Kabbage / K Servicing

Type: Atlanta-based fintech small-business lender. Before the pandemic it made working-capital advances and credit lines to small businesses online.¹² During PPP: by its own account, the second-largest PPP lender by application volume.³ After American Express bought its business in October 2020, the PPP loans stayed with the remaining company, which did business as KServicing and filed for Chapter 11 in 2022.
Legal entities: Kabbage, Inc., a Delaware corporation, which did business as KServicing after October 2020 and is now KServicing Wind Down Corp., the debtor in In re KServicing Wind Down Corp., No. 22-10951 (Bankr. D. Del.). American Express bought substantially all of its assets through Alpha Kabbage, Inc., later renamed American Express Kabbage Inc., a separate company that did not take the PPP portfolio.⁴³
Founded: 2008 by the company's account; the House Select Subcommittee's 2022 staff report and the estate's 2025 complaint say 2009.³⁵⁶ Atlanta, Georgia. The estate's complaint names Robert ("Rob") Frohwein and Kathryn Petralia as founders, and UGA Today credits Marc Gorlin as a co-founder.⁷
HQ: 730 Peachtree Street NE, Atlanta, Georgia 30308. Chairman Clyburn's May 27, 2021 letter was addressed to Suite 1100;⁸ the October 2022 bankruptcy petition gives Suite 470 and lists Suite 1100 as the address of American Express Kabbage Inc.⁹
CEOs: Frohwein (co-founder to the October 2020 sale). At K Servicing, Laquisha Milner, president and CEO at the October 2022 petition; the company said no director or executive officer from before the sale remained.³ Since June 20, 2023 the estate has been run by Wind Down Officer Jeremiah Foster of Resolute Commercial Services.¹⁰¹¹¹²
Role: Direct SBA PPP lender. It also processed and serviced PPP loans for Cross River Bank in the first round and Customers Bank in both rounds, and was program manager for Celtic Bank, the issuer of Kabbage Funding loans.³¹³ Kabbage said in June 2020, the House Select Subcommittee's report notes, that it was the direct lender for more than half its PPP volume.⁵

In the archive

Before the pandemic (2008 – March 2020)

Kabbage lent to small businesses online. Its bankruptcy declaration says it used machine-learning algorithms and data from public profiles to shorten loan approval significantly.³ TechCrunch reported at the time of the American Express deal that the company had raised nearly $990 million in debt and equity plus more than $3.5 billion in securitizations, and was valued over $1.2 billion in its 2017 SoftBank-led round.² At the 2022 bankruptcy filing its largest shareholders were SoftBank entities (19.8 percent together), BlueRun Ventures (13.6 percent), MDV (12.1 percent) and Thomvest (11.5 percent).³ It had an office in Bangalore, India, which the relator's complaint says performed data analytics among other tasks and was laid off in the spring-2020 furloughs.¹

TechCrunch reported on August 17, 2020 that Kabbage's business was "dropping off a cliff" in February and March; the company furloughed "a significant proportion of its staff" at the end of March and shut down its credit lines for SMBs in April.² Kabbage's own April 2 statement dates the lending pause to Sunday, March 29.¹³ Four days before that, a March 25 update to the board listed "four potential paths forward." One was to raise about $57 million to last through 2020, and another a roll-up with Silver Lake, TPG "or others." The other two read: "Sell company (conversation with Amex thus far, others to follow)" and "Pre-package BK with DIP financing."¹⁴

During the pandemic (March 2020 – October 2020)

What Kabbage did, March to October 2020

Kabbage paused its own lending on Sunday, March 29, 2020, and by August 8 had approved 297,587 PPP applications for $7 billion, by its own count.¹³¹⁵ Its customers had borrowed "nearly $3 billion" in all of 2019.¹⁵ The April 2 CEO statement called the switch "the logical, responsible and ethical choice," and said the government's response showed the crisis needed "at least $349 billion in SBA guarantees."¹³ Kabbage Funding loans were issued by Celtic Bank.¹³ A PPP loan carried an SBA guarantee, and the SBA paid the lender a processing fee on each loan.¹⁶

Customer programs. On March 18 Kabbage launched helpsmallbusiness.com, where consumers bought gift certificates of $15 to $500 from local businesses, with proceeds deposited through Kabbage Payments "as soon as the next business day." The release said "Kabbage will not profit."¹⁷ By March 31 it listed 14 partner companies, among them UPS, Gusto, The Hartford and Lendio, and said "hundreds" of small businesses were selling certificates.¹⁸ On April 3 Kabbage said Facebook would surface the offers in its mobile app.¹⁹ Kabbage's COVID-19 page of April 3 listed state and city grant programs and gave customers a script for their members of Congress: "Allow FinTechs to work with SBA in the CARES Act."²⁰ That page announced no payment deferral, fee waiver or hardship plan for existing Kabbage borrowers.²⁰

The PPP ramp, as the company reported it.

Date	Kabbage figure
Apr 7, 2020	37,000 applications, $3.5 billion requested²¹
May 18	110,000 SBA approvals, $3.5 billion; average $31,500, median $14,000²²
Jul 1	209,000 approvals, $5.8 billion; "third-largest PPP lender" by application volume²³
Aug 8	297,587 approvals, $7 billion; average $23,546, median $12,775; "second largest"¹⁵

New customers were 98% of approvals.¹⁵ On May 18 Frohwein said Kabbage would soon "disburse more dollars to small businesses than we did in all of 2019."²² In June it added a pre-filled application for Uber drivers, with a $500 minimum loan, and set its $29,000 average against the SBA's $113,000.²⁴²⁵

Automation. The company's August report said more than 75% of approved applications were "processed without human intervention or manual review," and that "for every 790 employees at major U.S. banks, Kabbage has one."¹⁵ Over the same months, the House Select Subcommittee found, Kabbage halved its Risk and Account Review staff, from 84 in April to 42 by June.²⁶

Whose name was on the loans. Kabbage said 55% of its loans were funded directly, 23% through Customers Bancorp and 22% through Cross River Bank.²³ SBA's public loan data lists Kabbage, Inc. as originating lender on 161,031 first-draw loans with $3,052,727,357 in initial approvals.²⁷ By count, that is 54% of the 297,587 approvals Kabbage reported. A partner bank owed Kabbage fees too: a 2022 Customers Bancorp 8-K records about $65.5 million in previously accrued fees payable by Customers Bank to KServicing. A settlement subject to bankruptcy-court approval would cut that to $58 million, less amounts KServicing owed the bank.²⁸

