Profiles · Companies and entitiesControversial
- Type
- Company or group
- Role
- Lender or loan platform
- Programs
- PPP, PPPLF
- Updated
The profile
Individuals and companies whose conduct was challenged or called into question during or after the pandemic. See sources: House fintech report, Dec. 1, 2022 Clyburn letter, May 27, 2021 Banking Dive on SBA review, Dec. 9, 2022
- Type: State-chartered, FDIC-insured New Jersey community bank operating as fintech bank-of-record ("banking-as-a-service" / "Marketplace Lending").
- Legal entity: Cross River Bank, an insured state nonmember bank, FDIC Cert. 58410. Held through CRB Group, Inc. (privately held; not publicly traded as of mid-2026).
- Founded: 2008, by Gilles Gade.
- HQ / charter location: Corporate office at 400 Kelby Street, 14th Floor, Fort Lee, NJ 07024 (the address Chairman Clyburn's May 27, 2021 letter used). The insured charter is held out of Teaneck, New Jersey, which is the address on the FDIC consent order.
- CEO: Gilles Gade — founder, chairman, president and CEO since 2008, continuous through mid-2026.
- Role: Partner bank for consumer fintechs — Affirm, Upstart, Upgrade, Coinbase, Stripe, Rocket, Divvy, Gusto, Veem, and the small-business lenders BlueVine and Kabbage all originated through Cross River. In PPP it was lender of record for loans that reached it through fintech partners.
In the archive
- Lender page → Cross River Bank
- Case: Harborview Capital Partners, LLC v. Cross River Bank — D.N.J.
- Case: Wax v. Cross River Bank — U.S. District Court, District of New Jersey
- Interactive: PPP second draws followed the open door: 78,257 of 283,560 first-draw borrowers matched a 2021 loan, and Kabbage kept 26.1% of its own
- Interactive: The pandemic-relief machine: 50 actors, seven layers, and $1.16 trillion between Congress and 15 million loans
Pandemic-role map
- Reader shorthand: FDIC-insured partner bank / lender of record for fintech channels.
- What Cross River did for borrowers: funded PPP loans, often to small borrowers who reached the bank through fintech front ends rather than a Cross River branch relationship.
- What Cross River sold to other companies: supplied bank charter access, SBA lender status, compliance infrastructure, loan funding, and servicing handoffs to fintech partners that had borrower-facing software but no bank charter.
- Where responsibility sat: Cross River was the SBA lender of record on its own PPP approvals and drew PPPLF liquidity against the loans; fintech partners handled much of the customer interface and intake.
Before the pandemic (2008–early 2020)
Gade founded Cross River in 2008 on two ideas. First, a new bank with a clean balance sheet could buy distressed, government-guaranteed assets. Second, a small bank could compete by selling regulated infrastructure to consumer-facing technology partners. The fintechs would build the apps, run KYC, set marketing; Cross River would hold the charter, take the SBA or marketplace loan onto its balance sheet, and handle regulatory compliance.
By the late 2010s its fintech partners included Affirm (point-of-sale BNPL), Upstart and Upgrade (consumer installment), Coinbase and Stripe (payments), Rocket, Divvy, Gusto, Veem, and the small-business lenders BlueVine, Kabbage. Pre-pandemic investors included Battery Ventures, Andreessen Horowitz and Ribbit Capital (a $28 million round announced November 1, 2016) and KKR (a $100 million investment in 2018), per the bank's Wikipedia entry, a secondary source.
During the pandemic (March 2020 – mid 2021)
Cross River ended March 2020 with $2.53 billion in assets and June 2020 with $9.91 billion (FDIC call-report financials, 2019Q4–2022Q4). Of the $7.38 billion added in that quarter, $6.27 billion was PPP loans, and $6.12 billion of those were pledged to the Federal Reserve's PPP Liquidity Facility.
