KeyBank

• Type: Bank; PPP lender of record and Main Street Lending Program lender
• Legal entities: KeyBank National Association; holding company KeyCorp
• Headquarters: Cleveland, Ohio

KeyBank is the national bank of KeyCorp, headquartered in Cleveland. SBA's loan-level file credits it with 69,405 PPP loans and $11.1 billion in approved dollars, ninth among all lenders by dollars.¹ In January 2026 it agreed to pay $7,770,595.25 to resolve False Claims Act and CARES Act claims over loans that a branch manager in Conshohocken, Pennsylvania had steered to companies with little or no real business. KeyBank did not admit liability.²³

The PPP book

The loans averaged $160,231 and went to 63,940 borrowers, who reported 1,114,910 jobs. Modeled loan by loan from SBA's published fee schedule, KeyBank's processing fees come to $379.3 million: $244.0 million on 2020 first-draw loans, $18.7 million on 2021 first-draw loans and $116.6 million on 2021 second-draw loans, 19th of 4,688 originating lenders.¹ SBA never published what it paid each lender.

KeyCorp's own count is in its 10-K for 2020: "We provided over 43,000 loans with over $8 billion in funding and were the seventh overall lender in the PPP in 2020." PPP loans accounted for $6.7 billion of commercial loans at year-end, and deposits rose $23.4 billion in the year, which the company attributed to "the impact of PPP and government stimulus programs" as well as its own client strategy. Net interest income rose "primarily" on balance-sheet growth "and fees related to PPP loans."⁴ In 2021, $8.0 billion of Key's PPP loans were forgiven, $1.5 billion were still outstanding at year-end, and forgiveness drove "higher loan fees."⁵ The same filing's risk factors note that "there have been lawsuits by borrowers and purported agents against lenders."⁴

On April 23, 2020, Senate Small Business Committee Chairman Marco Rubio wrote to KeyBank and eleven other large banks asking whether they took PPP applications first-come, first-served or filtered them in favor of certain borrowers.⁶ KeyCorp and KeyBank were among the defendants in ImpAcct, LLC's agent-fee class action in the District of Colorado, No. 1:20-cv-01344, which also named JPMorgan Chase, Bank of America, Wells Fargo and Zions.⁷ Both opposed centralizing the agent cases, and the Judicial Panel on Multidistrict Litigation declined to centralize them on August 5, 2020.⁸

The Conshohocken branch

KeyBank originated PPP loans through an online portal used by employees in its retail branches. Its branch managers were eligible for incentive pay tied partly to growth in business accounts at their branches, according to the settlement agreement.²

Tommy Hawkins managed the Conshohocken branch until KeyBank fired him in May 2021. From January to May 2021, during the second-draw round, he worked with people outside the bank, including Eric Rivera and Lisa Smith, to recruit owners of companies with little or no operation, open accounts for them at his branch and submit PPP applications with inflated payroll, employee counts and false tax forms. The agreement counts 48 such loans and $5,905,803 in PPP funds. Hawkins collected incentive compensation from Key for the new business accounts, and Rivera and Smith agreed to pay him $5,000 of the proceeds of each loan he helped obtain, according to the Justice Department.²⁹ He pleaded guilty to bank-fraud conspiracy in May 2024 and was sentenced in October 2024 to 65 months in prison.⁹¹⁰

The settlement is about what the bank did next. In spring 2021 Key's monitoring flagged Hawkins's account openings; it fired him and in June 2021 reported 18 of the loans to SBA's inspector general. Between June 2021 and December 2023 its investigations identified about a dozen more. It did not detect the remaining 17. It nonetheless submitted forgiveness applications or guaranty-purchase requests for all 48, and because each loan was under $150,000, SBA forgave them on an expedited basis.³² For the 48 loans, Key had received $299,646.20 in SBA fees.²

The government's contention, in the words of the U.S. Attorney's Office in New Jersey, was that Key submitted "forgiveness claims it had compelling evidence were fraudulent." The office credited the bank's cooperation.³ The $7,770,595.25 settlement is about 1.3 times the PPP money disbursed on the 48 loans and about 26 times the fees Key earned on them. The agreement states that it is "neither an admission of liability" by Key "nor a concession by the United States that its claims are not well founded."²

