Q4 2020 (Jan 21, 2021) (external), prepared remarks Fifth Third Bancorp Form 10-K for 2020 (filed Feb 26, 2021), p.64 — MD&A – Net interest income
U-REGIONS-UNTRACED	Regions Bank	Kept as interest income	destination	Amount not stated in full · unknown	2020-2021 fees	unknown		Kept as interest income. The fees were kept as net interest income.	Regions' Q2 2021 10-Q says 'Related SBA PPP net interest income totaled $43 million and $83 million for the three and six months ended June 30, 2021, respectively, and $18 million for both the three and six months ended June 30, 2020'; the Q3 2021 10-Q gives $31 million and $113 million for the three and nine months of 2021 and $31 million and $49 million for the same periods of 2020. The 10-K for 2021 says net interest income rose partly on 'increased PPP income. While PPP loan balances declined during the year, the fees related to loan forgiveness increased'. The 10-Ks carry no annual total. Checked: 10-K 2020, 2021, 2022; 10-Qs Q2 and Q3 2021 (no call transcripts). Not found: An annual PPP income total; a donation or pledge.	drawn, not to scale	Regions Financial Corporation Form 10-Q for Q2 2021 (filed Aug 6, 2021), p.74 — MD&A – Net interest income Regions Financial Corporation Form 10-Q for Q3 2021 (filed Nov 4, 2021), p.76 — MD&A – Net interest income Regions Financial Corporation, Form 10-K for 2021 (filed Feb. 24, 2022), p.50 — MD&A – Net interest income Regions Financial Corporation, Form 10-K for 2020 (filed Feb. 24, 2021), p.54 — MD&A – Net interest income Regions Financial Corporation Form 10-K for 2022 (filed Feb 24, 2023), MD&A
E-CELTIC-BLUEVINE-REFERRAL	Celtic Bank	BlueVine	referral/tech fee	Relationship, no width drawn · unknown	2020-2021	unknown	paid	Celtic payments to BlueVine: relationship documented, amount not public		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022), p. 73; BlueVine letter of Sept. 9, 2022
E-CELTIC-SQUARE-RELATION	Celtic Bank	Square Capital	relationship (servicing/channel)	Relationship, no width drawn · documented	2020	documented		Square channel for Celtic 2020 loans; any fee split not public		drawn	SBA PPP loan-level file (2024-09-30); Block Inc. Form 10-K 2020 (acc. 0001512673-21-000008) as logged in
E-CELTIC-WOMPLY-COLLECTED	Celtic Bank	Womply	referral/tech fee	$178,494.89 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $178,494.89; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
U-CELTIC-UNTRACED	Celtic Bank	Kept as bank capital	destination	Amount not stated · unknown	2020-2021 fees	unknown		Kept as bank capital. Most of the money remained in the bank's capital; dividends to the private parent stayed small.	Celtic publishes no PPP fee figure. Its Call Report data (FDIC, CERT 57056) show net income of $80.9 million in 2020 and $99.7 million in 2021 against $42.0 million in 2019, and noninterest income of $148.7 million in 2020 against $67.6 million in 2019 (the data do not say whether that reflects loan sales or partner fees). Cash dividends declared to the holding company were $4.0 million (2019), $3.0 million (2020), $11.0 million (2021), $11.0 million (2022) and $12.0 million (2023); equity grew from $193.3 million (2019) to $359.9 million (2021) and $548.8 million (2023). What Celtic paid Kabbage, Square, OnDeck and BlueVine is not public. Checked: FDIC Call Report data 2019Q4–2023Q4; FDIC institution record. Not found: A PPP fee figure; the partner fee splits; a pledge or donation.	drawn, not to scale	FDIC BankFind Celtic Bank CERT57056 financials 2019Q4-2023Q4, fields as above FDIC BankFind institution record, Celtic Bank (search result, September 30, 2026) Fdic Celtic Bank Cert57056 Financials 2019q4 2022q4
E-ALL2021-WOMPLY-REFERRAL	All Womply partner lenders and LSPs, 2021	Womply	referral/tech fee	$190,530,753 · documented	FY2021	documented	paid			not drawn: alternative measure of SUM(per-payer COLLECTED edges); shown with that flow, never added	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (PDF p. 52): 'PPP Referral Fee Revenue' FY 2021 $190,530,753.00; 'Total Net Revenue' $2,092,274,330.89, described as 'the total amount of fees for fiscal year 2021 that Womply has collected to date', not reflecting 'amounts owed but not yet paid' Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-ALL2021-WOMPLY-TECH	All Womply partner lenders and LSPs, 2021	Womply	referral/tech fee	$1,901,743,577.89 · documented	FY2021	documented	paid			not drawn: alternative measure of SUM(per-payer COLLECTED edges); shown with that flow, never added	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (PDF p. 52): 'PPP Technology Service Revenue' FY 2021 $1,901,743,577.89; 'Total Net Revenue' $2,092,274,330.89, described as 'the total amount of fees for fiscal year 2021 that Womply has collected to date', not reflecting 'amounts owed but not yet paid' Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