Customers and branches
On March 16, 2020, Gade wrote that the bank had "implemented a full 'work from home' policy" and was "100% operational" (COVID-19 Message from Gilles Gade). On March 18 it said it had offered "forbearance options and short-term loan products for eligible small business and commercial real estate borrowers" (Cross River Provides Assistance in Response to COVID-19 Pandemic). It also said it was working with its marketplace-lending platforms on "relief options." The release gave no terms, take-up or cost.
Upstart, one of those platforms, told the SEC that Cross River originated 72% of the loans on its platform in the nine months ended September 30, 2020 (Upstart Holdings, Inc., Form S-1). The same filing said its bank partners "tightened their credit requirements or paused originations" in response to the pandemic, and that hardship plans offered with them let borrowers defer payments for up to two months. It does not say which partner did what.
By March 27 the Teaneck branch had moved to a temporary location at 400 Kelby Street in Fort Lee, open for deposits and withdrawals only, 9 a.m. to 3 p.m. on weekdays (Coronavirus (COVID-19) Update). The Brooklyn Financial Center was temporarily closed. Teaneck reopened on July 28, 2020, by appointment, with masks and temperature checks required.
How the PPP book was built
Cross River said it partnered with "over 30 leading technology companies" and took PPP applications "without requiring preexisting banking relationships" (Cross River to Participate in Next Round of Paycheck Protection Program). In the same January 2021 release it said the first round had reached 198,738 small businesses with "more than $6.5 billion," an average loan of $33,000. SBA PPP loan-level data list 193,045 Cross River approvals dated 2020, totaling $6.40 billion.
At the June 30, 2021 peak the bank carried $11.23 billion of PPP loans, $9.95 billion of them pledged to the Fed facility, against $3.48 billion of deposits (FDIC call-report financials, 2019Q4–2022Q4).
By April 30, 2021, the company said it had "over 520 team members" and planned to hire 100 more by year-end (Cross River Deepens Roots in New Jersey with the Opening of New Headquarters in Fort Lee). No Cross River entry appears in New Jersey's WARN notice lists for 2020, 2021 or 2022 (2020, 2021, 2022).
What the bank earned
In December 2020, announcing two industry awards, Gade said: "At the very onset of the COVID-19 pandemic, Cross River recognized the extraordinary opportunity we had to help those in need" (Cross River Recognized for Its Leadership and Impact in 2020). Net income reported to the FDIC was $42.8 million in 2019, $91.1 million in 2020, $372.0 million in 2021 and $80.0 million in 2022 (FDIC call-report financials, 2019Q4–2022Q4). The 2021 figure is 8.7 times the 2019 one.
In August 2020 the parent, CRB Group, closed a $106 million private placement of subordinated notes paying 6.50% for the first five years, an offering Gade called "oversubscribed" (Cross River Completes $106 Million Subordinated Debt Offering). In November 2020 the bank's #CrossRiverStartMeUp contest offered New Jersey entrepreneurs a chance to win $5,000 (Cross River Launches Small Business Contest). In 2022 its grant program with the Brooklyn Chamber of Commerce was a $220,000 fund that paid grants of $1,000 to $5,000 (Cross River Teams Up with Brooklyn Chamber Again to Distribute Grants to Further Support Women and Minority Owned Businesses).
A suit over agent fees
On April 30, 2020, A.D. Sims LLC sued Wintrust, Bank of America, Cross River and an additional 4,971 named and unnamed defendants in federal court in the Northern District of Illinois (Wintrust Financial Corporation, Form 10-Q, quarter ended March 31, 2021). The plaintiffs alleged the banks had failed to pay PPP agent fees and that collective damages could exceed $3.8 billion. On December 27, 2020, legislation amending the CARES Act stated that lenders do not owe agents fees absent a fee agreement. The plaintiff then asked the court to dismiss the case, and on January 22, 2021, the court entered the voluntary dismissal.
PPP1
Going into PPP Cross River had 300 employees, according to American Banker.
Cross River's own June 9, 2020 release reported $4.7 billion approved in 105,000 loans, average size below $44,000, "the absolute lowest amongst national leaders". Gade said the bank "stepped up when others refused." A July 4, 2020 capture of the company's PPP page reported 120,000+ businesses, 750,000 jobs, average loan below $42,000 — and named the fintech servicing routes: Intuit QuickBooks borrowers to Intuit, Kabbage borrowers to Kabbage, everything else to Scratch.