Other steps. Kabbage made Juneteenth a permanent company holiday on June 18²⁹ and opened Kabbage Checking on July 22 with no monthly fees and a 1.10% APY.³⁰

The sale. The October 16 closing note said Kabbage customers had accessed "over $16 billion" through its services.³¹ American Express's filings describe what it bought: a "recent acquisition of financial technology company Kabbage" (Q3 2020 release), "Completed the acquisition of Kabbage" among 2020 achievements (2021 proxy), and a first business checking account "in part resulting from the Kabbage technology platform" (10-K for 2021).³²³³³⁴ The company left behind kept lending. SBA data lists Kabbage, Inc. as originating lender on 18,787 second-draw loans for $264,365,797, nearly all approved from January to March 2021.²⁷

The March 24, 2020 OnDeck letter

Kabbage signed the fintech coalition letter, published under OnDeck's banner and on Womply's own press page, to congressional leadership asking Treasury to route "upwards of $500 billion" to small businesses through online and non-bank lenders, stating, "We seek no gain from this crisis." Frohwein and Petralia are both listed as "Co-Founder, Kabbage" in the signature block (archived letter text).

Who borrowed through Kabbage

Counting both draws, SBA's data list 179,818 loans under Kabbage's own name, and its first-draw loans were 3.1 percent of all first-draw loans dated 2020.²⁷ The loans were small. The median was $10,746, about half the program median of $20,690; 70.5 percent were under $20,000 and 77 percent reported a single job, against 46.3 and 52.5 percent across the program. Self-employed individuals and independent contractors held 62.4 percent of them, and one in five went to a Florida borrower.²⁷

The company's own tally, filed in its bankruptcy, is larger and includes the loans it processed for its two partner banks: 319,000 loans for $7.27 billion across both rounds. Of those, 122,000 ($3.05 billion) were Cross River Bank loans, 99,000 ($2.59 billion) Customers Bank loans and 97,000 ($1.62 billion) loans Kabbage made itself and pledged to the Federal Reserve's PPP Liquidity Facility.³

How a Kabbage loan was sized

A PPP loan was 2.5 months of the borrower's payroll, counting no more than $100,000 of pay per person, which works out to $20,833 for a one-person business. SBA guaranteed the loan, paid the lender a processing fee of 5 percent on loans up to $350,000, and let lenders rely on the borrower's own certifications.¹⁶³ Every dollar a formula added to a small loan added five cents to the lender's fee.

Kabbage's formula took the total wages in Box 1 of a borrower's W-3 and added Boxes 17 and 19, the state and local income tax withheld from those same wages. The tax was already inside Box 1, so it was counted twice.³⁵ David Berteletti, a Massachusetts accountant who used Kabbage's portal for two clients, did the arithmetic in the whistleblower complaint: $5,000 of wages and a 5 percent state tax became $5,250 of "gross wages."³⁶ According to the government's complaint, two employees with no payroll, accounting or tax background proposed the formula around April 6, 2020, and Spencer Robinson, the head of strategy, approved it.³⁵ On April 8 Robinson wrote to a colleague, "i'm worried about our calcs."³⁷

The warnings arrived within days, the government alleges. A CPA's feedback was posted on Slack on April 11, and a Twitter post on April 12 said Kabbage was "doubling up." The company's own head of tax weighed in, a partner bank complained on April 20, and on April 24 a CPA told Frohwein and Petralia of a "huge, glaring error." The formula was not changed until after a civil investigative demand from the U.S. Attorney in Massachusetts arrived in January 2021.³⁵³⁸ The government counts more than 53,000 inflated loans and more than $111 million of excess principal.³⁵ In its 2024 Massachusetts settlement, Kabbage's estate admitted the double count and put its reach at "tens of thousands of borrowers" and at least $100 million.³⁸

The $100,000 cap was handled with a question. Kabbage asked applicants whether anyone earned more than $100,000 and, if the answer was no, went no further; it never built the per-employee check a staff member proposed, the government alleges.³⁵ A presentation sent to Robinson on April 29, 2020 described loans where the "correct loan amount is $20K, SBA submission for $2mm."³⁵ In the Massachusetts settlement the estate admitted that counting pay over $100,000 raised at least 1,900 loans by at least $100 million. It also admitted that asking for IRS Form 940 figures raised more than 700 borrowers' loans by "at least several millions of dollars."³⁸ In May 2020, according to the estate's complaint, Robinson summed up the verification of loan amounts on Slack: "[W]e just did a poor job verifying [PPP loan amounts]. . . . [M]aybe they'll be auto forgiven."⁶

The documents give four figures for what Kabbage earned:

"over $190 million" in processing fees on more than 310,000 applications, in the Texas settlement's recital;³⁹
"over $217 million" from April to August 2020, in the government's complaint;³⁵
about $321 million of PPP revenue on an accrual basis, in Kabbage's June 2021 letter to Congress;⁴⁰
"at least $330 million," an outside estimate that Chairman Clyburn's letter cited from the Miami Herald.⁸

Fraud controls, in the company's own records

The government alleges that on April 3, 2020 Robinson approved dropping bank-account verification to cut manual review, over an employee's warning that "there will be Soooo much fraud." It also alleges that on March 31 the head of fraud reported a 20 percent fraud rate in Kabbage's existing products against a 5 percent industry average, and on April 12 that about a quarter of incoming PPP applications looked fraudulent. Robinson did not believe the April 12 figures, the complaint says; the head of fraud was reassigned within days and then fired by Petralia.³⁵ For applications submitted through April 17, 2020, Kabbage ran its fraud checks after the loan had gone to SBA through the E-Tran system but before disbursement, American Express later told Congress.⁴⁰

The Subcommittee set the halving of the review team against the volume: Kabbage funded about $1.6 billion of PPP loans in May 2020, $1.5 billion in June and more than $800 million in July. It moved the work to temporary contractors, and executives discussed setting "crystal clear" contractual expectations with them "in terms of output per hour."²⁶ In late April the chief technology officer wrote that the review process was "a wreck."⁴¹ Employees who finished manual reviews received about $24,675 in gift cards, from $50 to $1,400 each; American Express, answering for Kabbage, said the cards were not tied to approvals.⁴⁰