V3-AMEXKABBAGE-SHAREHOLDERS	American Express Kabbage	Kabbage's former shareholders	merger consideration	$730,159,391 · reported · not to scale	Oct. 16, 2020	reported	paid (alleged)		As part of the Amex Merger, Kabbage's former shareholders received $730,159,391	drawn, not to scale	Complaint, KServicing Wind Down Corp. v. Frohwein et al., Adv. No. 25-52372 (Bankr. D. Del.), Doc. 1 (Oct. 16, 2025), para. 273
V3-BENWORTHPR-NAVARROS	Benworth Capital Partners PR	Bernardo and Claudia Navarro	payments to owners	Amount unknown · unknown		unknown	paid, amount not stated		Q. Payments specifically to you and Mrs. Navarro? A. Yes.	drawn	Womply's letter to the arbitrator of Dec. 21, 2022 quoting Bernardo Navarro's deposition of Dec. 16, 2022, filed as D.P.R. No. 3:23-cv-01034, Doc. 163-1, Navarro deposition Vol. II 57:8-58:12 (Doc. 163-1 p. 9-10)
E-BLUEACORN-BLUEACORN_OWNERS-DISTRIBU	Blueacorn	Blueacorn owners	distribution	$258,000,000 · documented	2021 - Feb 2022	documented	distributed	Blueacorn outflow: Blueacorn owners		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022) (Blueacorn financials obtained by the Subcommittee), p. 26: $258M to owners; p. 2 summary says "nearly $300 million in profits to its ownership"; p. 21 "over $250 million"
E-BLUEACORN-BLUEACORN_ELIGIBILITY-EXPENSE	Blueacorn	Eligibility review costs	expense	$13,713,563 · documented	2021 - Feb 2022	documented	paid	Blueacorn outflow: Eligibility review costs		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022) (Blueacorn financials obtained by the Subcommittee), p. 27: eligibility $13,713,563 (1.26%)
E-BLUEACORN-BLUEACORN_FRAUD_PREVENTION-EXPENSE	Blueacorn	Fraud prevention costs	expense	$8,682,207 · documented	2021 - Feb 2022	documented	paid	Blueacorn outflow: Fraud prevention costs		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022) (Blueacorn financials obtained by the Subcommittee), p. 27: fraud prevention $8,682,207 (0.79%)
E-BLUEACORN-PAYNERD-EXPENSE	Blueacorn	Paynerd / Paynerdier	expense	$666,000,000 · documented	2021 - Feb 2022	documented	paid	Blueacorn outflow: Paynerd / Paynerdier (marketing and lead generation vendor)		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022) (Blueacorn financials obtained by the Subcommittee), p. 26: $666M to Paynerd, "founded and operated by Blueacorn Strategic Advisor Matt Mandell and Blueacorn Chief Marketing Officer Taylor Hendricksen"
E-BLUEACORN-BLUEACORN_TECHNOLOGY-EXPENSE	Blueacorn	Technology costs	expense	$51,597,240 · documented	2021 - Feb 2022	documented	paid	Blueacorn outflow: Technology costs		drawn	House Select Subcommittee on the Coronavirus Crisis, 'We Are Not the Fraud Police' (Dec. 1, 2022) (Blueacorn financials obtained by the Subcommittee), p. 27: technology $51,597,240 (4.75%)
E-BLUEACORN-WOMPLY-COLLECTED	Blueacorn	Womply	referral/tech fee	$0 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': BA Fin Orion, LLC d/b/a Blueacorn, referral '-', technology '-' Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-BLUEACORN-WOMPLY-CLAIM	Blueacorn	Womply	claim	$76,714,482.67 · reported · not to scale	2021 (invoices July 21 and Aug. 4, 2021)	reported	billed			drawn, not to scale (panel 3)	First Amended Complaint, Oto Analytics, Inc. d/b/a Womply v. Capital Plus Financial, LLC, Crossroads Systems, Inc., Eric Donnelly, BA Fin Orion, LLC d/b/a Blueacorn and Barry Calhoun, N.D. Tex. 3:21-cv-02636 Doc. 20 (Dec. 23, 2021), paras. 61-65 (Referral Agreement and Order Form with Blueacorn, both dated May 10, 2021; referral 1% of balance, s. 2.2; technology fee 'the first $250 from any Lender Processing Fee, plus 1/3 of the remaining', s. 3.3, reduced by referral fee, s. 3.4); paras. 77-79 (owed 'more than $9 million in Referral Fees and more than $67 million in Technology Fees'); para. 88 (demand $76,714,482.67)
E-BLUEACORN-WOMPLY-SETTLEMENT	Blueacorn	Womply	claim	Amount unknown · unknown · not to scale	Nov. 2022 - Jan. 2023	unknown	paid			drawn, not to scale (panel 3)	Reconciliation of the court and House records (our arithmetic), (settlement terms not public)
V3-BLUEACORNOWNERS-REIS_HOCKRIDGE	Blueacorn owners	Nathan Reis and Stephanie Hockridge	owner share of profit distributions (modeled)	$129,000,000 · modeled	2021 - Feb. 2022	modeled	modeled from the House report: the stake "could have entitled Mr. Spirakus to $129 million, while Mr. Reis and Ms. Hockridge would have shared the other half" (p. 27)		This ownership stake could have entitled Mr. Spirakus to $129 million, while Mr. Reis and Ms. Hockridge would have shared the other half.	drawn	House Select Subcommittee on the Coronavirus Crisis, staff report "We Are Not the Fraud Police" (Dec. 1, 2022), p. 27 (PDF p. 29)
