Rankings & leaderboards
What the 2021 Fee Schedule Was Worth, by Vintage
The Paycheck Protection Program changed how it paid lenders between its 2020 and 2021 rounds. This is the fee pool each vintage of loans generated under the schedule that governed it, modeled from SBA's published schedules, and what the same loans would come to under the other one.
How this list is built
This is an exhibit, not a leaderboard: three rows. SBA's processing fee was a percentage of the loan, banded by loan size, and the bands and percentages were rewritten for the 2021 round in a way that paid much more on the smallest loans. The fee build applies both schedules to every loan in the SBA FOIA release and totals them by the loan's vintage and draw type. The first fee column applies the schedule that governed each loan; the two beside it price the same loans under each schedule in turn. All three are modeled from SBA's published fee schedules, not read from payment records.
Unit ranked: the loan vintage and draw regime. Metric: the modeled fee pool in billions of dollars. Universe: 11,468,206 loans, $792.60B approved. Vintage: SBA PPP FOIA release of 30 September 2024; fee build June 2026.
The three vintages
| Vintage and draw | Loans | Approved | Estimated fees under applicable rules | Under the 2020 schedule | Under the 2021 schedule |
|---|---|---|---|---|---|
| 2020 — PPP first round | 5,136,260 | $521.78B | $18.17B | $18.17B | $23.32B |
| 2021 — first-draw loans under the second round | 3,476,201 | $63.20B | $8.34B | $2.91B | $8.34B |
| 2021 — second-draw loans | 2,855,745 | $207.62B | $11.72B | $8.42B | $11.50B |
| All three | 11,468,206 | $792.60B | $38.24B | $29.50B | $43.16B |
SBA's loan file marks 17 loans ($2.4 million) as second-draw loans but dates their approval between April and July 2020. Second-draw loans were first authorized by the Economic Aid Act of December 27, 2020, so the two fields on those records cannot both be right. The archive counts them by approval date, with the 2020 first round, and prices them under the 2020 fee schedule.
What this measures, and what it does not
Each column applies one fee schedule to the same loans. It does not estimate how borrowers or lenders would have behaved under different rules.
The 2021 second-draw row is the one place the applicable column and the 2021 column part, by $226.44M, and the reason is that second draws had their own schedule. The Second Draw interim final rule (86 FR 3712, at 3722) sets three tiers and no 1 percent band, so a second-draw loan of exactly $2,000,000 earns 3 percent; the comparator column prices every loan on the four-tier first-draw schedule of 86 FR 3692, whose top band is 1 percent. The whole difference sits on the 5,661 second-draw loans approved at exactly $2,000,000.
The fees themselves are modeled: SBA has never published per-lender or per-loan fee payments. The model prices every loan in the release bar four; it does not filter out charged-off loans, and clawbacks and netting are outside it.
Sources
- Archive data page: PPP fee schedules by vintage
- Archive data page: SBA PPP FOIA release, 30 September 2024
- Build as held: the fee-schedule-by-vintage table linked above (sha256 d580579d0bef0d5c…)