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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.

Loan file 30 September 2024 FOIA releaseFee build June 2026Universe 11,468,206 loans ($792.60B approved)Source PPP fee schedules by vintage

Modeled fees under the rules that governed each vintage
$38.24B
Same 11,468,206 loans priced under the 2020 schedule
$29.50B
Same 11,468,206 loans priced under the 2021 schedule
$43.16B
2021 first-draw fees: $8.34B applicable vs. $2.91B (2020 rules)
$5.43B

What the 2021 fee schedule added to the pool

Pricing all three PPP loan cohorts under the applicable rules ($38.24B), the 2020 schedule ($29.50B) and the 2021 first-draw schedule ($43.16B).

How the 2020 and 2021 fee schedules price the 11,468,206 PPP loans

Modeled processing-fee pools by vintage under the schedule that governed each loan ($38.24B total) versus pricing all loans under the 2020 schedule ($29.50B) or the 2021 first-draw schedule ($43.16B).

  1. 12020 — PPP first round5,136,260 loans · $521.78B approved · $18.17B under 2020 vs. $23.32B under 2021 rules$18.17B (applicable)
  2. 22021 — first-draw loans under the second round3,476,201 loans · $63.20B approved · $8.34B under 2021 vs. $2.91B under 2020 rules$8.34B (applicable)
  3. Where the 2021 fee rewrite moved the pool (+$5.43B on 2021 first draws): The 3,476,201 first-draw loans of 2021 ($63.20B approved) generated $8.34B in modeled fees under the 2021 schedule, compared with $2.91B had the 2020 bands remained in force.
  4. 32021 — second-draw loans2,855,745 loans · $207.62B approved · $11.72B applicable ($8.42B under 2020; $11.50B under 2021 first-draw)$11.72B (applicable)
  5. Why applicable ($11.72B) and 2021 ($11.50B) differ by $226.44M on second draws: 5,661 second-draw loans at the $2,000,000 ceiling earned 3 percent under the three-tier Second Draw rule (86 FR 3712) versus 1 percent on the four-tier first-draw comparator schedule (86 FR 3692).
  6. Whole-program totals across all 11,468,206 loans ($792.60B approved): comparing the three fee regimes across the entire FOIA release.
  7. ΣAll three vintages — under 2020 schedule (counterfactual)11,468,206 loans · $792.60B approved priced on the 2020 fee bands$29.50B
  8. ΣAll three vintages — under applicable rules11,468,206 loans · $792.60B approved priced on the rule that governed each vintage$38.24B
  9. ΣAll three vintages — under 2021 first-draw schedule (counterfactual)11,468,206 loans · $792.60B approved priced on the four-tier 2021 first-draw schedule$43.16B

Source: PPP fee schedules by vintage, modeled from the SBA PPP FOIA release of 30 September 2024 (fee build June 2026).

  1. 1

    2020 — PPP first round

    $18.17BApplicable rules · 5,136,260 loans ($521.78B)
    2020 schedule
    $18.17B
    2021 schedule
    $23.32B

    Includes 17 loans ($2.4 million) dated April–July 2020 that SBA’s file marks as second-draw.

    Source: PPP fee schedules by vintage

  2. 2

    2021 — first-draw loans under the second round

    $8.34BApplicable rules · 3,476,201 loans ($63.20B)
    2020 schedule
    $2.91B
    2021 schedule
    $8.34B (+$5.43B)

    Higher percentages on the smallest loans nearly tripled the modeled fee pool on 2021 first-draw loans.

    Source: PPP fee schedules by vintage

  3. 3

    2021 — second-draw loans

    $11.72BApplicable rules · 2,855,745 loans ($207.62B)
    2020 schedule
    $8.42B
    2021 schedule
    $11.50B (-$226.44M)

    Governed by the three-tier Second Draw rule (86 FR 3712), where the 5,661 loans at $2,000,000 earned 3%.

    Source: PPP fee schedules by vintage

The three vintages

Three loan cohorts plus the combined program row across 11,468,206 loans ($792.60B approved).

Showing 3 vintages + total row · 11,468,206 loans ($792.60B approved)

FOIA release 30 September 2024 · fee build June 2026

What the 2021 Fee Schedule Was Worth, by Vintage
Vintage and drawLoansApprovedEstimated fees under applicable rulesUnder the 2020 scheduleUnder the 2021 scheduleSource
2020 — PPP first round5,136,260$521.78B$18.17B$18.17B$23.32BFee build (Jun 2026)
2021 — first-draw loans under the second round3,476,201$63.20B$8.34B$2.91B$8.34BFee build (Jun 2026)
2021 — second-draw loans2,855,745$207.62B$11.72B$8.42B$11.50BFee build (Jun 2026)
All three11,468,206$792.60B$38.24B$29.50B$43.16BFee build (Jun 2026)

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.

How this list is built

Method & definitions

Unit ranked
the loan vintage and draw regime.
Metric
the modeled fee pool in billions of dollars.
Universe
11,468,206 loans (the 11,468,210 rows of the 30 September 2024 release minus 4 rows the disbursement filter removes), $792.60B approved.
Vintage
SBA PPP FOIA release of 30 September 2024; fee build June 2026.

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.

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

  1. Archive data page: PPP fee schedules by vintage
  2. Archive data page: SBA PPP FOIA release, 30 September 2024
  3. Our copy: the fee-schedule-by-vintage table linked above (sha256 d580579d0bef0d5c…)
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