Main Street and unemployment cards

KeyBank sold 12 loans into the Federal Reserve's Main Street Lending Program; the program's participations in them totaled $207.1 million, 15th of the 320 lender entries in the Fed's disclosure.¹¹ In an Eastern District of New York prosecution, the government said a ring filed fraudulent New York unemployment claims with stolen identities and took the benefits into bank accounts it controlled or onto reloadable KeyBank debit cards mailed to addresses it controlled, then withdrew the money in cash.¹²

Related profiles

• Eric Rivera — recruited applicants to the Conshohocken branch, according to the Justice Department; pleaded guilty in April 2026.
• Lisa Smith — pleaded guilty to bank-fraud conspiracy in the same scheme in July 2024.

Sources

1. KeyBank PPP lender page, computed from SBA PPP FOIA loan-level data. Original: https://data.sba.gov/dataset/ppp-foia SBA PPP FOIA loan-level data (stored capture) ↩
2. Settlement agreement, United States and KeyBank National Association (executed Dec. 1, 2025). Original: https://www.justice.gov/usao-nj/media/1422621/dl Settlement agreement, United States and KeyBank National Association (executed Dec. 1, 2025; announced Jan. 7, 2026) (stored capture) ↩
3. U.S. Attorney's Office, District of New Jersey, "Key Bank Agrees to Pay $7.7 Million to Resolve Branch Manager's Fraud" (Jan. 7, 2026). Original: DOJ Usao Nj Press Release Key Bank Agrees Pay 77 Million Resolve Branch Managers Fraud 2026 01 07 (original: justice.gov · stored capture) ↩
4. KeyCorp, Form 10-K for 2020 (filed Feb. 22, 2021). Original: https://www.sec.gov/Archives/edgar/data/91576/000009157621000044/key-20201231.htm ↩
5. KeyCorp, Form 10-K for 2021 (filed Feb. 22, 2022). Original: https://www.sec.gov/Archives/edgar/data/91576/000009157622000029/key-20211231.htm ↩
6. Senate Small Business Committee, "Rubio Sends Letters to Large Banks Participating in the Paycheck Protection Program" (Apr. 23, 2020). Original: https://www.sbc.senate.gov/public/index.cfm/pressreleases?ID=D1C1F214-DEA1-4F78-8D13-C95B7904BD7A ↩
7. Schedule of Actions, In re Paycheck Protection Program (PPP) Agent Fees Litigation, MDL No. 2950, Dkt. 1-2 (J.P.M.L., filed May 22, 2020). ↩
8. Order Denying Transfer, MDL No. 2950, as filed at Dkt. 86-1 (N.D. Fla.). ↩
9. U.S. Attorney's Office, District of New Jersey, "Bank Manager Admits Coordinating Multistate COVID-19 Relief Program Fraud Scheme" (May 30, 2024). Original: https://www.justice.gov/usao-nj/pr/bank-manager-admits-coordinating-multistate-covid-19-relief-program-fraud-scheme-new Bank Manager Admits Coordinating COVID-19 Relief Fraud (stored capture) ↩
10. U.S. Attorney's Office, District of New Jersey, "Bank Manager Sentenced to 65 Months in Prison for Coordinating Multistate COVID-19 Relief Program Fraud Scheme" (Oct. 21, 2024). Original: https://www.justice.gov/usao-nj/pr/bank-manager-sentenced-65-months-prison-coordinating-multistate-covid-19-relief-program Bank Manager Sentenced to 65 Months in COVID-19 Relief Fraud (stored capture) ↩
11. Main Street Lending Program: 25 banks by participations sold. ↩
12. Government sentencing memorandum, United States v. Stewart (Abraham et al.), No. 1:21-cr-00411 (E.D.N.Y. Feb. 28, 2024). Original: https://storage.courtlistener.com/recap/gov.uscourts.nyed.467854/gov.uscourts.nyed.467854.232.0.pdf ↩