By December 2020, Cross River ranked third in the country by loan count behind only Bank of America and JPMorgan, and twelfth by dollar volume. Banking Dive named it Company of the Year. Goldfeder (SVP public affairs): "Cross River merges the expertise of a bank with innovative offerings of a technology company every single day, and PPP was just an extension of that." The bank "didn't hire any new employees — it repurposed its resources internally". The House Subcommittee's May 2021 letter, citing American Banker, said Cross River's chairman had "admitted to 'diving headfirst into PPP without adding staff'" (Clyburn letter text).
May 27, 2021: the Clyburn letter
On May 27, 2021, House Select Subcommittee Chairman James E. Clyburn sent Gade a multi-page document-and-information demand as part of the subcommittee's fintech-PPP-fraud probe. Parallel letters went to Kabbage, BlueVine, and Celtic Bank.
The letter set out:
- Cross River, "a small New Jersey bank," had partnerships with 30+ fintechs including Affirm, Upgrade, Upstart, Divvy, Gusto, Intuit, Veem, BlueVine, and Kabbage: a "rent-a-charter" model in which the bank "typically agree[s] to ensure regulatory compliance and other banking rules, while the FinTech partners focus on user interfaces and platforms."
- The May 2021 SBA report had Cross River as the fifth-largest PPP lender by value with over 280,000 loans worth over $6.5 billion.
- The fee economics: roughly $2,200 per loan, "often sharing a portion with partner FinTechs," with an estimated ~$160 million paid to Cross River by U.S. taxpayers in PPP fees as of July 2020 alone, nearly doubling its previous year's net revenue."
- POGO's analysis: Cross River was involved in over 30% of the FinTech / bank-partner approved loans in early DOJ prosecutions, including United States v. Dinesh Sah (N.D. Tex.), United States v. Donald Franklin Trosin (N.D. Iowa), and United States v. Ahmad Kanan (W.D. Wis.): borrower-fraud cases in which Cross River was the funding bank.
- A request for SBA Form 3507, written fraud controls, AML / BSA / fraud-compliance headcount by week, denial rates, the bank's own estimate of fraudulent loans facilitated, and revenue/liability-sharing terms with every fintech partner.
PPP2
Cross River re-opened for second-draw and first-draw under the December 2020 Economic Aid Act. An August 16, 2021 capture of the post-program page reported 375,000+ businesses, average loan below $25,000, with ApplePie Capital and BlueVine now named alongside Kabbage and Intuit as 2020 origination partners, and Scratch as servicer for all 2021 loans. NJBIZ reported Cross River was the No. 6 lender for 2021, approving 288,932 loans for ~$6.6 billion at $22,787 average. SBA's September 2024 data list 285,821 Cross River approvals dated 2021: 200,772 first-draw and 85,049 second-draw.
The same NJBIZ piece reported that Cross River ended its Kabbage partnership in August 2020 over "process and documentation issues" that made it "a prudent risk management decision not to work with Kabbage during the 2021 PPP." The 2022 House report would credit Cross River with pushing BlueVine to reform its practices during PPP, "likely reducing fraud."
Program totals
Across both rounds, per SBA PPP loan-level data (Sept. 30, 2024 release), Cross River originated 478,866 PPP loans worth $12.89 billion, supporting a reported 1.44 million jobs, at an average loan size of $26,928; the Gilles Gade profile uses the same totals.
The statutory PPP schedule paid lenders 5% on the smallest loans, sliding down. SBA FOIA data crossed with the statutory fee schedule estimate Cross River earned ~$1.035 billion in SBA lender processing fees — roughly $2,160 per loan — of which about 72% was earned in the 2021 vintage ($294M on the 2020 round, $500M on 2021 first-draw, $240M on second-draw).
What the loans became
Of the 478,866 loans, 72,271, or 15.1%, carry the status "Charged Off" in SBA PPP loan-level data current to September 30, 2024, against 5.6% of all PPP loans. For Cross River's 2021 first-draw loans the share is 19.5%. The data do not record why a loan was charged off.