Alvarez & Marsal, hired to assess the program, found by June 11, 2020 that one of ten Kabbage-approved loans it tested had failed the automated business-identity check and three of ten lacked a required document. Kabbage had funded more than 120,000 loans by then, and the consultant concluded that "[o]verall" the program complied with SBA rules.⁴² A consultant's draft risk report, which the estate identifies as Alvarez & Marsal's, drew a different reaction. In a July 23, 2020 text thread filed by the defendants themselves, Frohwein wrote that the report "is going to kill our amex deal," that its findings were "all in red," and: "We're sending fraudulent data to the SBA. We aren't performing calculations correctly." Frohwein told the others to keep it privileged and to have the consultant "update that report and pull it back."⁴³⁶

A week earlier, on July 16, a reviewer in the #ppp-fraud Slack channel wrote: "I feel like the level of fraud we're reviewing is wildly underestimated." The reviewer, uncomfortable at having to pass almost everyone, cited applications with more than 600 matching devices. A manager answered that "a fundamental difference is the risk here is not ours - it is SBAs risk." Later in the thread the reviewer posted: "Dear Secret Service, Please make sure my dog goes to a good home before I end up in prison."⁴³ The next day Frohwein texted a colleague, "We are set up to manage a tolerable amount of fraud, right?" The colleague wrote that the company had weighed tighter fraud rules against losses and "we've come out ahead."⁴³

The House report and the government's complaint quote other lines from those months. Robinson wrote on July 8: "Essentially if there is no definitive proof of fraud ... then we have to let it through."⁴⁴ Petralia told a July 2 town hall that "[a]s long as we are following all of the requirements that SBA has for this program we are not liable for that fraud." In October, opposing a tool to flag fraud during forgiveness, Petralia told Frohwein: "There is no value in doing their jobs for them."³⁵ In May 2020 Kabbage's head of policy, Sam Taussig, wrote that loans for exactly $20,833, the one-person maximum, were not suspicious "given we're serving these markets"; Kabbage had approved nearly 9,000 of them, worth more than $183 million.⁴⁵ In September Taussig wrote that SBA's rules, not Kabbage, had created the fraud.⁴⁶

The banks receiving the money noticed. On July 17, 2020 a Wells Fargo representative wrote to Kabbage about an increase in fraudulent transactions confirmed by Kabbage, "including $18MM of new transactions that were flagged yesterday." Wells Fargo asked Kabbage to move its fund transfers to another bank.⁴⁷³⁵ In a separate chain that day, Kabbage's general counsel, L. Scott Askins, joked about one applicant: "OK you got me it was me—I'm behind little piglet soap company."⁴⁷⁶ The Little Piglet Soap Company had received a $414,375 PPP loan. Its purported owner, Ganell Tubbs of Little Rock, pleaded guilty to bank fraud and in March 2021 was sentenced to 41 months; restitution was set at $14,000 because the rest of the nearly $2 million in loans to two companies had been recovered, the Justice Department said.⁴⁸ On July 31 a Citibank fraud executive offered to send back funds still on hold from a $20,833 Kabbage loan to someone who owned no business. On September 22, writing about another loan, the same executive said the funds could no longer be held because no one at Kabbage had responded.⁴⁷

By the end of July 2020 Kabbage had filed 28 suspicious activity reports, the government alleges.³⁵ American Express later told Congress that, because of the volume, Kabbage began filing them in batches after discussions with FinCEN.⁴⁰ By September 10 its legal team counted about 50 grand jury subpoenas, 15 of them in the previous few days, and an in-house lawyer called it a "subpoena tornado!"⁶ When the Miami Herald asked about PPP fraud that month, Frohwein wrote that Kabbage needed to "crush" the story. A draft response put Kabbage's rejection rate at 0.2 percent of applications, against an 11 percent average for lenders. Askins asked whether that meant "we let stuff through." American Express objected to including the figure, and it was not given to the reporter, according to the estate.⁶

Fake farms and the loans prosecutors found

ProPublica reported in May 2021 that Kabbage had processed 378 loans worth $7 million to one-person businesses that did not appear in their states' corporate records, most of them self-described farms.⁴⁹ The House report's examples include "Deely Nuts," which got $20,833 in August 2020 for "tree nut farming" at an address that turned out to be a beachfront vacation rental in coastal New Jersey. Its papers implied an 82 percent gross margin, against a 13.61 percent average for farms. "Shaila Big Fresh Oranges" was an orange grove at a three-bedroom house in Minnesota, and a strawberry farm was flagged for a "fake passport" two weeks after its loan was approved. Three other purported farms, raising tomatoes, wheat and beef cattle, were confirmed fraudulent in March 2021, seven to eight months after funding, and Kabbage recovered none of the money.⁵⁰⁴⁵ SBA's data list 1,136 Kabbage loans under crop- or animal-production codes; 377 of them, a third, were later charged off.²⁷

A 2021 study by John Griffin, Samuel Kruger and Prateek Mahajan, published in the Journal of Finance in 2023, put Kabbage among the four lenders with the highest share of sampled borrowers with criminal records, all of them fintechs.⁵¹ One of its examples is 13 Kabbage loans to businesses at a single address, 11 of them for $53,229 and 10 jobs each.⁵¹ The government's complaint describes eleven loans, all for $53,229 and each for the same 10 employees, to companies at one address in Park Forest, Illinois, formed in July or August 2020.³⁵ Chairman Clyburn's May 2021 letter cited a Miami Herald, McClatchy and Anti-Corruption Data Collective investigation that found about 20 percent of the PPP loans it identified as suspicious had been approved by Kabbage.⁸

The same letter tied three criminal cases to Kabbage-approved loans. In one, Jean R. Lavanture (N.D.N.Y.) obtained a $1.3 million loan for a company that "existed only on paper," the letter says, and bought an 18-room Tuscan-style mansion in New Jersey and a riverfront motel outside Branson, Missouri. Lavanture pleaded guilty and was sentenced to 60 months.⁸⁵² The House report adds the May 2022 indictment of the actor who played the Red Power Ranger, whose Kabbage applications, prosecutors said, carried business names that differed across the supporting documents (United States v. Jason Lawrence Geiger, E.D. Tex. No. 4:22-cr-110).⁵ We do not have the outcome of that case. On August 19, 2026 a federal grand jury in the Northern District of Texas indicted two people over about 561 PPP loans of roughly $20,832 each, about $11 million in all, which the indictment says were built on fictitious Schedule C forms and routed through loan processors that included Kabbage.⁵³

The sale to American Express

Most of what is known about the sale comes from the two lawsuits Kabbage's estate filed in October 2025 and the internal records the defendants filed with their motions to dismiss. What the complaints say is allegation.

