Fall 2022 SBA OIG Semiannual Report to Congress

Full text

Semiannual Report to Congress
April 1, 2022 – September 30, 2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | i
Message from the Inspector General
November 30, 2022
I am honored to submit our Semiannual Report to Congress for the second
half of fiscal year 2022. Every 6 months, we report to Congress our
independent oversight of the U.S. Small Business Administration (SBA) as
required by law.
Over 2 years after the start of the Coronavirus Disease 2019 (COVID-19)
pandemic economic crisis, the SBA Office of Inspector General (OIG)
continues to provide independent and objective oversight. We oversee the
integrity, accountability, and performance of SBA and its programs for the
benefit of the American people. OIG works to improve SBA programs by
identifying key issues facing the agency, recommending corrective actions,
and promoting a high level of integrity.
This fiscal year we are reporting an unprecedented statistic: $4.8 billion in
joint monetary recoveries and savings. Without a doubt, this achievement
would not have been possible without our partner organizations.
Pandemic Response Oversight
Since March 2020, our goal has been to set a standard of excellence in overseeing SBA pandemic
response for America’s small businesses. Independence and objectivity are critical in the oversight of
taxpayer funds allocated by the Coronavirus Aid, Relief, and Economic Security (CARES) Act and
subsequent Congressional economic stimulus funds and mandates.
SBA has expended more than a trillion dollars in lending authority and entrepreneurial assistance in the
wake of the pandemic. When SBA expedited relief to those in need, the agency relaxed internal
controls, increasing the risk of program fraud, abuse, and improper payments.
As the landscape continues to unfold, we are collaborating across government to bring fraudsters to
justice. OIG pandemic oversight and investigative work has resulted in in 607 indictments and 362
convictions, as of October 2022. Leveraging finite supplemental resources provided by Congress, we
have published 29 reports on pandemic oversight. We have issued dozens of recommendations for
corrective action aimed at strengthening internal controls so eligible small businesses receive the
economic aid promised by Congress, not fraudsters or other unscrupulous borrowers abusing taxpayer
resources.
The true magnitude of fraud in SBA pandemic assistance programs will be coming to light for many
more years as these programs move into new stages. We will continue to evaluate and recommend
corrections for the most critical risks facing SBA, but oversight of pandemic relief funds and combating
fraud in these programs will be a top priority for years to come and will require adequate oversight
resources.
Hannibal “Mike” Ware
Inspector General

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Our Work this Period
During the 6-month period from April to September 2022, OIG issued 16 reports with 59
recommendations to improve SBA operations and reduce fraud and unnecessary losses in agency
programs. We questioned $54 million in audits, other reports, and follow-up activities. In addition, OIG
investigations resulted in 141
indictments and 100 convictions.
Overall, OIG’s investigations and audit
work achieved monetary recoveries and
savings of more than $146 million during
this semiannual period.
We are also keeping watch over
government contractors for business
ethics, integrity, honesty, and
competency, ensuring taxpayer dollars
are spent efficiently according to intent.
OIG Staff Dedication and Success
I am proud that our OIG staff members are engaged change agents who set the standard for oversight
excellence in support of American small businesses and entrepreneurs. We carry out our duties and
responsibilities with integrity, never losing sight of this vision, committed to protecting the interests of
all American taxpayers by promoting positive change within SBA and across government.

Hannibal “Mike” Ware
SBA Inspector General

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Table of Contents
Pandemic Response Oversight ................................................................................................................................. 1
Audits, Inspections, and Evaluations ...................................................................................................................... 1
Evaluation of SBA’s Disaster Assistance Loan Recommendation Services (Report 22-10) ............................. 1
SBA's Handling of Potentially Fraudulent Paycheck Protection Program Loans (Report 22-13) ................... 2
SBA’s Award and Payment Practices in the Shuttered Venue Operators Grant Program (Report 22-15) ..... 2
SBA’s COVID-19 EIDL Program Data Migration Challenges (Report 22-16) .................................................. 3
SBA’s COVID-19 EIDL Applications Submitted from Foreign IP Addresses (Report 22-17) .......................... 3
COVID-19 and Disaster Assistance Information Systems Security Controls (Report 22-19) .......................... 4
Paycheck Protection Program Eligibility for Nonprofit Organizations (Report 22-21) .................................... 4
Follow-Up Inspection of SBA’s Internal Controls to Prevent COVID-19 EIDLs to Ineligible Applicants (Report 22-
22) ......................................................................................................................................................................... 5
SBA's Guaranty Purchases for Paycheck Protection Program Loans (Report 22-25) ............................................... 6
Notable Investigations .............................................................................................................................................. 6
California Man Sentenced to Over 11 Years for $27 Million PPP Fraud Scheme ............................................ 6
DC man Sentenced to 10 Years for Attempting to Steal More than $31 Million in COVID-19 Funds ............ 6
Texas Man Sentenced to More Than 9 Years in COVID-19 Fraud and Money Laundering Scheme .............. 7
Small Business Access to Capital............................................................................................................................. 8
Inspection .................................................................................................................................................................. 8
SBA’s Actions to Improve the Management of the 7(a) Loan Guaranty Approval Process (Report 22-18) ..... 8
Disaster Assistance Program ................................................................................................................................... 9
Investigations ............................................................................................................................................................ 9
Colorado Man Sentenced to 66 Months for EIDL and PPP fraud ..................................................................... 9
Salt Lake City Man Charged in $1.8 Million CARES Act Loan Fraud Scheme ............................................... 9
Contracting and Counseling Programs .................................................................................................................. 10
Audits, Inspections, and Evaluations .................................................................................................................... 10
SBA’s Implementation of the Women-Owned Small Business Certification Program (Report 22-20) .......... 10
SBA’s Protest Process (Report 22-24) ............................................................................................................... 11
Investigations .......................................................................................................................................................... 11
Odyssey International Inc. and Former Officer of Company Convicted of Obtaining $99 Million U.S.
Government Contract ........................................................................................................................................ 11
Construction Company Owner Convicted of Fraud in Securing Over $240 Million in Contracts Intended for
Service-Disabled Veterans ................................................................................................................................. 12
Agency Management............................................................................................................................................... 13
Audits, Inspections, and Evaluations .................................................................................................................... 13
Fiscal Year 2021 Federal Information Security Modernization Act Review (Report 22-11) .......................... 13