In DOJ borrower-fraud cases, Cross River is the defrauded bank
In the PPP criminal cases that name Cross River, the bank is the defrauded institution, not a defendant. In Sah (N.D. Tex.) a borrower used PPP money for a Bentley convertible and a fleet of luxury cars after wiring application-day money out of Cross River. In Trosin (N.D. Iowa), a Minnesota man used his own name as the business and his own SSN as the EIN, fraudulently claimed 120 employees, and pulled $1.2 million through Cross River. In United States v. Epstein (D. Md., sentenced May 8, 2025), a borrower fabricated employee counts and bank statements to defraud Cross River, BlueVine, and Celtic (DOJ release, May 8, 2025). None charges Cross River.
After the pandemic (mid 2021 – present)
March 2022: the $620M raise
In March 2022 Cross River raised $620 million in a round led by Eldridge and Andreessen Horowitz, with T. Rowe Price, Whale Rock, and Hanaco participating, reportedly valuing the bank at more than $3 billion (Cross River release, March 30, 2022; TechCrunch, March 30, 2022).
December 2022: SBA names Cross River among eight lenders it will investigate
A week after the House Subcommittee's December 1, 2022 fintech-PPP report, the SBA publicly suspended Blueacorn and Womply and said it would launch investigations into eight high-volume lenders: Cross River, Celtic, Customers, Fountainhead, Harvest, Capital Plus, Benworth, and Prestamos. Goldfeder told NJBIZ the framing was "outrageous" and pointed to $300M+ owed to Cross River by SBA for unpaid lender fees. As of September 2026, SBA has published no resolution of the Cross River investigation.
March 8, 2023: an FDIC fair-lending consent order
On March 8, 2023 Cross River entered a Consent Order with the FDIC, Docket FDIC-22-0040b, 34 pages, predicated on a May 3, 2021 Consumer Compliance Report of Examination.
The bank "neither admits or denies" the determinations. The findings:
- Unsafe or unsound banking practices tied to fair-lending compliance: failure to establish and maintain internal controls, information systems, and prudent credit underwriting practices in conformance with the Safety and Soundness Standards (Appendix A of 12 C.F.R. Part 364).
- Equal Credit Opportunity Act (ECOA) / Regulation B violations (15 U.S.C. § 1691 et seq.; 12 C.F.R. Part 1002).
- Truth-in-Lending Act (TILA) / Regulation Z violations (15 U.S.C. § 1601 et seq.; 12 C.F.R. Part 1026).
The Order's requirements are directed at the bank's "Marketplace Lending Compliance Management System." The Order required board-level fair-lending overhaul, prudent credit underwriting, self-correction of identified violations, FDIC non-objection before launching new credit products or onboarding new fintech partners, and ongoing monitoring.
The public Order makes no PPP-fraud determination and does not state whether any of the ECOA findings concern PPP approvals.
The lawsuits: a commercial dispute and a PPP over-funding recovery
Harborview Capital Partners v. Cross River Bank (D.N.J. 2:21-cv-15146-EP-SDA, filed 2021, active as of a May 14, 2024 order). A commercial wire-transfer and depositor-bank dispute.
Cross River Bank v. 3 Bea's Assisted Living LLC (D. Md. 8:21-cv-03210-TJS; 4th Cir. 23-2271). A PPP-specific recovery action: Cross River approved a PPP loan and funded the borrower $1,706,711 against a qualified maximum of $20,680, then sued to recover. On June 4, 2025 the Fourth Circuit issued an unpublished opinion (ECF 49) and judgment (ECF 50) vacating in part and remanding; the Fourth Circuit denied Cross River's rehearing motions and issued its mandate July 9, 2025. The D. Md. court issued a post-remand opinion on April 21, 2026. The case makes no fraud allegation against Cross River.
A development subsidiary in Jerusalem
Cross River continues to operate an Israeli development subsidiary in Jerusalem, the subject of an August 2022 Globes profile.