On March 29, 2020, the day Kabbage paused its own lending,¹³ Frohwein texted an American Express managing director that "Kabbage is positioned to make many billions ($) of loans" under the PPP.⁵⁴ American Express signed a non-disclosure agreement on April 3 and made its first offer, $450 million, on April 20, as an asset purchase that left out the PPP and older loan books.⁵⁴ Kabbage's head of data science told Frohwein the structure meant "we can say bye felicia to our outstanding bad debt."⁶ An American Express note said the "PPP book and servicing are being left behind in the entity we are not purchasing," while American Express would be able to market to those customers.⁵⁴ On June 9 Frohwein told the board a sale would "mitigate [the] risk of law suites [sic] around PPP." American Express moved to $550 million and then to $625 million plus whatever cash Kabbage held beyond what servicing required.⁶⁵⁴ Its public announcement on August 17 said: "Kabbage's pre-existing loan portfolio is not included in the purchase agreement."⁵⁵

American Express's diligence team asked about fraud. After a May 1 "Fraud Risk Deep Dive" call, Robinson texted colleagues that "it's a difficult spot for me to push back on the questions"; American Express's final readout said Kabbage's historical liability "cannot be precisely assessed."⁶⁵⁴ In early August it asked for a $62 million escrow. Frohwein reported the reply to the deal team: "I explained that if they want $62m in escrow, we want the purchase price increased by $100m."⁴³ The escrow settled at $37.5 million, alongside a solvency opinion for the company left behind, representation-and-warranty insurance and indemnities. Frohwein explained American Express's position to colleagues: "This is not about them saving us money. It's about separating legal liability."⁶

The solvency opinion took two tries. Houlihan Lokey, asked to leave out non-recourse assets and debt and to assume the PPP loans would be forgiven, declined the engagement on August 1, 2020; Duff & Phelps signed on August 5.⁶ Its August 11 analysis gave the company keeping the PPP book $15.85 million of cash against a $15.05 million servicing obligation and a possible $300,000 reimbursement to Mastercard, for a net asset value of $503,500.⁴³ It rested on management's assumptions of "Blanket Forgiveness" for loans under $150,000 and that lenders could shield themselves from liability through SBA's good-faith provisions.⁴³ The sensitivity case reserved $1 million for legal liabilities and $949,000 for PPP put-backs.⁴³ Kabbage's chief financial officer described the $1 million to deal counsel as "literally a reserve," with "no projected use of cash."⁴³ The complaints note that the $949,000 was less than 0.014 percent of the $7 billion Kabbage had processed.⁶

On October 13, 2020 Kabbage transferred substantially all its assets to Alpha Kabbage, including $120 million of cash earned from the PPP; the estate alleges American Express had that cash moved to itself between October 16 and 19.⁶⁵⁴ The night before closing, Cross River Bank said it would not consent, arguing the solvency opinion ignored Kabbage's contractual liabilities to it. Lawyers for Kabbage and American Express concluded Cross River had no consent right; Frohwein's words, as the complaint gives them, were "Drink ourselves to death."⁵⁴ The merger closed on October 16. Kabbage's bankruptcy schedules list the sale at $750,000,000.⁴ A press report before the announcement, citing a person familiar with the deal, said it could be worth as much as $850 million.⁵⁶

Former shareholders received $730,159,391, the estate alleges. The largest amounts went to SoftBank ($231.7 million), Reverence Capital Partners ($84.9 million), BlueRun ($66.2 million), MDV ($53.4 million) and Thomvest ($51.8 million). Frohwein received $29.9 million and Petralia $12.0 million, and each also received a $13.32 million retention bonus; retention bonuses for five officers came to $30,365,000.⁶ The company left behind kept about $17 million of cash, the PPP loans, and a license to go on using its own corporate name "until wind-down is complete."⁵⁷⁵⁸

K Servicing (October 2020 – October 2022)

A loan servicer with fewer than a dozen employees

The company that kept the loans traded as K Servicing because, as the estate's complaint against American Express puts it, the Kabbage trademark had gone with the assets.⁵⁴ Its court filings carry the footnote: "Kabbage is a trademark of American Express used under license; Kabbage, Inc. d/b/a KServicing is not affiliated with American Express."⁵⁹ It told the House Select Subcommittee in June 2021 that it had fewer than a dozen full-time employees. One of them had worked full time on anti-money-laundering, Bank Secrecy Act or fraud compliance from October 16, 2020 until May 2021, when that person moved to American Express. After that, some staff did the work part time, alongside a contracted firm.⁴⁰⁶⁰ Over one 13-week stretch, the Subcommittee reported, Kabbage funded more than 50,000 loans.⁶⁰

Customers Bank signed on again for the 2021 round, and from January 2021 the two originated about $800 million of new PPP loans; Cross River Bank did not take part.⁶¹ Kabbage's counsel said at the first bankruptcy hearing that the second-round loans had been "pretty clean."⁶² In February 2021 SBA suspended Kabbage's certification as a direct PPP lender over the state and local tax double count, according to the estate's complaints, and by late March K Servicing was sending second-draw applicants to SmartBiz, CNBC reported.⁶⁶³

Forgiveness

K Servicing ran forgiveness on American Express's systems under a transition services agreement. When SBA revised the forgiveness form in early 2021, the company says, American Express refused to update the platform; it hired Biz2Credit to build a new portal, and for nearly three months borrowers could not submit forgiveness applications at all.³ American Express's answer, in a 2023 court declaration, is that it "has fulfilled all of its obligations under the TSA, and much more."⁶⁴ On May 3, 2021 Kabbage stopped sending SBA forgiveness decisions on loans hit by the tax double count, and SBA then paused forgiveness on the whole portfolio for about three months and on about 53,000 loans for five months more.³⁸³

In April 2021 CNBC reached a K Servicing representative working from a call center in the Philippines who had never worked for Kabbage, and found a Facebook support group for its borrowers with more than 2,000 members.⁶³ By early January 2022, the Miami Herald reported, 54 percent of the 2020 PPP loans Kabbage approved had been forgiven, against 93 percent of all 2020 loans. On some of K Servicing's customer-service calls, the paper reported, "a rooster can clearly be heard crowing repeatedly in the background." K Servicing's CEO told the Herald that a majority of its PPP loans had been forgiven.⁶³