V3-BLUEACORNOWNERS-SPIRAKUS	Blueacorn owners	Noah Spirakus	owner share of profit distributions (modeled)	$129,000,000 · modeled	2021 - Feb. 2022	modeled	modeled from the House report: the stake "could have entitled Mr. Spirakus to $129 million" (p. 27)		This ownership stake could have entitled Mr. Spirakus to $129 million, while Mr. Reis and Ms. Hockridge would have shared the other half.	drawn	House Select Subcommittee on the Coronavirus Crisis, staff report "We Are Not the Fraud Police" (Dec. 1, 2022), p. 27 (PDF p. 29)
R-CROSSROADS-CAPPLUS-OWNERSHIP	Crossroads Systems, Inc. (now Crossroads Impact Corp.)	Capital Plus Financial, LLC	relationship (ownership)	Ownership relationship, no amount, no width drawn · documented	since 2017-12-18	documented	ownership (a relationship, never a payment)	Parent-subsidiary relationship		drawn	Crossroads FY2021 annual disclosure (acquisition of 100% of CPF common equity, Dec. 18, 2017); FY2023 audited statements note 1 and note 17
E-CAPITAL_PLUS_RETAINED-CROSSROADS_SHAREHOLDERS-DISTRIBU	Crossroads Systems, Inc. (now Crossroads Impact Corp.)	Crossroads Systems, Inc. shareholders	distribution	$238,900,000 · documented · not to scale	July 26, 2021	documented	distributed	Owner distribution; tie to PPP fees is alleged, not stated by the company		drawn, not to scale	Crossroads press release, July 15, 2021; Q2 FY2021 shareholder letter
V3-CRSS-HOLDERS-VOSE	Crossroads Systems, Inc. shareholders	Charles A. Vose III	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		485,474 shares, 8.1% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
V3-CRSS-HOLDERS-WEBB	Crossroads Systems, Inc. shareholders	Clark Webb	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		646,143 shares, 10.8% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
V3-CRSS-HOLDERS-DONNELLY	Crossroads Systems, Inc. shareholders	Eric Donnelly	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		718,590 shares, 12.0% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
V3-CRSS-HOLDERS-GIGA	Crossroads Systems, Inc. shareholders	Farzana Giga	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		618,683 shares, 10.4% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
V3-CRSS-HOLDERS-CROCKETT	Crossroads Systems, Inc. shareholders	Mark Crockett	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		466,233 shares, 7.8% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
V3-CRSS-HOLDERS-ALPERT	Crossroads Systems, Inc. shareholders	Robert Alpert	dividend (share of the July 2021 special dividend)	Amount unknown · unknown	July 26, 2021 (dividend); holding as of Oct. 31, 2021	unknown	holder of record not stated		546,142 shares, 9.1% of the 5,971,994 shares outstanding as of October 31, 2021	drawn	Crossroads Systems, Inc., Annual Disclosure Statement for the fiscal year ended Oct. 31, 2021 (OTC Markets), Item 11, beneficial ownership table as of Oct. 31, 2021
E-DREAMSPRING-WOMPLY-COLLECTED	DreamSpring	Womply	referral/tech fee	$25,177,391.25 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $1,376,371.64; technology service $23,801,019.61 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-FUNDBOX-WOMPLY-COLLECTED	Fundbox	Womply	referral/tech fee	$132,851.23 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $132,851.23; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-FUNDINGCIRCLE-WOMPLY-COLLECTED	Funding Circle	Womply	referral/tech fee	$1,287,523.37 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $1,287,523.37; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
V3-KABBAGE-AMEXKABBAGE-PPPCASH	Kabbage	American Express Kabbage	asset transfer (cash earned from the PPP)	$120,000,000 · reported	Oct. 13, 2020	reported	transferred (alleged)		On October 13, 2020, Kabbage transferred virtually all of the company's valuable assets (including those of its wholly owned subsidiaries) to AmEx Kabbage, including $120 million in cash earned from the PPP.	drawn	Complaint, KServicing Wind Down Corp. v. American Express Kabbage Inc. et al. (Bankr. D. Del., Oct. 16, 2025; main case Doc. 1177), para. 28, p. 16; Frohwein complaint para. 8
V3-KABBAGE-US-FCA-PAID	Kabbage	United States	False Claims Act settlement (allowed claim)	$0 · documented	settled May 2024; paid to Mar. 31, 2026	documented	paid to date		d. General unsecured claims $0 $0 $0 $246,770,917 0%	drawn	Post-confirmation report for the quarter ending Mar. 31, 2026, In re KServicing Wind Down Corp., No. 22-10951 (Bankr. D. Del.), Doc. 1202, Part 3, line d (general unsecured claims: paid cumulative $0)