Where Cross River doesn't appear
Outside the FDIC fair-lending order:
- DOJ criminal charges against Cross River or Gade — none. The bank is named as a defrauded institution in borrower-fraud cases, never as a defendant.
- DOJ False Claims Act resolutions — none. Kabbage remains the only fintech PPP lender with a corporate FCA resolution.
- CFPB action — none located against Cross River.
- State-AG action against Cross River — none located.
- OCC action — n/a. Cross River is FDIC-supervised, not OCC.
- Federal Reserve action — none. The Federal Reserve has entered no action against Cross River over the PPP channel.
- SBA suspension — none. The December 8, 2022 SBA action suspended Blueacorn and Womply only; Cross River was placed under "investigation," and no public resolution of that investigation has surfaced.
- The 2022 House Subcommittee fintech-PPP report ("We Are Not the Fraud Police," Dec. 1, 2022) — Cross River is discussed in the report (named as one of the fintech-channel banks; credited with ending its Kabbage partnership in August 2020 and pushing BlueVine to reform) .
Current posture (as of mid-2026)
The FDIC consent order remains in force on the public record.
Related profiles
- Gilles Gade — founder, chairman, president and CEO
- Kabbage / K Servicing — major Cross River fintech partner; Cross River ended the relationship August 2020
- BlueVine — major Cross River fintech partner through both PPP rounds
- Customers Bank — fintech-channel bank; Federal Reserve written agreement Aug. 5, 2024
- Celtic Bank — fintech-channel bank; co-recipient of the May 27, 2021 Clyburn letter
- Blueacorn and Womply — lender service providers suspended by SBA in December 2022
Court records
- Harborview Capital Partners, LLC v. Cross River Bank — D.N.J. (No. 2:21-cv-15146)
Sources
Primary documents in this archive
- FDIC Consent Order, In re Cross River Bank, Teaneck, New Jersey (FDIC-22-0040b, issued under delegated authority March 8, 2023, 34 pp.): ENFORCEMENT FDIC Cross River Bank CONSENT ORDER 2023-03-08 (extracted text at FDIC-22-0040b Cross River Bank Consent Order 2023-03-08; summary at FDIC-22-0040b Cross River Bank Consent Order 2023-03-08).
- House Select Subcommittee on the Coronavirus Crisis, Chairman Clyburn to Gilles Gade, May 27, 2021 (document-and-information demand): 2021-05-27-clyburn to cross river re fintech ppp fraud (text at 2021-05-27-clyburn to cross river re fintech ppp fraud).
- Cross River Bank newsroom / Business Wire release, June 9, 2020 ("105,000 loans / $4.7B / avg. <$44k"): PRESS cross river newsroom top ppp lender-105000-loans 2020-06-09.
- Banking Dive, "Company of the Year: Cross River Bank," Dec. 9, 2020: PRESS banking dive company of the year cross river bank 2020-12-09.
- NJBIZ, "Cross River Bank caught in PPP lending report crosshairs," Dec. 14, 2022 (Kabbage cut-off in August 2020; $300M+ unpaid SBA fees; 2021 league-table position): PRESS njbiz cross river bank caught in ppp lending report crosshairs 2022-12-14.
- Cross River PPP page captures, July 4, 2020 and August 16, 2021: crossriver paycheck protection program 2020-07-04; crossriver paycheck protection program 2021-08-16.
- Cross River Bank v. 3 Bea's Assisted Living LLC, 4th Cir. 23-2271 / D. Md. 8:21-cv-03210-TJS (PPP over-funding recovery; CA4 vacatur and remand June 4, 2025) (post-remand opinion text at CASE MDD 8-21-cv-03210 Cross River v-3-Beas doc103 OPINION POST REMAND 2026-04-21).
- Harborview Capital Partners, LLC v. Cross River Bank, D.N.J. 2:21-cv-15146-EP-SDA (commercial dispute; active May 2024).
- FFIEC / FDIC call-report data 2019Q4–2022Q4: cross river bank 58410 2019Q4-2022Q4.