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Independent Auditors’ Report on SBA’s Fiscal Year 2021 Compliance with the Payment Integrity
Information Act of 2019 (Report 22-12) ............................................................................................................ 13
SBA's Controls Over Cash Contributions and Gifts, Fiscal Years 2022 and 2021 (Report 22-14) ........................... 14
SBA’s Corrective Actions to Improve Monitoring District Offices’ Customer Service Activities (Report 22-23) ....... 14
Other Significant OIG Activities ............................................................................................................................ 15
Background Investigations Ensure Integrity ........................................................................................................ 15
Debarment and Other Administrative Enforcement Actions ............................................................................... 15
Stakeholder Presentations on PPP and EIDL Fraud ............................................................................................ 15
Reviews of Proposed Agency Regulations, Operating Procedures, and Other Initiatives Lead to Improved
Program Controls ................................................................................................................................................... 15
Approval of Small Business Development Center Surveys................................................................................... 15
Unprecedented Numbers ........................................................................................................................................ 16
Organizational Overview ........................................................................................................................................ 17
U.S. Small Business Administration ..................................................................................................................... 17
Office of Inspector General ..................................................................................................................................... 18
Appendixes .............................................................................................................................................................. 20
Appendix A. Reporting Period Statistical Highlights ........................................................................................... 20
Summary of OIG Dollar Accomplishments ....................................................................................................... 20
Efficiency and Effectiveness Activities Related to Audit, Other Reports, and Follow-up Activities ............. 20
Indictments, Convictions, and Case Actions .................................................................................................... 20
SBA Personnel Actions Taken as a Result of Investigation ............................................................................ 20
Program Actions Taken During the Reporting Period as a Result of OIG Action .......................................... 21
Agency Legislative and Regulatory Proposals Reviewed ................................................................................. 21
Appendix B. Full-Year Statistical Highlights, FY 2022 ........................................................................................ 22
Summary of OIG Dollar Accomplishments ....................................................................................................... 22
Efficiency and Effectiveness Activities Related to Audit, Other Reports, and Follow-up Activities ............. 22
Indictments, Convictions, and Case Actions .................................................................................................... 22
SBA Personnel Actions Taken as a Result of Investigations ........................................................................... 22
Program Actions Taken During the Fiscal Year as a Result of OIG Action ................................................... 23
Agency Legislative and Regulatory Proposals Reviewed ................................................................................. 23
Appendix C. Reports, Recommendations, and Management Decisions ............................................................... 24
Reports Issued .................................................................................................................................................... 24
Reports with Questioned Costs (dollars)........................................................................................................... 25
Reports with Recommendations that Funds Be Put to Better Use ................................................................. 25
Reports from Prior Periods with Overdue Management Decisions ................................................................. 26
Reports from Prior Periods with Open Recommendations as of September 30, 2022 .................................... 28

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Significant Recommendations from Prior Reporting Periods without Final Action as of September 30, 2022
 ............................................................................................................................................................................ 29
Significant Recommendations from this Reporting Period .............................................................................. 45
Significant Management Decisions – OIG Disagreement ..................................................................................... 51
Significant Revised Management Decisions .......................................................................................................... 52
Federal Financial Management Improvement Act ............................................................................................... 52
Instances of Interference ........................................................................................................................................ 52
Appendix D. Investigations Reporting Statistics .................................................................................................. 53
Investigative Reports Issued ............................................................................................................................. 53
Persons Referred for Prosecution ...................................................................................................................... 53
Pandemic-Related Investigative Statistics ....................................................................................................... 53
Whistleblower Retaliation Cases ...................................................................................................................... 53
Investigations Involving a Senior Government Employee Where Misconduct Was Substantiated .............. 53
Investigations Involving a Senior Government Employee That Is Closed and Not Disclosed to the Public . 53
Appendix E. Legal Actions Summary .................................................................................................................... 54
April 1, 2022 – September 30, 2022 .................................................................................................................. 54
Appendix F. Cosponsored and Other Activities ..................................................................................................... 59
Appendix G. External Peer Reviews ...................................................................................................................... 61
Audits Division ................................................................................................................................................... 61
Investigations Division ...................................................................................................................................... 61
Appendix H. Office of Inspector General Reporting Requirements ...................................................................... 62
Reporting Requirements in the Inspector General Act of 1978, As Amended ................................................ 62