Six borrowers sued in federal court in Atlanta in March 2022 (Carr v. Kabbage, Inc. d/b/a K Servicing). They alleged that K Servicing denied forgiveness applications and then sent borrowers a DocuSign copy of the SBA form with the requested forgiveness amount changed to "$0.00." Representatives, they said, told borrowers who lacked a requested document "to make one up," and loans still under forgiveness review were sent to collections. The complaint added that K Servicing had not joined SBA's direct borrower forgiveness portal for loans of $150,000 or less, which more than 1,400 lenders had joined.⁶⁵ Kabbage answered that SBA's own instructions required lenders to enter $0.00 when forgiveness was denied.⁶⁶ On March 31, 2023 Judge Victoria Marie Calvert dismissed the case with prejudice. The CARES Act gives borrowers no private right of action, SBA rather than the borrowers paid Kabbage's fees, and "it is illogical to conclude that compliance with SBA guidance constitutes an unfair or deceptive practice," the order says.⁶⁷ The plaintiffs did not appeal, according to the estate's wind-down officer.⁶⁸

The $30 million SBA settlement and the investigations

In October 2021 Kabbage paid SBA $30 million over the tax double count, including $12.5 million for excess forgiveness SBA had already paid on about 8,994 loans. The settlement left False Claims Act liability open, and the partner banks contributed nothing.³⁸³ By then the investigations had started: civil investigative demands from the U.S. Attorney in Massachusetts in January 2021 and from the Justice Department's Civil Division in June 2021, and one from the Federal Trade Commission in February 2021 about the advertising, underwriting and servicing of PPP loans.³⁸³⁹³ The Justice Department, alleging $100,000-cap and Form 940 errors, flagged about 6,200 loans, $120 million of principal, and told the company not to process them for forgiveness.³ SBA said it would not guarantee the excess amounts and had placed hold codes on the affected loans by August 11, 2022.³³⁸

The company spent about $19 million on professional fees for these disputes in 2022 and about $11 million on staffing firms, and fielded more than 100 subpoenas a week from borrowers' bankruptcies and other cases.³ Its partner bank had stopped paying it. Customers Bank paid about $47 million of first-round fees on time but withheld the second-round referral and servicing fees, citing Kabbage's processing failures, and Kabbage sued the bank in May 2022.⁶¹

Congress

Chairman James Clyburn of the House Select Subcommittee on the Coronavirus Crisis wrote to Frohwein on May 27, 2021, asking for six categories of documents and answers to eleven questions.⁸ Kabbage told the Subcommittee it had disbursed about $6.2 billion to about 258,000 small businesses in the first round, at a median of about $13,000, and that its PPP revenue on an accrual basis was about $321 million.⁴⁰ American Express told the Subcommittee that it "expressly did not acquire" the PPP portfolio's liabilities: "Any regulatory obligations or issues related to Kabbage's PPP loans belong solely to Kabbage."⁴⁰

The Subcommittee's staff report of December 1, 2022, "We Are Not the Fraud Police," gives Kabbage its own section, drawn from what the Subcommittee said were more than 83,000 pages of internal documents gathered across its fintech inquiry.⁵⁶⁹ Clyburn sent the report to SBA's Inspector General the same day, naming Kabbage among the four fintechs the investigation focused on and asking for a review of PPP lenders and agents.⁷⁰ The report's findings carry no penalty.

Chapter 11 (October 2022 – present)

The filing

Kabbage, Inc. and five subsidiaries filed for Chapter 11 in Delaware on October 3, 2022 (Case No. 22-10951, Judge Craig T. Goldblatt).⁹ Two days earlier the Federal Reserve Bank of San Francisco, which had lent the company about $1.6 billion through its PPP Liquidity Facility, sent a notice of default; about $541 million was still outstanding at the end of September.³ The company had about $11 million of unrestricted cash, 18 full-time employees and about 163 contractors, and was servicing about 48,000 PPP loans with $1.3 billion outstanding.³ Its creditor list included about 456,000 current and former borrowers. Mailing them notice would have cost more than $500,000 in postage, so it asked to use email and notices in The New York Times and USA Today instead.³

The first-day declaration said the company "would not have participated in the PPP absent the 'minimal review'" the program required. It called the investigations "hindsight investigations and misdirected scrutiny," and said the company was using bankruptcy "to obtain a respite from having to constantly defend against the Disputes."³ At the first hearing, on October 6, the company's lawyer said it was "like a pinata almost here between all the various agencies" and called the investigations "revisionist history." Judge Goldblatt said the papers told "a compelling story" but that "I don't think any of the relief that you're asking me on the first day asks me to form a judgment on any of this."⁶² The Federal Reserve Bank's lawyer said it had "extended approximately $1.62 billion to Kabbage" and was the largest creditor. Cross River Bank's lawyer said "$750-plus million" had come into the company two years earlier and gone out to its shareholders, while "some pocket change was left behind."⁶² American Express objected to every statement about it in the first-day declaration, and the judge struck them from that day's record: "It doesn't mean it's false or that it's true."⁶²

The schedules and statement of financial affairs fill in the rest. They list the 2020 sale to American Express Kabbage Inc. at $750,000,000, and revenue of $250.1 million in 2020 and $222.7 million in 2021.⁴ Total assets were $686.2 million against scheduled liabilities of $536.7 million, almost all of it owed to the Federal Reserve Bank; the claims of the Justice Department, the FTC, SBA and the two partner banks were left "undetermined."⁵⁸ The post-sale management paid four executives retention bonuses totaling $527,250, dated September 30, 2022, three days before the petition; the court was asked to approve payments only to the non-executive employees.⁴⁷¹ The petition's list of the largest unsecured creditors names the Small Business Administration as "Small Business Bureau."⁹ No creditors' committee was formed; the U.S. Trustee recorded an "[i]nsufficient response."⁷² In the order that let it use cash, KServicing admitted it owed the Reserve Bank about $536,450,940 and waived any challenge to the debt.⁷³

