Who Made the Most Delivering Pandemic Relief

1. Documented fee-only figures beat the loan-by-loan model. Most PPP lenders amortized SBA processing fees into net interest income over the life of the loans and never published a standalone fee total. For those lenders, fees are modeled loan by loan from the SBA's September 30, 2024 FOIA file under the statutory schedule in force at approval: 5 percent up to $350,000, 3 percent from $350,000 to under $2,000,000, and 1 percent at $2,000,000 or more for 2020 loans (85 FR 20811), and the lesser of 50 percent or $2,500 on loans of $50,000 or less in 2021 (86 FR 3692; 86 FR 3712). Where a collector's own filings, audited statements, or congressional responses report a fee-only retained total (Wells Fargo at $690.0M vs. $690.1M modeled; Customers Bank at $350.0M net of direct origination costs vs. $558.2M gross modeled; Harvest at $319.3M retained out of $1,074.9M received; Capital Plus at $305.7M audited), the documented figure governs. Where a bank's disclosures bundle fees with the 1 percent loan coupon (Truist's $692M, TD Bank's US$525M, U.S. Bancorp's $412M), the fee-only model governs.

2. Single-counting across lenders, agents, and subcontractors. Under the SBA's rules, PPP agents were paid out of the lender's processing fee, and SBA prime contractors paid their subcontractors out of prime contract billings. Subtracting documented pass-throughs prevents counting the same dollar twice: Prestamos CDFI's $1,055.1M in modeled fees is reduced by the $700.0M reported paid to Blueacorn (leaving $355.1M at Rank 15), and RER Solutions' $740.5M audited COVID-19 EIDL order is reduced by $383.2M paid to subcontractors Rocket Loans and Rapid Finance (leaving at least $357.3M at Rank 14, with $139.5M in later payments across two orders unallocated and $437.3M as the upper bound if RER retained all of the second $80.0M order). For Guidehouse ($352.4M: $231.6M PPP/OCA support and $120.8M EIDL call centers), the Goldschmitt-CRI joint venture ($339.4M across three PPP forgiveness and EIDL closing contracts, excluding its $66.7M Restaurant Revitalization Fund portal award), and Highlight Technologies ($337.9M across four pandemic loan-review call orders, $32,344 behind M&T Bank), USAspending records do not disclose subcontractor payment splits, so prime obligations are shown.

3. Why ERC promoter revenue and lender interest income are left blank. Employee Retention Credit contingency-fee promoters charged 15 to 25 percent of refunds claimed, and PPP lenders earned a 1 percent annual interest coupon (or a 65-basis-point spread when funded at 0.35 percent through the Federal Reserve's Paycheck Protection Program Liquidity Facility). Because no federal dataset or comprehensive filing discloses ERC promoter revenue or separates PPP interest spread across lenders, both columns are left blank (n/a) rather than estimated.

4. Why aid recipients and goods procurement are excluded. This ranking covers only intermediaries paid to administer, originate, or process relief applications. Beneficiaries that received grants or forgivable loans for their own payrolls (such as hospital systems under the Provider Relief Fund or passenger airlines under the Payroll Support Program) and manufacturers that sold vaccines, tests, or personal protective equipment to the federal government are excluded.