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Summary of OIG Oversight Work
Pandemic Response Oversight
To support businesses affected by the Coronavirus Disease 2019 (COVID-19) pandemic, Congress tasked
SBA with lending $470 billion in COVID-19 Economic Injury Disaster Loans (EIDL) and $20 billion in COVID-
19 emergency grants. Congress appropriated additional funds for new disaster assistance programs: $35
billion for targeted and supplemental EIDL advances, $16.25 billion for the Shuttered Venue Operators
Grant (SVOG) program, and $28.6 billion for the Restaurant Revitalization Fund (RRF).
The Coronavirus Aid, Relief, and Economic Security (CARES) Act provided $349 billion for the creation of
the Paycheck Protection Program (PPP) under Section 7(a) of the Small Business Act. Congress added an
additional $310 billion to the PPP on April 24, 2020 through the Paycheck Protection Program and Health
Care Enhancement Act.
The Consolidated Appropriations Act of 2021, the Economic Aid to Hard-Hit Small Businesses, Nonprofits,
and Venues Act, extended the program through March 31, 2021, providing an additional $147.5 billion in
PPP funding. Lastly, the American Rescue Plan Ac of 2021t provided an additional $7.25 billion, which
increased the total program funding to $813.7 billion.
SBA’s need to quickly provide relief to small businesses led to reduced controls on pandemic-related
loans and grants, substantially increasing the fraud risk. It was immediately clear that pandemic relief
efforts had drawn the attention of unscrupulous and greedy criminals. Complaints from lenders and
allegations of misuse of funds overwhelmed OIG’s Hotline. A growing national narrative told of
widespread fraudulent activity involving funds intended to provide economic relief to qualifying small
businesses and entrepreneurs. We launched investigations and audits to root out the fraud and abuse
endangering these critical resources.
The following summarizes our pandemic oversight work this period.
Audits, Inspections, and Evaluations
Evaluation of SBA’s Disaster Assistance Loan Recommendation Services
(Report 22-10)
We evaluated the SBA’s procedures to award a contract for data analysis and loan
recommendation services for EIDL applications and Targeted EIDL Advance
applications related to the COVID-19 pandemic. To increase loan processing
capabilities and quickly disburse loans during the pandemic, SBA used an existing
contract awarded to RER Solutions and its subcontractor Rocket Loans set aside for
small businesses. SBA initially set a contract ceiling of $100 million and then used emergency contracting
authority to increase the contract ceiling to $850 million.
SBA relied on an earlier 2018 contract but did not follow the proper procedures to ensure that contract
provided the best value to the government. SBA awarded the contract for data analysis and loan
recommendation services without adequately ensuring the contract prices were fair and reasonable in

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accordance with Federal Acquisition Regulation and agency policy. SBA did not ensure the contractor
complied with established size standards to be eligible for a small business set-aside award. SBA also did
not ensure the contractor complied with subcontracting limitations, exceeding the limit by $13 million.
These awards are intended to help small businesses compete and win government contracts. Instead,
the COVID-19 contract was noncompetitively awarded and largely performed by an affiliate of one of the
nation’s largest mortgage lenders.
We made six recommendations to strengthen SBA’s procurement policies and enhance controls to
ensure compliance with SBA’s contracting program requirements. SBA agreed or partially agreed with all
six recommendations.
Access this evaluation report on the SBA OIG Reports site.
SBA's Handling of Potentially Fraudulent Paycheck Protection Program
Loans (Report 22-13)
We found that SBA did not have an organizational structure with clearly defined
roles, responsibilities, and processes to manage and handle potentially fraudulent
PPP loans across the program. In addition, the agency did not establish a
centralized entity to design, lead, and manage fraud risk. This problem occurred
because the agency did not establish a sufficient fraud risk framework at the start
of and throughout PPP implementation. Management stated this was partly due to the speed of the
delivery of PPP and the continuous and rapid discovery of different kinds of fraud schemes. Lenders also
were not always clear on how to handle PPP fraud or recover funds obtained fraudulently from the PPP
that remained in the borrower’s account. SBA did not provide lenders sufficient specific guidance to
effectively identify, track, address, and resolve potentially fraudulent PPP loans. During our review, SBA
established a Fraud Risk Management Board.
To better mitigate fraud, we recommended SBA establish clearly defined and detailed roles,
responsibilities, and processes and provide lenders formal guidance for managing and handling
potentially fraudulent loans. SBA management generally agreed with the findings and agreed with both
recommendations. Management plans to document the roles, responsibilities, and processes for all SBA
offices responsible for managing and handling potentially fraudulent PPP loans. Management also plans
to consolidate its existing guidance to lenders regarding fraud and provide new guidance as appropriate.
Access this inspection report on the SBA OIG Reports site.
SBA’s Award and Payment Practices in the Shuttered Venue Operators
Grant Program (Report 22-15)
We inspected the SBA’s award and payment practices used to administer the SVOG
program. Even after determining multiple disbursements would better protect
grant funds from fraud or misuse, SBA switched to a riskier single advance payment
for all grantees. This payment method may have hastened award disbursement, but
the agency removed internal controls that would have better protected taxpayer
funds. Multiple disbursements enable program officials to verify that grant recipients used award funds
for allowable activities before disbursing additional funds. In our sample of 10 awards, to test SBA’s

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disbursement and budget approval practices, none had the proper documentation signed by an
authorized government official. The authorizing agency signature on the notice of award demonstrates
that the proper procedure has been followed and the obligation has been officially recorded.
Program officials did not ensure they had adequate support for the grant amounts in 3 of the 10 awards
we reviewed. SBA awarded these three recipients $2.6 million above amounts that were requested. The
higher grant award amounts did not correspond to their budgets, nor was there supporting
documentation to show why SBA awarded the higher amounts.
We made six recommendations for SBA management to ensure SBA properly safeguards program funds
and improves disbursement and award procedures while administering the SVOG program. SBA
management agreed or partially agreed with four recommendations and disagreed with two.
Management’s planned actions resolved all six recommendations.
Access this inspection report on the SBA OIG Reports site.
SBA’s COVID-19 EIDL Program Data Migration Challenges (Report 22-
16)
OIG found that SBA had been migrating data from its software provider without a
data migration plan. This software service provider is an outside company
contracted to provide cloud-based software solutions. Without advance planning
for data migration and defined acceptance criteria, SBA took reactive measures to
prevent the loss of vital program data when the contract ended on June 30, 2022.
To address concerns about data migration challenges for SBA’s COVID-19 EIDL pandemic relief program,
we suggested the SBA design and implement a comprehensive migration plan for the COVID-19 EIDL
program, to include defined acceptance criteria and robust testing, with detailed project milestones and
defined areas of responsibility for program management, information technology, and procurement
groups so that data is preserved to meet the needs of all stakeholders.
SBA managers stated they were working to modify the software service provider contract to ensure data
will remain available for future litigation efforts. Management’s plan to modify the contract would ensure
data is preserved. Once the contract modification is complete, the risk of data loss will be mitigated.
Safeguarding the data from destruction beyond the June 30, 2022 contract expiration will allow SBA to
support legal proceedings for the immediate future.
Access this memorandum report on the SBA OIG Reports site.
SBA’s COVID-19 EIDL Applications Submitted from Foreign IP
Addresses (Report 22-17)
We evaluated SBA’s controls to flag or prevent potentially fraudulent COVID-19 EIDL
applications submitted from foreign Internet Protocol (IP) addresses. We found that
although the agency implemented several layers of controls to prevent or reduce
fraud from foreign countries, foreign IP addresses were able to access the
application system. SBA received millions of attempts to submit COVID-19 EIDL
applications from foreign IP addresses and stopped most of them; however, the agency processed more