The fee fight with Customers Bank

An early contest in the case was with a bank that owed the company money. On October 27, 2022 KServicing settled with Customers Bank for $58 million against a receivable of about $65.5 million. The bank would pay about $23 million in cash, and Kabbage would keep the roughly $34 million of the bank's collections and fees it already held.⁶¹⁷⁴ Cross River Bank objected that the deal let Customers Bank keep $8 million it owed and that the bank's withholding had "starved the Debtors of needed liquidity and helped precipitate this bankruptcy." Cross River, which had prepaid Kabbage for servicing, called itself "likely the largest unsecured creditor of the Debtors."⁷⁵ The company's CEO testified that without the settlement cash it would run out of money by the end of December.⁷⁶ Judge Goldblatt approved the deal on November 7. The ruling noted that the deal let Customers Bank keep about $8 million the company said it was owed, and that "what is reasonable for someone to do when they are over a barrel may be different from what is reasonable to do in other circumstances."⁷⁶⁷⁷

The payment then became its own dispute. Customers Bank wired $20,499,683; KServicing said it was owed $23,780,786.63.⁷⁸ The bank said the company could not produce a reconciled trial balance and that its figures "camouflage a deep rot in the internal financial accounting function."⁷⁹ KServicing said it had double-counted $925,242.87 of payments to SBA on the bank's loans and repaid the amount in December.⁸⁰ A January 2023 stipulation made Customers Bank solely responsible to SBA and borrowers for post-petition overpayments on its loans, with KServicing passing the bank's collections to it monthly.⁸¹ KServicing's claim for the $3.28 million balance was adjourned without a date and does not reappear in the filings we have.⁸¹

The plan, the vote and the ten-dollar loan sale

The liquidation plan's disclosure statement estimated that the Federal Reserve Bank would recover 90.5 to 99 percent of its $536 million claim. For general unsecured creditors the recovery was "TBD," depending on "any proceeds that may be recovered on account of any Causes of Action."⁸¹ The chief ones concerned the sale. The company told creditors that American Express had paid about $750 million, "of which it appears approximately $668 million was paid directly to former shareholders instead of the Company."⁸¹ The plan kept claims against American Express, former officers and directors and former shareholders out of its releases, and its schedule of retained claims reserved those against the sale's outside advisers.⁸²⁸³ FT Partners, Kabbage's banker on the sale, had collected a fee "in excess of $12 million" and produced 60 documents; the court ordered it to produce the rest by March 31, 2023.⁸⁴ Cross River and Customers Bank asked to examine American Express, saying parts of their loan files had been transferred to it in 2020 "without Cross River's knowledge or consent."⁸⁵

The company's liquidation analysis projected nothing for unsecured creditors under the plan or in a Chapter 7, before any lawsuit recoveries.⁸⁶ The unsecured creditors who voted rejected the plan, 24 to 18, holding 66.3 percent of the dollars voted. The Reserve Bank voted its $536,450,940 claim to accept,⁸⁷ and the plan was confirmed on March 15, 2023.¹² The U.S. Trustee had objected that a permanent injunction for a liquidating company amounted to a discharge the Bankruptcy Code forbids.⁵⁹ Judge Goldblatt agreed, and the injunction became temporary. The letter ruling explained that "bankruptcy law will treat as a duck that which quacks like a duck."⁸⁸

On April 11, 2023 the court approved the transfer of 14,959 PPP loans pledged to the Federal Reserve, ownership and servicing both, to Lendistry SBLC, LLC. The cash purchase price was ten dollars, plus the benefit to the estate of Lendistry taking over the servicing; the Reserve Bank kept its liens.⁸⁹ SBA's data now list 13,815 Kabbage loans under the servicer "Lendistry-Federal Reserve Contract," and 10,489 of them, 75.9 percent, were charged off.²⁷

The plan took effect on June 20, 2023.¹² Jeremiah Foster of Resolute Commercial Services runs the estate as Wind Down Officer, at $30,000 a month.¹⁰¹¹ The wind-down officer's report for the quarter ending March 31, 2026 shows $16.4 million disbursed since the effective date and nothing paid on $246,770,917 of allowed general unsecured claims.¹²

Borrowers as creditors

PPP borrowers filed claims too. In September 2024 the estate objected to them on the ground that forgiveness disputes belong to SBA, a lender being "merely a processer who compiles information from the PPP Borrower." It cited the Carr dismissal for the rule that borrowers have no private right of action.⁹⁰ On November 1, 2024 the court disallowed 168 borrower claims with stated amounts totaling $4,840,237.01, among them claims filed by three of the Carr plaintiffs.⁹¹⁹²

The Juneau Group, whose connection to the case was a $2,223 PPP loan, asked for a $499,999.99 administrative claim for "TIME" it said it had sold the debtors, plus $20,833 a month. Judge Goldblatt ruled that "'time' is not a 'good' that may give rise to an administrative claim."⁹³ A claimant named Wiggins, whose two 2020 Kabbage loans went to Wiggins & Graham Enterprises ($1,828,568) and Pink Lady Line ($1,819,577), filed a $260 million "personal claim."⁶⁸ The court disallowed it in February 2024.⁹⁴ Both companies were on the list of sixteen entities whose records the House Select Subcommittee had asked American Express to produce first.⁴⁰ In January 2026 the court disallowed indemnification claims by seven individuals, because the plan rejected the company's indemnification obligations.⁹⁵

The False Claims Act cases

Two whistleblowers

Two sealed False Claims Act complaints came first. David Berteletti, the Massachusetts CPA, filed in Boston in November 2020 (United States ex rel. Berteletti v. Kabbage, Inc.), alleging the tax double count.³⁶ Paul Pietschner, a legal analyst in Kabbage's Atlanta collections department who had been furloughed in March 2020 and recalled in June, filed in Sherman, Texas, in February 2021 against Kabbage, Petralia, Frohwein and Robinson (United States ex rel. Pietschner v. Kabbage, Inc.).¹ The Pietschner complaint describes a "fund now, verify later" approach, a payments-fraud reviewer with a backlog of 500 cases, and thousands of loans returned overnight as SBA duplicates in what staff called the "Wednesday Night Massacre."¹

Two settlements, May 2024

The Justice Department settled both cases with Kabbage's estate in agreements signed May 7, 2024 and announced May 13.³⁸³⁹⁹⁶ Neither pays cash. The Massachusetts agreement gives the United States an allowed unsecured claim of $63,294,270.43, and in it the estate admits the $100,000-cap, Form 940 and tax double-count errors.³⁸ The Texas agreement allows $56,705,729.57 for alleged fraud-control failures and contains no admission: the United States "contends" that Kabbage set substandard fraud thresholds, cut fraud staff and instructed staff to submit loans already flagged as fraudulent.³⁹ The two claims total $120,000,000, and $15.25 million of that is payable only after every other unsecured creditor has been paid in full.³⁸³⁹ The Massachusetts agreement credits the estate with the $12.5 million Kabbage had paid SBA for excess forgiveness in 2021 and commits the United States to pay Berteletti $2,343,750, the relator's 18.75 percent share of that credit.³⁸