E-KABBAGE-WOMPLY-COLLECTED	Kabbage	Womply	referral/tech fee	$3,669.26 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $3,669.26; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-LENDIO-WOMPLY-COLLECTED	Lendio	Womply	referral/tech fee	$335,937.22 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $335,937.22; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
V3-HOCKRIDGE-RESTITUTION	Nathan Reis and Stephanie Hockridge	United States	restitution order (not a payment)	at least $63,000,000 · documented · not to scale	ordered Nov. 21, 2025	documented	ordered		The defendant was also ordered to pay over $63 million in restitution.	not drawn: a court order, not a record of payment; shown in the tables and details only	U.S. Department of Justice, "Co-Founder of Paycheck Protection Program Lender Service Provider Sentenced for $63M COVID-19 Relief Fraud Scheme" (Nov. 21, 2025), release text
V3-REIS-RESTITUTION	Nathan Reis and Stephanie Hockridge	United States	restitution order (not a payment)	at least $66,000,000 · documented · not to scale	ordered Dec. 18, 2025	documented	ordered		The defendant was also ordered to pay over $66 million in restitution.	not drawn: a court order, not a record of payment; shown in the tables and details only	U.S. Department of Justice, "Co-Founder of Paycheck Protection Program Lender Service Provider Sentenced for $65M COVID-19 Relief Fraud Scheme" (Dec. 18, 2025), release text
E-ONDECK-WOMPLY-COLLECTED	On Deck Capital	Womply	referral/tech fee	$5,834 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $5,834.00; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-ATLAS-AWARD	Oto Analytics, LLC (surviving company)	Atlas Technology Group	claim	$27,174,614.43 to $34,866,758.99 · documented	final award Aug. 24, 2023	documented	owed			drawn (panel 2)	Verified Petition to Confirm Arbitration Award, Atlas Technology Group, LLC v. Oto Analytics, LLC, Del. Ch. No. 2023-0900 (Sept. 1, 2023), paras. 15-17: damages $27,174,614.43; interest $3,521,904.48 to Aug. 11, 2023 plus $7,817.35/day; fees $4,130,539.69; costs $39,700.39; para. 20: not satisfied as of Sept. 1, 2023
E-ATLAS-PAID	Oto Analytics, LLC (surviving company)	Atlas Technology Group	claim	Amount unknown · unknown	2023-	unknown	paid			drawn (panel 2)	Reconciliation of the court and House records (our arithmetic)
E-FTC-JUDGMENT	Oto Analytics, LLC (surviving company)	Federal Trade Commission	claim	$26,000,000 · documented	entered Apr. 3, 2024	documented	owed			drawn (panel 2)	Stipulated order, FTC v. OTO Analytics, Inc. and Toby Scammell, N.D. Cal. 3:24-cv-01661 Doc. 10 (entered Apr. 3, 2024), Section II (monetary judgment $26,000,000, jointly and severally against both defendants; counsel to hold in escrow within 10 days of signatures; payment within 7 days of entry)
E-PAYINGAGENT-ESCROW	Paying agent for the Dec. 2021 merger	Secondary Escrow Fund	escrow	$630,720,000 · documented	at closing, Dec. 2021	documented	allocated			drawn (panel 2)	Atlas Technology Group, LLC v. Oto Analytics, LLC (fka Oto Analytics, Inc., dba Womply), AAA Interim Award (July 10, 2023), paras. 16, 44 ('$630,720,000.00 was deposited in a "Secondary Escrow Fund."')
E-PAYINGAGENT-SHAREHOLDERS	Paying agent for the Dec. 2021 merger	Womply's selling shareholders	sale allocation	up to $460,264,577.30 · arithmetic	at closing, Dec. 2021	arithmetic	distributed			drawn (panel 2)	Reconciliation of the court and House records (our arithmetic), $1,090,984,577.30 - $630,720,000 = $460,264,577.30 (ceiling)
V3-PAYNERD-PRINCIPALS	Paynerd / Paynerdier	Matt Mandell and Taylor Hendricksen	owner payouts	Amount unknown · unknown		unknown	not stated		$666 million of the $1.08 billion in taxpayer funded SBA processing fees that Blueacorn received—well over half of the total—went to Paynerd (also known as Paynerdier), a marketing company founded and operated by Blueacorn Strategic Advisor Matt Mandell and Blueacorn Chief Marketing Officer Taylor Hendricksen.	drawn	House Select Subcommittee on the Coronavirus Crisis, staff report "We Are Not the Fraud Police" (Dec. 1, 2022), p. 26 (PDF p. 28) The House report is a partisan staff document released by the Democratic majority's staff in the final weeks of the 117th Congress, with no public hearing and no sworn testimony; an arbitrator refused it as "rank hearsay" that relied on companies then in arbitration with Womply, and a federal judge declined to take judicial notice of its findings (about the report).