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than 233,000 of these applications from March 20, 2020 to November 12, 2021, our review period. Of
this amount, SBA approved and disbursed 41,638 COVID-19 EIDLs, advances, and grants for $1.3 billion.
The numerous applications submitted from foreign IP addresses are an indication of potential fraud that
may involve international criminal organizations. OIG has ongoing investigations into international
organized crime operations that applied for and stole pandemic relief funds. SBA officials were aware of
and concerned about the potential fraud from overseas.
We recommended the agency thoroughly review the loans in our test sample and the $1.3 billion
disbursed to applicants from foreign IP addresses. The agency should stop any further or future
disbursements to any applicants deemed to be ineligible or fraudulent. We also recommended SBA
recover any disbursed loans and advances determined to be ineligible or fraudulent. Additionally, we
recommended that the agency examine controls related to foreign IP addresses and ensure these
controls are more effective in future disaster processing systems. Management partially agreed with
recommendation 1 and agreed with recommendation 2.
Access this evaluation report on the SBA OIG Reports site.
COVID-19 and Disaster Assistance Information Systems Security
Controls (Report 22-19)
We found the agency’s entity-level control environment was not designed in
accordance with federal guidance at the beginning of the COVID-19 assistance
programs. SBA needed information technology systems from third-party service
providers that could improve the system efficiency and productivity to process
high transaction volumes, transmit data between other information systems, and
safeguard the integrity and confidentiality of the personally identifiable information processed by the
programs. The agency allowed the third-party systems to be put into service without conducting the
baseline assessments. With no baseline, the agency could not perform effective continuous monitoring.
Also, we found that control processes did not identify, communicate, and capture privacy and identity
risks on an enterprise-wide basis.
We made 10 recommendations to strengthen the agency’s entity-level IT control environment. The areas
addressed included cybersecurity risk and privacy controls, system development life cycle, continuous
monitoring, and the supply chain risk management processes.
SBA management agreed with seven recommendations, disagreed with two recommendations, and
stated one recommendation was specific to the pandemic and will not likely be repeated. While the
agency agreed to implement seven recommendations, management’s planned corrective actions did not
fully address identified control issues.
Access this audit report on the SBA OIG Reports site.
Paycheck Protection Program Eligibility for Nonprofit Organizations
(Report 22-21)
Based on data analysis, we identified 179 PPP loans, totaling approximately $684
million, made to potentially ineligible nonprofits that may have exceeded SBA’s
requirements for business size, known as size standards, at the time of application.

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We also reviewed PPP loans for three large nonprofits, including Planned Parenthood of Illinois that
received over $3.8 million, Goodwill of Southwestern Pennsylvania that received over $6 million, and
YMCA of the Rockies that received over $3.5 million. OIG included a Planned Parenthood organization to
address concerns from some members of the U.S. Senate Committee on Small Business and
Entrepreneurship. We determined that the Planned Parenthood organization met PPP loan eligibility
requirements. The Goodwill organization was not eligible for a PPP loan at the time of application but
subsequently became eligible for forgiveness due to updated PPP guidance. The YMCA organization we
reviewed did not meet eligibility requirements because they exceeded the applicable size standard of no
more than 500 employees at the time of application and forgiveness.
We also reviewed the three national organizations associated with the PPP loans to the aforementioned
Planned Parenthood, Goodwill, and YMCA for potential affiliation with the PPP loan recipients. We found
no affiliation between the national organizations and the loan recipients.
We recommended SBA review the 179 PPP loans, totaling approximately $684 million, to ensure
eligibility requirements were met and seek remedy or repayment for all loans deemed ineligible, and
seek remedy or repayment of the PPP loan we reviewed for YMCA totaling $3.5 million. SBA
management partially agreed with recommendation 1 and agreed with recommendation 2.
Access this inspection report on the SBA OIG Reports site.
Follow-Up Inspection of SBA’s Internal Controls to Prevent COVID-19
EIDLs to Ineligible Applicants (Report 22-22)
We found SBA did not implement the tax transcript requirement in a timely
manner, potentially disbursing COVID-19 EIDLs to ineligible entities. The CARES Act
prohibited the agency from requiring tax return transcripts to prove eligibility.
Congress eliminated this restriction 9 months later with the Consolidated
Appropriations Act, 2021. For about 4 months after Congress removed the tax
return prohibition, SBA made 133,832 COVID-19 EIDL disbursements, totaling about $8.5 billion, without
proving applicant eligibility using official tax information. Of that amount, more than $92 million was
disbursed to businesses with suspect Taxpayer Identification Numbers.
We reviewed 30 of these loans approved before SBA implemented the requirement for tax return
transcripts and found that 16 of them, totaling about $1.1 million, should not have been approved.
Specifically, we found disbursements to 13 businesses that did not exist on or before January 31, 2020 or
had an unknown start date. We also found three businesses that did exist on or before January 31, 2020,
but had other red flags, including change of registered agent shortly before the application date,
evidence of falsified documents, or evidence the applicant did not own the business.
We recommended SBA recover funds disbursed to ineligible applicants identified in our sample and
review the remaining COVID-19 EIDL disbursements with suspect tax ID numbers to determine if the
business applicant was legitimate and met CARES Act eligibility requirements. SBA agreed with our
recommendations and plans to review the loans identified in the report to determine if the applicant
business qualified for assistance under the COVID-19 EIDL eligibility criteria and attempt to recover funds
provided to ineligible businesses.
Access this inspection report on the SBA OIG Reports site.