DOJ's announcement added that the government alleged Kabbage knew of the errors "as early as April 2020"; that line is in the press release, not in either agreement.⁹⁶³⁸ In February 2025 the U.S. Attorney's office in Massachusetts, reporting its year's results, described "a $120 million settlement" with Kabbage as "the largest federal civil settlement involving the PPP program."⁹⁷ The $120 million is an allowed claim, paid only from what the estate recovers; as of December 2024 Kabbage had made no cash payment, the government's complaint says.³⁵ The estate has also allowed SBA a $92 million claim and settled Cross River Bank's claim for $30 million, and it estimates total allowed claims at no less than $270 million. Its complaint says the Justice Department had offered in August 2023 to settle for about $212 million.⁶

The case against Frohwein, Petralia and Robinson

On December 20, 2024 the United States filed its own complaint in the Texas case against Frohwein, Petralia and Robinson; Kabbage is not a defendant.³⁵⁹⁸ The 98-page complaint pleads False Claims Act presentment, false records and conspiracy, plus unjust enrichment and payment by mistake, and seeks treble damages and civil penalties of $13,946 to $27,894 per claim, with no total stated.³⁵ It quotes the early internal view of the program. An employee called the PPP a "money making machine! . . . Plus no risk of loss," and Robinson called it revenue "that we're going to take as much of as we can." Petralia urged approvals for the value of being "the fintech that deployed more $ faster." On July 9, 2020 Frohwein asked Petralia whether donating "$10 million of our PPP fees to some cause" might help "if we're ever under the microscope on the PPP program."³⁵ The complaint says each defendant invoked the Fifth Amendment on every question about Kabbage and the PPP in sworn examinations in 2024: Robinson on April 25, Petralia on May 16 and Frohwein on June 3.³⁵ Its claims are allegations; no court has found liability.

The defendants moved to dismiss in March 2025. They argued that SBA required only a minimal good-faith review and kept paying claims while knowing of widespread fraud, that invoking the Fifth Amendment cannot supply the detail fraud pleading requires, and that the case belongs in another district. Robinson's motion describes the tax error as an innocent mistake by two employees.⁹⁹¹⁰⁰ The United States answered that it was "not at this time asking this Court to rule that any of the Defendants' Fifth Amendment invocations warrant an adverse inference."¹⁰¹ While the motions were pending, a May 2025 scheduling order set trial for April 2027 in Plano.¹⁰² Petralia and Robinson had exchanged settlement offers with the government; no offer had passed between the government and Frohwein.¹⁰³ In January 2026 the defendants said they would point to the involvement of Kabbage's in-house lawyers, naming Askins and two others.¹⁰⁴ On March 19, 2026 Judge Sean D. Jordan stayed the whole case until the court rules on the motions to dismiss, which, the order says, "provide substantial arguments for dismissal of many, if not all, of Plaintiff's claims."¹⁰⁵

The estate's lawsuits (October 2025)

Against the founders, directors and investors

On October 16, 2025 KServicing Wind Down Corp. sued 25 defendants in the Delaware bankruptcy court (KServicing Wind Down Corp. v. Frohwein, Adv. No. 25-52372). They are five former officers (Frohwein, Petralia, general counsel L. Scott Askins, Robinson and Sam Taussig, the head of global policy), six former directors, and the funds that received most of the sale money, among them SoftBank Vision Fund, Reverence Capital Partners, BlueRun, MDV and Thomvest.⁶ The 109-page complaint alleges that Kabbage "knowingly or recklessly" approved "tens of thousands of fraudulent or otherwise ineligible" loan applications to earn "tens of millions of dollars" in fees; its first-round PPP fees exceeded $217 million. The sale, in the estate's telling, sent the value to American Express and the shareholders and left the liabilities with a company that could not pay them. The counts are breach of fiduciary duty against the officers and directors, recovery of the October 13, 2020 transfer as a fraudulent transfer, and disallowance or subordination of the defendants' own claims; damages are put at "hundreds of millions of dollars."⁶ Like the government, the estate says co-founders Frohwein and Petralia and strategy head Robinson pleaded the Fifth when the Justice Department questioned them: "A reasonable inference to draw from their refusal to answer questions is that they knew."⁶ Frohwein, Petralia, Askins, Robinson and four of the directors had filed indemnification claims against the same estate; the complaint asks the court to disallow them.⁶

The defendants moved to dismiss, and on April 9, 2026 filed a joint appendix of internal records in support: board materials, text messages, the #ppp-fraud Slack thread and the Duff & Phelps solvency analysis quoted above.¹⁴⁴³

Against American Express

The same day the estate sued American Express Kabbage Inc. and American Express Travel Related Services Company. The 97-page complaint seeks to recover "over $746 million" as actual and constructive fraudulent transfers, to avoid American Express's release and indemnification rights under the merger agreement, and to disallow its claims against the estate.⁵⁴ It alleges American Express knew Kabbage was leaving cash only for servicing, not for litigation, and did not take the transfer in good faith.⁵⁴ The complaint does not show how the $746 million is calculated; the figures it gives are the $120 million of PPP cash and the more than $730 million paid to shareholders.⁵⁴ American Express disclosed the suit in its 2025 annual report as seeking "up to approximately $746 million." The report adds that the former directors, officers and shareholders sued in the companion case "have taken the position that we must indemnify them for any resulting liability (which we dispute)."¹⁰⁶ Its quarterly report for the period ended June 30, 2026 repeats the same description.¹⁰⁷

What became of the loans

SBA's loan data, current through September 30, 2024, record a status for each loan; for 13,209 Kabbage loans the status field reads only "Exemption 4." Of the 179,818 loans Kabbage originated, 33,825 were charged off: 18.8 percent, against 5.6 percent for the program as a whole. By dollars the gap is wider, $722.6 million or 21.7 percent against 2.3 percent.²⁷ Among the 20 lenders with the most PPP loans, three had a higher share of loans charged off: Harvest Small Business Finance (24.3 percent), Benworth Capital (22.6 percent) and BSD Capital, which does business as Lendistry (21.2 percent). By dollars, only Benworth's share was higher.²⁷ Forgiveness covered 62.2 percent of Kabbage's loan dollars, the lowest share among those 20 lenders; across the program it was 96.3 percent.²⁷