E-ESCROW-FTC-PAID	Secondary Escrow Fund	Federal Trade Commission	claim	Amount unknown · unknown	2024	unknown	paid			drawn (panel 2)	Reconciliation of the court and House records (our arithmetic)
E-ESCROW-SHAREHOLDERS-RELEASES	Secondary Escrow Fund	Womply's selling shareholders	release	Amount unknown · unknown	2022-	unknown	distributed			drawn (panel 2)	Reconciliation of the court and House records (our arithmetic)
E-SMARTBIZ-WOMPLY-COLLECTED	SmartBiz Loans	Womply	referral/tech fee	$22,286,718.32 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $22,286,718.32; technology service $0.00 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-SUNSHINE-WOMPLY-COLLECTED	Sunshine State Economic Development	Womply	referral/tech fee	$10,297,907.68 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $397,741.22; technology service $9,900,166.46 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-TMC-WOMPLY-COLLECTED	TMC Financing	Womply	referral/tech fee	$33,000 · documented	cumulative to Apr. 14, 2022	documented	paid			drawn	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release, Womply response of Apr. 14, 2022, p. 3 (PDF p. 16), 'Fees' table: fees 'Womply has collected from Lenders and Platforms to date'; the table 'does not reflect amounts owed but not yet paid': referral $3,732.37; technology service $29,267.63 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, Apr. 14, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-WOMPLY-TAX	Womply	Income taxes	tax	Amount unknown · unknown	FY2021	unknown	paid			drawn (panel 2)	Reconciliation of the court and House records (our arithmetic)
E-WOMPLY-RETAINED	Womply	Oto Analytics, LLC (surviving company)	retained	$217,175,000 · reported	at closing, Dec. 2021	reported	retained			drawn (panel 2)	Atlas Technology Group, LLC v. Oto Analytics, LLC (fka Oto Analytics, Inc., dba Womply), AAA Interim Award (July 10, 2023), para. 9 ('over $217,175,000 of cash that remained on the company's balance sheet at the close'), para. 37
E-WOMPLY-PAYINGAGENT	Womply	Paying agent for the Dec. 2021 merger	sale allocation	$1,090,984,577.30 · documented	Dec. 2021 (at least three days before closing)	documented	allocated			drawn (panel 2)	Atlas Technology Group, LLC v. Oto Analytics, LLC (fka Oto Analytics, Inc., dba Womply), AAA Interim Award (July 10, 2023), paras. 15 ('total amount of balance sheet cash allocated to stockholders in the December 2021 Merger - before reductions for contributions into escrow - was $1,090,984,577.30'), 41 (transferred 'off Womply's balance sheet to the Wilmington Trust at least three days prior to closing'), 42
E-WOMPLY-VENDORS	Womply	Third-party technology providers in Womply's platform	expense	Amount unknown · unknown	2021	unknown	paid			drawn (panel 2)	JAMS Corrected Final Award, Oto Analytics d/b/a Womply v. Benworth Capital Partners, LLC, JAMS Ref. No. 1210038203 (June 26, 2024), filed as N.D. Cal. 3:24-cv-03975 Doc. 1-4, award p. 24: 'Womply paid these third-party service providers for their technology'; vendor names: Harvest Order Form s. 1.2 (PDF p. 342), N.D. Tex. FAC para. 64
E-WOMPLY-UNEXPLAINED	Womply	Unexplained difference in closing cash: unexplained (reconciliation item)	unknown	$105,187,422.70 · arithmetic · not to scale	Dec. 2021	arithmetic				drawn, not to scale (panel 2)	Reconciliation of the court and House records (our arithmetic), $1,413,347,000 - $1,090,984,577.30 - $217,175,000
E-WOMPLY-OTHEREXP	Womply	Womply 2021 'other income expenses'	expense	$379,289,000 · documented	FY2021	documented	paid			drawn (panel 2)	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (the House Womply document release PDF p. 52): 'other income expenses ($379,289,000)'; House report p. 57 ('$379 million') Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-WOMPLY-COSTREV	Womply	Womply 2021 cost of revenue	expense	$261,166,000 · documented	FY2021	documented	paid			drawn (panel 2)	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (the House Womply document release PDF p. 52): 'total cost of revenue from its entire business... of $261,166,000'; gross profit $1,843,135,000 (87.6%) Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-WOMPLY-NETINCOME	Womply	Womply 2021 net income	retained	Relationship, no width drawn: recorded amount $1,303,153,000 · documented	FY2021	documented	profit			drawn (panel 2)	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (the House Womply document release PDF p. 52): 'Womply's net income for its entire business was $1,303,153,000' Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-WOMPLY-OPEX	Womply	Womply 2021 operating expenses	expense	$160,692,000 · documented	FY2021	documented	paid			drawn (panel 2)	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (the House Womply document release PDF p. 52): 'operating expenses ($160,692,000)'; House report p. 57 ('$160 million') Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)
E-REFERRAL2020-WOMPLY	Womply referral-channel partners, 2020	Womply	referral/tech fee	$2,934,899 · documented	2020	documented	paid			not drawn: alternative measure of SUM(per-partner COLLECTED referral fees); shown with that flow, never added	House Select Subcommittee document release 'Womply_Batched_Docs_With_Redactions.pdf' (linked as 'Womply' from the Dec. 1, 2022 press release); letters from Womply's counsel to Chairman Clyburn, Womply letter Jan. 14, 2022, PDF p. 4, resp. 1: 'PPP Referral Revenue' 2020 $2,934,899 House Select Subcommittee document release 'Womply_Batched_Docs_With_Redactions.pdf' (linked as 'Womply' from the Dec. 1, 2022 press release); letters from Womply's counsel to Chairman Clyburn (original) (external)
E-OTHERCUST-WOMPLY	Womply's non-PPP customers	Womply	fee	$12,025,669.11 · arithmetic	FY2021	arithmetic	paid			not drawn: outside the PPP fee flow (womply_other_revenue); shown only in the separate explanatory panel	Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release, Womply response May 20, 2022, p. 14 (the House Womply document release PDF p. 52): gross revenue 'from its entire business (not only PPP-Related Services)' $2,104,300,000 minus PPP net revenue $2,092,274,330.89 Oto Analytics, Inc. d/b/a Womply (Willkie Farr & Gallagher), Response to Certain Requests for Information, May 20, 2022, in the House Select Subcommittee's Womply document release (original) (external)

Top 25 lenders

Top 25 lenders by gross SBA PPP processing fees, with onward flows and coverage
Chart	Rank	Lender	Gross fees · status	By year	Onward flows	Coverage	Sources
	1	JPMorgan Chase Bank	$1,700,183,418.42 · modeled	2020: $1,033,208,375.08 · modeled; 2021: $666,975,043.33 · modeled	Kept as interest income: Amount not stated · unknown; Programs that help small businesses: Relationship, no width drawn · documented	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	2	Bank of America	$1,491,138,677.80 · modeled	2020: $946,528,326.30 · modeled; 2021: $544,610,351.50 · modeled	Small businesses, communities and nonprofits: Relationship, no width drawn · documented; Kept as interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	3	Harvest Small Business Finance	$1,074,907,943.72 · documented	2020: $39,041,928.51 · documented; 2021: $963,589,998.59 · documented	Retained by Harvest: $319,282,668.92 (fiscal 2021) · documented; Womply: $1,028,061,422.80 · documented; Womply: $537,453,971.86 to $755,625,274.80 · documented; Womply: $272,436,148 · arithmetic; Womply: $785,808,462.82 · modeled	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: traced (documented); owner distributions: untraced	Locke Lord (for Harvest Small Business Finance, LLC) letter to Chairman Clyburn, Aug. 31, 2022, p. 3, resp. 4(a): 'SBA paid Harvest $1,074,907,943.72 in fees from the SBA for PPP loans for which it was the lender' (House Select Subcommittee release 'Criminal_Section_Batched_Docs_With_Redactions.pdf'; Womply ledger edge the SBA → Harvest Small Business Finance entry of $1,074,907,944). Exceeds the model's $1,002.6M by $72.3M, unexplained.