- Cross River, March 16, 2020: COVID-19 Message from Gilles Gade
- Cross River, March 18, 2020: Cross River Provides Assistance in Response to COVID-19 Pandemic
- Cross River, March 16, 2020: Coronavirus (COVID-19) Update
- SEC filing, November 5, 2020: Upstart Holdings, Inc., Form S-1 Registration Statement
- Cross River, January 6, 2021: Cross River to Participate in Next Round of Paycheck Protection Program
- Cross River, April 30, 2021: Cross River Deepens Roots in New Jersey with the Opening of New Headquarters in Fort Lee
- New Jersey Department of Labor and Workforce Development, 2020: 2020 WARN Notices
- New Jersey Department of Labor and Workforce Development, 2021: 2021 WARN Notices
- New Jersey Department of Labor and Workforce Development, 2022: 2022 WARN Notices
- Cross River, December 10, 2020: Cross River Recognized for Its Leadership and Impact in 2020
- Cross River, August 18, 2020: Cross River Completes $106 Million Subordinated Debt Offering
- Cross River, November 24, 2020: Cross River Launches Small Business Contest
- Cross River, November 22, 2022: Cross River Teams Up with Brooklyn Chamber Again to Distribute Grants to Further Support Women and Minority Owned Businesses
- SEC filing, May 7, 2021: Wintrust Financial Corporation, Form 10-Q for the quarterly period ended March 31, 2021
- Internal analysis: the project's lender-accountability ledger (Cross River as one of the four ~$1B-fee earners with no PPP-specific institutional penalty); SBA loan-level FOIA data and the statutory fee schedule.
External references
- FDIC Consent Order — official portal: Cross River 11f4bc5a1cdf (original: orders.fdic.gov · stored capture)
- Consumer Finance Monitor, "FDIC consent order with Cross River Bank indicates heightened scrutiny of bank-fintech partnerships" (May 2023): https://www.consumerfinancemonitor.com/2023/05/04/fdic-consent-order-with-cross-river-bank-indicates-heightened-scrutiny-of-bank-fintech-partnerships/ local copy
- ABA Banking Journal, "Cross River Bank enters consent order with FDIC over fair-lending compliance practices" (May 2023): ABA Banking Journal, "Cross River Bank enters consent order with FDIC over fair-lending compliance practices" May 2023 (original: bankingjournal.aba.com · stored capture)
- Cross River Bank, "$620 Million Capital Raise" press release (March 30, 2022): Cross River Bank, "Cross River Announces $620 Million Capital Raise" Mar. 30, 2022 — $620M round, Eldridge/a16z lead,... (original: crossriver.com · stored capture)
- TechCrunch, "Cross River Bank lands $620M at a $3B valuation" (March 30, 2022): TechCrunch, "Cross River Bank lands $620M at a $3B valuation" Mar. 30, 2022 (original: techcrunch.com · stored capture)
- American Banker, "Cross River chief prepares for PPP encore" (Dec. 8, 2020) — Gade "dove headfirst" quote: American Banker, "Cross River chief prepares for PPP encore" Dec. 8, 2020 — Gade "dove headfirst" remark (original: americanbanker.com · stored capture)
- New York Times, "The Tiny Bank that Got Pandemic Aid to 100,000 Small Businesses" (June 23, 2020): https://www.nytimes.com/2020/06/23/business/paycheck-protection-program-cross-river-bank.html local copy
- SBA, "Statement on House Select Subcommittee on the Coronavirus Crisis Report" (Dec. 8, 2022) — Womply / Blueacorn suspended; Cross River investigated, not suspended: SBA, "Statement on the House Select Subcommittee on the Coronavirus Crisis Report" Dec. 8, 2022 — "full investigation... (original: sba.gov · stored capture)
- Banking Dive, "SBA bars Womply, Blueacorn; investigates Cross River, Celtic, Customers" (Dec. 9, 2022): Banking Dive, "SBA bars Womply, Blueacorn; investigates Cross River, Celtic, Customers" Dec. 9, 2022 — Hurn cooperati... (original: bankingdive.com · stored capture)