The same file shows who holds the loans now. Cross River Bank services 75,837 of them and Customers Bank 8,114; 13,815 sit with "Lendistry-Federal Reserve Contract," and 81,999 with a servicer the file lists as "Fed ¿ Kabbage," stray character included.²⁷

What American Express did with the platform

American Express announced in August 2020 that it would acquire "Kabbage's team and its full suite of financial technology products";⁵⁵ its Form 10-K for 2020 reports its own PPP lending separately, at "$0.6 billion of gross PPP loans outstanding as of December 31, 2020."¹⁰⁸ The Kabbage Funding line of credit continued as the American Express Business Line of Credit, and in 2023 American Express retired the Kabbage brand with the launch of Business Blueprint, Finovate reported.¹⁰⁹¹¹⁰ Frohwein stayed at American Express Kabbage as a senior vice president until December 2021. Robinson later served as American Express's chief credit officer for commercial non-card lending, from 2021 to 2023, according to the estate's complaint.⁴⁰⁶

Where Kabbage doesn't appear

SBA's December 8, 2022 statement on the House report suspended Blueacorn and Womply; it does not name Kabbage.¹¹¹
The company disclosed a February 2021 civil investigative demand from the FTC about its PPP advertising, underwriting and servicing.³ We found no FTC order or complaint against Kabbage.
The Justice Department's case against Frohwein, Petralia and Robinson is a civil False Claims Act case. We found no criminal indictment of any Kabbage executive.

Current posture (as of September 2026)

KServicing Wind Down Corp. is in liquidation under the plan confirmed on March 15, 2023, and had paid nothing to general unsecured creditors through March 2026.¹²
The Justice Department's allowed claims can be paid only from what the estate recovers.³⁸³⁹
The Texas case against Frohwein, Petralia and Robinson is stayed until the court rules on the motions to dismiss.¹⁰⁵
In the estate's suit against the insiders and investors, the defendants moved to dismiss in April 2026; the suit against American Express is pending.¹⁴¹⁰⁷
Frohwein and Petralia founded Keep Financial Technologies after the American Express deal;¹¹² Petralia's biography says Keep was sold to Apprenta.¹¹³

Notes

Robert Frohwein — co-founder and CEO; defendant in the U.S. and estate cases
Kathryn Petralia — co-founder and president; defendant in the U.S. and estate cases
L. Scott Askins — general counsel; estate defendant
Marc Gorlin — co-founder
Cross River Bank — first-round partner bank; objector in the bankruptcy
Customers Bank — partner bank in both rounds; $65.5 million fee dispute
Celtic Bank — issuer of Kabbage Funding loans
Lendistry — took over 14,959 Federal Reserve–pledged Kabbage loans in 2023
SmartBiz — where K Servicing sent second-draw applicants in 2021, CNBC reported
Biz2Credit — built K Servicing's 2021 forgiveness portal, K Servicing says
Craig T. Goldblatt — bankruptcy judge
Sean D. Jordan — district judge in the Texas False Claims Act case
James Clyburn — chairman of the House Select Subcommittee on the Coronavirus Crisis
Brian M. LaMacchia, Diane Seol, Sarah E. Loucks and Alastair Gesmundo — Justice Department lawyers on the Kabbage matters
Derek Willis and Lydia DePillis — ProPublica reporters on the fake-farm loans
Jenny Surane and Zeke Faux — Bloomberg reporters on Kabbage's 2020 credit-line cuts
Caitlin Mullen — Banking Dive, on the 2024 settlements
Blueacorn, Lendio, OnDeck and BlueVine — other fintechs in the PPP record

Sources

Primary documents in this archive

Company, investor and press records:

Congressional record:

In re KServicing Wind Down Corp., No. 22-10951 (Bankr. D. Del.):

Estate lawsuits (Bankr. D. Del.):

Complaint, KServicing Wind Down Corp. v. Frohwein, Adv. No. 25-52372 (Bankr. D. Del.), Doc 1 (October 16, 2025), ¶¶ 1, 7–10, 17, 34–53, 123, 160–162, 208–229, 237–249, 257–261, 270–288, 311, 339–358.
Complaint, KServicing Wind Down Corp. v. American Express Kabbage Inc. and American Express Travel Related Services Company, Inc. (Bankr. D. Del., October 16, 2025; filed in the main case as Doc 1177), ¶¶ 1, 3, 14, 28, 69–72, 103–117, 175, 201, 219–221, 237–309.
Joint declaration and joint appendix of all defendants, Exhibits 1–10, KServicing Wind Down Corp. v. Frohwein, Adv. No. 25-52372, Doc 97-1 (April 9, 2026), ¶¶ 1–5 and Ex. 6 (board update, March 25, 2020).
Joint appendix, Exhibits 11–20, Adv. No. 25-52372, Doc 97-2 (April 9, 2026), Ex. 16 (message of April 8, 2020).
Joint appendix, Exhibits 31–40, Adv. No. 25-52372, Doc 97-4 (April 9, 2026): Ex. 31 (#ppp-fraud Slack channel, July 16, 2020), Exs. 32–33 (text messages, July 17 and July 23, 2020), Ex. 36 (email, August 4, 2020), Ex. 38 (emails, August 10–11, 2020), Ex. 39 (Duff & Phelps solvency analysis, August 11, 2020).

False Claims Act cases:

Borrower litigation:

Class action complaint, Carr v. Kabbage, Inc. d/b/a K Servicing, No. 1:22-cv-01249 (N.D. Ga.), Doc 1 (March 30, 2022), ¶¶ 15, 106, 120, 122, 134, 189.
Press articles filed as an exhibit to the Carr complaint (Miami Herald, March 8, 2022; CNBC, April 7, 2021), Doc 1-1, pp. 18–29.
Memorandum in support of Kabbage's motion to dismiss, Carr, Doc 12-1 (May 31, 2022).
Order granting the motion to dismiss, Carr, Doc 22 (March 31, 2023), pp. 11, 13, 19.

Prosecutions:

External references:

OnDeck letter to Congress Mar. 24, 2020, the coalition letter published under OnDeck's banner — original: OnDeck letter to Congress Mar. 24, 2020 (original: ondeck.com) our copy of the letter
SBA PPP loan-level data: SBA PPP FOIA loan-level data, release through September 30, 2024.