	4	Prestamos CDFI	$1,055,074,365.58 · modeled	2020: $1,250,674.03 · modeled; 2021: $1,053,823,691.55 · modeled	Blueacorn: $700,000,000 · documented; Chicanos Por La Causa (parent nonprofit): up to $355,074,365.58 · arithmetic · not to scale; Kept by Chicanos Por La Causa (parent nonprofit): Amount not separately stated · unknown	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: traced (modeled); owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	5	Cross River Bank	$1,034,618,127 · modeled	2020: $293,983,258.23 · modeled; 2021: $740,634,868.77 · modeled	Kabbage: Relationship, no width drawn · unknown; BlueVine: Relationship, no width drawn · unknown; Intuit: Relationship, no width drawn · unknown; Kept as bank capital: Amount not stated · unknown; Womply: $1,583,902.99 · documented	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	6	Capital Plus Financial, LLC	$929,229,749 · documented	2020: $0 · documented; 2021: $929,229,749 · documented	Capital Plus Financial, LLC's lending service partners: $623,526,413 · documented; Blueacorn: $386,000,000 · reported; Blueacorn: Relationship, no width drawn: recorded amount $80,000,000 · documented; Capital Plus Financial, LLC: net PPP income: $256,860,836 · documented · not to scale; Crossroads Systems, Inc. (now Crossroads Impact Corp.): Balance, not a transfer: $304,252,816 · documented; Holders of Capital Plus Financial, LLC preferred units: $630,000 · documented · not to scale	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: traced (documented); owner distributions: untraced	Crossroads FY2021 annual disclosure (PPP administrative fees $868,422,947) + Crossroads Impact Corp FY2023 audited statements (FY2022 $50,774,445; FY2023 $10,032,357); and. About $10.6M was still deferred at FY2023 (lifetime about $939.8M); model $937.3M. All loans approved in 2021. Crossroads FY2021 annual disclosure (PPP administrative fees $868,422,947) + Crossroads Impact Corp FY2023 audited statements (FY2022 $50,774,445; FY2023 $10,032,357); and. About $10.6M was still deferred at FY2023 (lifetime about $939.8M); model $937.3M. All loans approved in 2021.
	7	Benworth Capital	$697,409,428.02 · modeled	2020: $1,139,891.01 · modeled; 2021: $696,269,537.02 · modeled	Kept by Benworth (private; no public accounts): Amount unknown · unknown; Womply: $464,991,236.65 · documented; Womply: $464,991,487 · documented; Womply: $616,664,869 · arithmetic; Womply: $551,291,379 · documented; Womply: $117,920,254.72 · documented · not to scale; Womply: Amount unknown · unknown · not to scale; Benworth Capital Partners PR: $171,000,000 · documented; Benworth Capital Partners PR: at least $50,000,000 · reported; Bernardo Navarro: at least $48,240,502.75 · reported · not to scale; Bernardo Navarro: at least $804,860.89 · reported · not to scale	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	8	Wells Fargo Bank	$690,000,000 · reported	2020: $420,000,000 · reported; 2021: $270,000,000 · reported	Open for Business Fund grantees: $420,000,000 · documented; Charitable recipients: Relationship, no width drawn · documented; Kept as interest income (2021 round): approximately $270 million of 2021 fees deferred · documented	technology referral partners: untraced; documented ppp costs: untraced; donations: traced (documented); net ppp income: untraced; owner distributions: untraced	Wells Fargo & Co. Form 10-Q Q2 2021 (acc. 0000072971-21-000267): 'funded approximately $3.5 billion of PPP loans in the first half of 2021 and deferred approximately $270 million of related SBA processing fees'. Model: $269.4M.