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SBA's Guaranty Purchases for Paycheck Protection Program Loans (Report
22-25)
In anticipation of a significant number of delinquent PPP loans that lenders will
submit for guaranty purchase, we began reviewing SBA’s process for approving
PPP guaranty purchases. During our review, we identified concerns with SBA’s
decision to end collections on PPP loans with an outstanding balance of $100,000
or less. We found that expedited management action is needed to determine
whether it is cost effective to pursue collections on these loans. Management attention is needed to
ensure effective stewardship of billions of dollars in potential funds owed to taxpayers. Ending collections
could incentivize ineligible borrowers to obtain loans valued at $100,000 or less in similar future loan
programs. However, continuing to pursue collections will help ensure accountability from delinquent
borrowers.
We recommended the SBA Administrator stay the April 27, 2022 decision to end collections on
purchased PPP loans with an outstanding balance of $100,000 or less until a comprehensive cost benefit
analysis can be conducted. We recommended the agency explore alternative means of collections for
PPP loans with an outstanding balance of $100,000 or less. We also recommended conducting an initial
and periodic cost benefit analysis on PPP purchase guarantees with comprehensive estimates to
sufficiently assess whether the cost of collecting loans of $100,000 or less is more than the recovery
amount and pursue collections based on results of the analysis. Management disagreed with
recommendations 1 and 2 and agreed with recommendation 3.
Access this management advisory on the SBA OIG Reports site.
Notable Investigations
California Man Sentenced to Over 11 Years for $27 Million PPP Fraud
Scheme
A Southern California man was sentenced to about 11 years and 3 months for submitting
fraudulent applications seeking money from the PPP, submitting false statements to a
financial institution, and money laundering. He submitted 27 PPP loan applications to
four banks on behalf of eight companies and sought a total of $27 million in forgivable
PPP loans. In his fraudulent applications, he represented that each of his companies had
100 employees and average monthly payroll of $400,000, even though he knew that the companies did
not have any employees or payroll expenses. He used the funds for personal expenses, including cash
withdrawals, payments on his personal credit cards, transfers to other personal and business accounts he
controlled, and renting an ocean-front apartment in Santa Monica.
DC man Sentenced to 10 Years for Attempting to Steal More than $31
Million in COVID-19 Funds
A Washington, DC man was sentenced to 10 years for attempting to steal more than $31
million and laundering the proceeds of the crime. The man succeeded in stealing $2.4
million in PPP and EIDL funds. From July 2020 through May 2021, the man used his

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company to fraudulently apply for at least 25 PPP loans totaling more than $30 million. He also submitted
at least four false EIDL applications totaling $950,000. In support of his fraudulent applications, the man
used stolen identities, stolen tax returns, and stolen financial records from a Washington, DC consulting
company, which he doctored to appear to be tax returns and payroll records from his company. Once
received, the man wired the loan proceeds of his scheme to at least 13 separate bank and brokerage
accounts, purchased a Tesla Model 3, and converted at least $288,000 of proceeds from fiat currency
into multiple cryptocurrencies. Fiat currency is a national currency with value derived from a country’s
promise to back it, not from physical commodities like gold or silver. The man conducted over 2,000
transactions involving at least 43 different cryptocurrencies.
Texas Man Sentenced to More Than 9 Years in COVID-19 Fraud and
Money Laundering Scheme
A Texas man was sentenced to 110 months for his scheme to fraudulently obtain and
launder proceeds from more than $1.6 million in PPP loans. He pled guilty in September
2021 to charges of wire fraud and money laundering, submitting fraudulent PPP loan
applications to two different lenders on behalf of three entities. Through these loan
applications, he sought over $2.6 million and obtained over $1.6 million in PPP funds. He
falsely represented the number of employees and payroll expenses in each of the loan applications. To
support the fraudulent applications, he also submitted fraudulent tax records. He applied in the name of
a person who died shortly before the application was submitted. With these taxpayer funds he
purchased a Lamborghini Urus, a Ford F-350 truck, a Rolex watch, and paid off a loan on a residential
property. The Department of Justice, along with law enforcement partners, seized over $700,000 of the
funds fraudulently obtained.

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Small Business Access to Capital
SBA provides small businesses with financial assistance through several key programs. SBA has a financial
assistance portfolio of guaranteed and direct loans that totaled about $240 billion as of March 2022,
after the forgiveness of over $700 billion in Paycheck Protection Program loans. Over the years, OIG has
worked closely with the agency to identify potential points of risk and improve SBA’s oversight and
controls to ensure eligible participants most in need of assistance benefit from these programs.
The Section 7(a) loan program is SBA’s principal vehicle for providing small businesses with access to
credit that cannot be obtained elsewhere. Proceeds from a 7(a) loan may be used to establish a new
business or to assist in acquiring, operating, or expanding an existing business. This program relies on
numerous outside parties (such as borrowers, loan agents, and lenders) to complete loan transactions.
SBA has centralized several loan approval and servicing functions and reduced the number of staff
performing these functions, placing more responsibility on and giving greater independence to lenders.
Past OIG reviews have reported on these trends, and OIG continues to identify weaknesses in SBA’s
lender and loan agent oversight processes.
Criminals use a wide array of techniques to fraudulently get—or induce others to obtain—SBA-
guaranteed loans. The techniques include submitting fraudulent documents, making fictitious asset
claims, manipulating listed property values, using loan proceeds contrary to the terms of the loans, and
failing to disclose debts or previous criminal records.
Consequently, there is a greater chance of financial loss to the agency and its lenders. OIG dedicates a
significant portion of its resources to identifying wrongdoers and, whenever possible, recovering taxpayer
funds. The following summarizes our work this period.
Inspection
SBA’s Actions to Improve the Management of the 7(a) Loan Guaranty
Approval Process (Report 22-18)
In a 2014 audit, we found significant opportunities existed to improve the
management of the 7(a) loan guaranty approval process to mitigate its risk of loss
and protect the integrity of the program. Specifically, the audit found that
processing center management emphasized quantity over quality for 7(a) loan
reviews, and processing center loan specialists were not provided adequate
guidance and training to conduct their 7(a) loan review activities.
A verification inspection is a short review that focuses on closed recommendations from prior OIG
reports. This inspection focused on recommendation 1, which recommended that SBA revise
management reports to measure quality against established targets, ensure production credit is given for
all loan review actions, and promote compliance with SBA requirements. We found SBA effectively
implemented recommendation 1 by revising its management reports to include key factors for
measuring the quality and complexity of loan reviews to promote compliance with SBA requirements.
Access this inspection report on the SBA OIG Reports site.