	9	Fountainhead SBF	$640,621,923.23 · modeled	2020: $15,524,081.15 · modeled; 2021: $625,097,842.09 · modeled	Retained by Fountainhead (private; no filed accounts): Amount unknown · unknown; Womply: $454,180,690.22 · documented; Womply: at least $90,000,000 · reported · not to scale; Womply: Amount unknown · unknown · not to scale; Womply: $496,379,672.48 · modeled	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	10	PNC Bank	$606,847,472.04 · modeled	2020: $392,000,388.53 · modeled; 2021: $214,847,083.51 · modeled	Kept as interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	11	Truist Bank	$588,456,509.34 · modeled	2020: $407,750,437.81 · modeled; 2021: $180,706,071.53 · modeled	Kept as interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	12	Customers Bank	$558,207,417.99 · modeled	2020: $111,456,266.81 · modeled; 2021: $446,751,151.18 · modeled	ReadyCap Lending: $43,300,000 · documented; Kabbage: $58,000,000 · documented; Kabbage: $22,055,340 · documented; Kabbage: $35,944,660 to $37,500,317 · documented; Kabbage: Relationship, no width drawn · unknown; Customers Bancorp: $424,100,000 · documented · not to scale; Kept as interest income: $424.1 million PPP interest income incl. net fees, 2020–2022 · arithmetic from the 10-Ks (not fee-only)	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: traced (documented); owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	13	Lendistry	$521,082,199.42 · modeled	2020: $8,639,905.97 · modeled; 2021: $512,442,293.45 · modeled	Kept by Lendistry (private; no public accounts): Amount unknown · unknown; Harvest Small Business Finance: Relationship, no width drawn · documented; Harvest Small Business Finance: Relationship, no width drawn · documented; Womply: Relationship, no width drawn · reported; Harvest Small Business Finance: Amount unknown · unknown; Womply: Amount unknown · unknown	technology referral partners: traced (modeled); documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	14	U.S. Bank	$506,938,700.70 · modeled	2020: $284,948,435.07 · modeled; 2021: $221,990,265.63 · modeled	Kept as interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	15	TD Bank	$497,913,518.16 · modeled	2020: $298,280,044.47 · modeled; 2021: $199,633,473.69 · modeled	Kept as U.S. Retail interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	16	Itria Ventures	$473,404,806.06 · modeled	2020: $5,823,161.98 · modeled; 2021: $467,581,644.08 · modeled	Biz2Credit: Relationship, no width drawn · reported; Kept by Itria / Biz2Credit (private; no public accounts): Amount unknown · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	17	KeyBank	$379,294,735.97 · modeled	2020: $244,007,549.84 · modeled; 2021: $135,287,186.12 · modeled	Kept as interest income: Amount not stated in full · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	18	Zions Bancorporation	$361,360,046.96 · modeled	2020: $220,686,902.85 · modeled; 2021: $140,673,144.10 · modeled	Zions foundation: $30,000,000 · documented; Kept as interest income: Amount not separately stated · unknown (PPP interest income $146M, $235M, $47M in 2020–2022, not fee-only)	technology referral partners: untraced; documented ppp costs: untraced; donations: traced (documented); net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	19	Manufacturers and Traders Trust Company	$337,888,668.38 · modeled	2020: $206,295,480.58 · modeled; 2021: $131,593,187.80 · modeled	Kept as interest income: Amount not stated in full · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	20	ReadyCap Lending	$307,457,260.52 · modeled	2020: $102,523,263.90 · modeled; 2021: $204,933,996.62 · modeled	Customers Bank: Relationship, no width drawn · documented; Ready Capital: $157,803,000 · documented · not to scale; PPP direct operating costs: $17,841,000 · documented; Kept as net PPP income: $157.8 million net PPP income, 2020–2023 · documented (not fee-only)	technology referral partners: untraced; documented ppp costs: traced (documented); donations: untraced; net ppp income: traced (documented); owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	21	The Huntington National Bank	$300,838,730.53 · modeled	2020: $200,998,233.29 · modeled; 2021: $99,840,497.24 · modeled	Kept as interest income: Amount not stated in full · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	22	Citizens Bank	$293,168,800.66 · modeled	2020: $165,617,686.57 · modeled; 2021: $127,551,114.10 · modeled	Kept as interest income: Amount not stated · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	23	Fifth Third Bank	$272,745,955.41 · modeled	2020: $165,922,643.53 · modeled; 2021: $106,823,311.88 · modeled	Kept as interest income: Amount not stated as fees · unknown (PPP interest income $97M, $189M, $43M in 2020–2022, not fee-only)	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	24	Regions Bank	$268,451,148.31 · modeled	2020: $156,805,944.69 · modeled; 2021: $111,645,203.62 · modeled	Kept as interest income: Amount not stated in full · unknown	technology referral partners: untraced; documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
	25	Celtic Bank	$233,058,941.75 · modeled	2020: $175,176,125.46 · modeled; 2021: $57,882,816.29 · modeled	BlueVine: Relationship, no width drawn · unknown; Square Capital: Relationship, no width drawn · documented; Kept as bank capital: Amount not stated · unknown; Womply: $178,494.89 · documented	technology referral partners: traced (documented); documented ppp costs: untraced; donations: untraced; net ppp income: untraced; owner distributions: untraced	Fee model (the published fee schedule applied to each SBA loan): SBA PPP loan-level file (release 2024-09-30) priced loan by loan under 85 FR 20811, 86 FR 3692, 86 FR 3712 (
No top-25 lender is part of this selection.

Gaps and unresolved balances

Gaps and unresolved balances in the Womply records
Gap	What would close it	Related flows
Lendistry: Contractual payer of any Womply fee on Lendistry-originated loans; no contract covering them is public; Lendistry absent from Womply's partner lists (Jan 14 and Apr 14, 2022) and from its per-payer collection table	A Womply-Harvest or Womply-Lendistry agreement or invoice naming Lendistry loans; Harvest or Lendistry statement	Lendistry → Womply
Lendistry: Terms of Harvest's purchase of Lendistry-originated loans (documented for one loan only) and whether Lendistry passed any SBA processing fee to Harvest	Loan-sale or participation agreement; SBA 1086/servicing transfer records; Lendistry financials	Lendistry → Harvest Small Business Finance
Harvest: Attribution of the $272,436,148.00 Womply collected from Harvest above the Harvest letter's own-loan ceiling ($755,625,274.80); consistent with fees on Lendistry-originated loans but not stated anywhere	Harvest invoice detail by loan; Harvest's full Aug 2, 2022 letter; Womply invoices to Harvest	Harvest Small Business Finance → Womply
Harvest: Harvest letter terms undefined: 'Fiscal Year 2021' and 'loans for which it was the lender'; SBA-paid $1,074,907,943.72 exceeds the model's Harvest-originated total ($1,002.6M, 2020+2021) by $72.3M	Harvest financial statements; SBA fee payment records by loan	SBA → Harvest Small Business Finance; Harvest Small Business Finance → Womply
Womply totals: Womply's per-payer collected table (Apr 14, 2022) sums to $2,008,556,579.88, $86,652,650.01 below its 2020+2021 PPP revenue ($2,095,209,229.89); gap is entirely technology fees	Womply revenue ledger by payer; later Womply letters	All Womply partner lenders and LSPs, 2021 → Womply
Collections after Apr 14 2022: Amounts collected after Apr 14, 2022, including settlements	Settlement agreements; Womply or payer financials	Benworth Capital Partners → Womply; Blueacorn → Womply; Fountainhead SBF → Womply
Benworth: Settlement amount (dismissal with prejudice Jan 2, 2025, confidential)	Settlement agreement	Benworth Capital Partners → Womply
Capital Plus / Blueacorn: Settlement amount (mediation Nov 14, 2022; dismissed Jan 5, 2023); whether any Womply fee sits inside Crossroads' $623.5M PPP processing-fee expense	Settlement agreement; Crossroads FY2022-23 notes; Blueacorn records	Blueacorn → Womply
Fountainhead: JAMS No. 1100-111-808 outcome; the 'on or about March 23, 2021' agreement and 'separate contract' (not in the release); any API fee	JAMS award or dismissal; the later agreements	Fountainhead SBF → Womply
DreamSpring / Sunshine / TMC: Contract terms not in the release; TMC Financing has no loans under that name as SBA originating lender (its $33,000 of fees imply loans under another name)	Agreements (Bates range House_Select_000003577-3890 is said to hold all Womply agreements; only Benworth, Harvest and Fountainhead pages are in the public batch)	DreamSpring → Womply; Sunshine State Economic Development → Womply; TMC Financing → Womply
Referral-only partners: Split of referral fees between 2020 and 2021 per partner; referral rates for partners other than Harvest	Agreements; Womply revenue by year and payer	Womply referral-channel partners, 2020 → Womply
Womply costs: Vendor spend (table in Jan 14, 2022 letter resp. 11 is fully redacted in the House release); 'invested more than $200 million' in Fast Lane technology is unitemized; composition of cost of revenue and of 'other income expenses'	Unredacted letter; Womply financial statements	Womply → Third-party technology providers in Womply's platform; Womply → Womply 2021 cost of revenue; Womply → Womply 2021 'other income expenses'
Taxes: Womply income tax for 2021 not in any record (may or may not sit inside 'other income expenses')	Womply financial statements or tax filings	Womply → Income taxes
Sale and escrow: Verified closing payments to shareholders; other holdbacks; escrow releases and remaining balance; $105,187,422.70 of closing cash unexplained; we do not have a copy of the SRS Acquiom escrow update of Mar. 27, 2024	Merger agreement and funds flow (Exh. J-31); escrow statements	Paying agent for the Dec. 2021 merger → Womply's selling shareholders; Secondary Escrow Fund → Womply's selling shareholders; Womply → Unexplained difference in closing cash: unexplained (reconciliation item)
Claims: Whether and from what funds the $26M FTC judgment and the Atlas award were paid; Del. Ch. 2023-0900 outcome	FTC payment confirmation; Del. Ch. docket	Secondary Escrow Fund → Federal Trade Commission; Oto Analytics, LLC (surviving company) → Atlas Technology Group
Womply as borrower: Final status of Womply's two PPP loans after SBA withdrew its forgiveness decisions (Dec 16, 2022); meaning of USAspending total_outlay on them ($3,156,819.17; $2,073,996.89)	SBA loan status; lender (Harvest) records	SBA → Womply
Scoped statement: SAM.gov entity registrations (UEI) not checked: anonymous search covers exclusions only; entity API needs a key. USAspending subaward coverage depends on FSRS reporting; the FPDS full vendor-name field returns 0 even for a control (the short vendor-name field was used)	SAM.gov entity API with a key; FSRS search
Model basis: lender_fees.csv figures are accruals assuming a fee on every loan (METHOD s.6); not verified receipts	Lender filings or SBA fee payment data