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Disaster Assistance Program
Disaster assistance has been part of the agency since its inception in 1953. SBA provides long-term, low-
interest financial assistance to businesses of all sizes, private nonprofits, homeowners, and renters
following a declared disaster. Each year, SBA approves hundreds of millions of dollars in disaster
assistance loans.
The disaster assistance loan program is the only form of SBA assistance not limited to small businesses.
The program’s disaster assistance loans are the primary form of federal assistance for repairing and
rebuilding nonfarm, private sector losses following a declared disaster.
The program includes four categories of loans for disaster-related losses:
• Home disaster loans
• Business disaster loans (includes PPP loans)
• Economic injury disaster loans (includes pandemic relief loans)
• Military reservist economic injury loans
The following summarizes our work this period.
Investigations
Colorado Man Sentenced to 66 Months for EIDL and PPP fraud
A Colorado man pled guilty and was sentenced to two concurrent 66-month terms and to
pay $367,552 in restitution to SBA. Between March and October 2020, he devised a
scheme to defraud and obtain money by means of materially false representations on his
EIDL and PPP loan applications. As a result of the scheme, he received two EIDLs totaling
$185,500, and one PPP loan for $20,052.
Salt Lake City Man Charged in $1.8 Million CARES Act Loan Fraud
Scheme
A Salt Lake City man was charged by a federal grand jury in the District of Utah with
fraudulently obtaining more than $1.8 million in EIDL funds. He submitted six fraudulent
loan applications to SBA between March and June 2020 and obtained $1.9 million in loan
proceeds. He used the proceeds from these pandemic assistance loans to purchase a
$610,000 home in West Jordan, a $518,000 house in Las Vegas, a Jaguar F-PACE SUV for
$16,058, a BMW M3 luxury car for $26,723; and $39,000 in cryptocurrency from Robinhood and
Coinbase.

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10 | Fall 2022 Semiannual Report to Congress
Contracting and Counseling Programs
The U.S. government is the largest single purchaser of goods and services in the world, awarding over
$550 billion in prime contracts annually. SBA works to maximize opportunities for small businesses to
receive these contract awards. As mandated by the Small Business Act, the government-wide goal is to
award at least 23 percent of contract dollars to small businesses.
SBA has specific programs that focus on strengthening particular types of small businesses, like those
owned by service-disabled veterans, Women-Owned Small Businesses (WOSB), as well as small
businesses that are disadvantaged or located in historically underutilized business zones (HUBZones).
The HUBZone program helps small businesses stimulate their economically challenged local economies.
Similarly, to help small, disadvantaged businesses gain access to federal and private procurement
markets, SBA’s 8(a) Business Development Program helps small businesses owned by socially and
economically disadvantaged entrepreneurs gain business skills and access to federal contracting
opportunities so that they can better compete in the open marketplace. The program offers free
business development education, training workshops, and match-making opportunities with federal
buyers.
SBA also aids existing and prospective small businesses through a variety of counseling and training
services offered by partner organizations. Among these partners are Small Business Development
Centers, the SCORE mentoring network, Women’s Business Centers, and Veterans Business Outreach
Centers. SBA also started the Community Navigator Pilot Program, an American Rescue Plan initiative.
The program will provide funding to organizations that will work with local community groups to improve
access to SBA and government resources.
Additionally, SBA designed the Boots to Business program, providing transitioning service members
interested in exploring business ownership or other self-employment opportunities with technical
assistance and access to resources. These programs require effective and efficient management,
outreach, and service delivery.
Audits, Inspections, and Evaluations
SBA’s Implementation of the Women-Owned Small Business
Certification Program (Report 22-20)
We found SBA had applicants provide documentation that demonstrates a woman
owned and controlled the business in accordance with federal regulations, but SBA
did not design a process that ensured analysts thoroughly and promptly reviewed
the documentation.
Despite requirements that the business be considered small to be eligible for
contracts set aside for WOSBs, SBA did not require that firms submit any documentation to ensure the
business met federal size regulations. We also determined the agency did not have adequate staffing
levels to support the program, nor did it ensure the database used to administer the eligibility reviews
could fully support the certification program. And though SBA relies on the program eligibility decisions

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that third-party certifiers make, SBA could not provide evidence that they effectively monitored third-
party certifiers compliance with program regulations.
We made six recommendations for SBA to improve its oversight and management of the WOSB
certification program. Management partially agreed with recommendations 1 and 6 and disagreed with
recommendations 2, 3, 4, and 5. We did not reach resolution on recommendations 1, 2, and 4.
Access this audit report on the SBA OIG Reports site.
SBA’s Protest Process (Report 22-24)
We found SBA had effective controls in place to ensure protest decisions were
properly enforced and used to monitor the protest process. The small business
protest process was created to allow self-interested offerors to police themselves
and prevent awards from going to ineligible businesses. The process was intended
to protect the integrity of set-aside awards and of SBA’s small business contracting
certification programs.
We found that only 4 percent of the small businesses protested in FY 2021 did not update their proper
status in their company profile after SBA found they did not qualify for set-aside awards. We also found
program officials decided 80 percent of small business protests within the required 15 business days, or
within extension dates approved by the contracting officer.
We made one recommendation for SBA management to strengthen controls to consistently document
and monitor required protest information to ensure decisions are made in a timely manner. SBA
Management agreed with the recommendation.
Access this audit report on the SBA OIG Reports site.
Investigations
Odyssey International Inc. and Former Officer of Company Convicted of
Obtaining $99 Million U.S. Government Contract
A federal jury found both Odyssey International Inc. and the president of the company
guilty of conspiracy to commit wire fraud and major fraud. The business fraudulently
claimed special status under an SBA program to obtain a $99 million contract meant for
a disadvantaged small business. Investigators found that in 2011, Odyssey fraudulently
bid on a $99 million HUBZone small business contract for work at the Fort Drum military
base in New York. To qualify for a HUBZone contract, at least 35 percent of the small business’s
employees must reside in a HUBZone. The company did not qualify as a small business and 35 percent of
its employees did not reside in a HUBZone.

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Construction Company Owner Convicted of Fraud in Securing Over $240
Million in Contracts Intended for Service-Disabled Veterans
A federal jury in San Antonio, Texas convicted the owner of several construction
companies and co-conspirators of defrauding the federal government in a long-running
contracting scheme to obtain valuable government contracts. The defendants falsely
claimed the ostensible owner of a general construction company was a service-disabled
veteran, fraudulently benefiting from a contracting designation meant to support small
veteran-owned businesses. The conspirators committed fraud against the United States to secure over
$240 million in government contracts.

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Agency Management
OIG is responsible for ensuring that agency management appropriately safeguards SBA from fraud,
waste, and abuse, and that SBA activities directly further agency goals. As part of this work, OIG
coordinates with the offices of the Chief Financial Officer, the Chief Information Officer, and the Chief
Operating Officer to review financial reporting and performance management, human resources,
procurements and grants, space and facilities, and maintenance of SBA’s information systems and
related security controls.
Audits, Inspections, and Evaluations
Fiscal Year 2021 Federal Information Security Modernization Act
Review (Report 22-11)
We tested a subset of systems in nine areas, called domains, and evaluated them
using guidance for Federal Information Security Management Act metrics. The Act
requires the information security program of every agency to be evaluated each
year. In FY 2021, SBA faced new information security challenges under the weight
of lending huge amounts during the pandemic.
Inspectors General are required to assess the effectiveness of information security programs on a
maturity model spectrum. We rated SBA’s overall program of information security as “not effective”
because SBA achieved a maturity level rating of “managed and measurable” in only one of the nine
domains.
We made 10 recommendations in five of the domains: three recommendations in risk management,
three recommendations for configuration management, two for identity and access management, one
recommendation for security training, and one for information security continuous monitoring. SBA
management agreed with the recommendations.
Access this evaluation report on the SBA OIG Reports site.
Independent Auditors’ Report on SBA’s Fiscal Year 2021 Compliance
with the Payment Integrity Information Act of 2019 (Report 22-12)
Public accounting firm KPMG found the agency was compliant with 5 of the 10
reporting requirements under the Act and Office of Management and Budget
(OMB) guidance. However, SBA is not in compliance with the Act because the
agency did not conduct or update the improper payment risk assessment for each
program with annual outlays greater than $10 million. Also three of four reported
areas did not publish an improper payment and unknown payment reduction target. The Disaster Direct
Loan Program did not publish corrective action plans, demonstrate improvement to payment integrity or
develop a plan to meet the improper payment and unknown payment reduction target, and the Disaster
Direct Loan Program reported a gross improper payments and unknown payments rate exceeding 10
percent, which is higher than the amount allowed by law. In addition, KPMG found the agency needs to

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14 | Fall 2022 Semiannual Report to Congress
improve the accuracy and appropriateness of improper payment reporting. The agency also needs to
improve controls to prevent and reduce improper payments.
Access this financial management report on the SBA OIG Reports site.
SBA's Controls Over Cash Contributions and Gifts, Fiscal Years 2022 and
2021 (Report 22-14)
We found that SBA complied with the 2021 Consolidated Appropriations Act, SBA
regulations and policies regarding soliciting and accepting cash contributions for
National Small Business Week 2021. SBA’s Office of Communications and Public
Liaison obtained proper approval from the Office of General Counsel for the 2021
National Small Business Week cosponsored activity.
We recommended the agency enhance the tracking system with alerts to ensure responsible officials
close out all cosponsored activities within 90 days, as required. We also recommended the agency
implement quality control procedures to ensure that required fiscal agent and SBA documents for future
National Small Business Week cosponsored activities are timely, complete, accurate, and can be relied
on. SBA management agreed with both of our recommendations.
Access this compliance report on the SBA OIG Reports site.
SBA’s Corrective Actions to Improve Monitoring District Offices’ Customer
Service Activities (Report 22-23)
We found SBA effectively implemented corrective actions for three of the four
recommendations made by OIG in a past audit. A verification inspection is a short
review that focuses on closed recommendations from a prior OIG report. Our
objective was to determine the effectiveness of corrective actions SBA
implemented to assess customer service at district offices and track and measure
customer service activities.
The corrective actions were implemented through the agency’s Goals and Measures Activity Tracking
Tool system, which records customer outreach activities. We determined this system has better
functionality than the previous system, the Activity Contact Report. The new system also includes
controls that allow for hierarchical reviews of recorded activities. Management enforced the policy for
district office officials to record customer outreach activities in the system in a timely manner. However,
program officials have not fully implemented a process to collect and analyze customer feedback.
We will track management’s implementation by reopening the recommendation and will work with SBA
to establish a target date for implementing corrective actions through the audit follow-up process.
Access this inspection report on the SBA OIG Reports site.

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Other Significant OIG Activities
Background Investigations Ensure Integrity
During this reporting period, OIG initiated 49 background investigations and issued 3 security clearances
for OIG employees and contractors. OIG adjudicated 23 background investigative reports.
Debarment and Other Administrative Enforcement Actions
OIG promotes program integrity by making present responsibility referrals to SBA and other agencies.
Present responsibility means the business ethics, integrity, honesty, and competence of persons who
participate in SBA programs or otherwise do business with the government. During this reporting period,
OIG sent 30 present responsibility referrals to SBA.
Present responsibility referrals can result in suspensions, debarments, and similar administrative
enforcement actions. These actions protect taxpayer funds from program participants who are not a
good risk for the government.
A typical OIG referral contains a summary of allegations and criminal, civil, administrative, or other
evidence supporting the recommendation. Most OIG administrative referrals involve SBA’s loan and
contract programs. OIG ensures that a suspension and debarment official reviews all appropriate
allegations arising in other contexts, such as the investigation of False Claims Act cases.
Stakeholder Presentations on PPP and EIDL Fraud
During this reporting period, SBA OIG conducted 109 presentations to internal and external stakeholders
to raise awareness of fraud, waste, and abuse related to SBA programs. More than 2,570 participants
attended these events.
Reviews of Proposed Agency Regulations, Operating
Procedures, and Other Initiatives Lead to Improved Program
Controls
OIG reviews changes SBA proposes to make to its program directives, such as regulations, internal
operating procedures, agency policy notices, and SBA forms completed by the public. OIG often identifies
material weaknesses in the proposals and works with the agency to promote more effective controls to
deter waste, fraud, and abuse. During the reporting period, OIG reviewed 60 proposed revisions of these
program directives and submitted comments designed to improve 12 of these initiatives.
Approval of Small Business Development Center Surveys
Section 21(a)(7) of the Small Business Act states that until Small Business Development Center
information disclosure regulations are issued, the Inspector General must approve any related client
survey, as well as the use of any survey information. OIG must also include this approval in the
semiannual report. SBA did not submit any surveys OIG review during this reporting period.

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OIG Hotline
OIGs have a hotline function that takes complaints
from anyone who suspects waste, fraud, abuse, or
serious mismanagement within an agency or its
programs by employees, contractors, and the
public. Hotline complaints may result in corrective
actions, audits, or administrative, civil, or criminal
investigations.
Our Hotline staff vets complaints and monitors
the progress of matters referred to SBA program
offices for action to ensure the agency has
promptly followed up, adequately resolved
allegations, and documented any corrective
actions.
Unprecedented Numbers
Hotline work has changed dramatically
because of the COVID-19 pandemic. OIG’s
Hotline team has been diligently working
through a large backlog of complaints. The staff
is addressing each complaint received via
online submissions to the SBA OIG website,
telephone, e-mail, posted mail, as well as
referrals from banks and other agencies.
During this semiannual period, the OIG Hotline
received more than 29,000 complaints of loan
fraud and abuse, identity theft, and issues with
SBA’s customer service. Hotline complaints
may result in corrective actions, audits, or
administrative, civil, or criminal investigations.
Our Hotline staff monitors the progress of
matters referred to SBA program offices for
action to ensure the agency has promptly followed up, adequately resolved allegations, and documented
any corrective actions.

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Organizational Overview
U.S. Small Business Administration
The mission of the SBA under the Small Business Act, as amended, is to maintain and strengthen the
nation’s economy by enabling the establishment and vitality of small businesses and assisting in the
economic recovery of communities after disasters. The agency’s strategic plan for FYs 2022-26 has three
key goals:
1. Ensure equitable and customer-centric design and delivery of programs to support small
businesses and innovative startups
2. Build resilient businesses and a sustainable economy
3. Implement strong stewardship of resources for greater impact
SBA is organized around the areas of financial, contracting, entrepreneurial development, and disaster
assistance. The agency also represents small businesses through an independent advocate and an
ombudsman.
SBA headquarters is in Washington, DC. The agency has staff in 10 regional offices, 68 district offices and
corresponding branch offices, and 4 disaster field offices. SBA also has 6 government contracting area
offices and maintains a network of resource partners in all 50 states, the District of Columbia, Puerto
Rico, American Samoa, the U.S. Virgin Islands, and Guam.

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18 | Fall 2022 Semiannual Report to Congress
Office of Inspector General
OIG’s mission is to provide independent, objective, and timely oversight to improve the integrity,
accountability, and performance of SBA and its programs for the benefit of all Americans.
Our strategic plan for FYs 2022-27 has four goals. In addition to the Office of Counsel to the Inspector
General, three divisions assist in carrying out the statutory responsibilities of the OIG: the Audits Division,
Investigations Division, and the Management and Operations Division.
Our vision is to be valued and engaged change agents who set the standard for oversight excellence in
support of America’s small businesses.
We seek to demonstrate our values of integrity, commitment, and excellence as we deliver products and
services of the highest quality defined by accuracy, timeliness, fairness, and usefulness.
The Office of Counsel provides legal and
ethics advice to all OIG components;
protects the OIG’s interests in litigation
arising out of or affecting OIG operations;
assists with the prosecution of criminal,
civil, and administrative enforcement
matters; processes subpoenas; responds
to Freedom of Information and Privacy
Act requests, and reviews and comments
on proposed policies, regulations,
legislation, and procedures.
The Audits Division performs and
oversees audits and reviews to promote
the economical, efficient, and effective
administration of SBA programs and
operations. Key areas of emphasis are
SBA loan, disaster assistance, business
development, and government
contracting programs, as well as
mandatory and other statutory audit
requirements involving information technology security, financial reporting, and other SBA program
areas. The balance of the engagements is discretionary and focuses on high-risk activities and identified
management issues.
The Investigations Division manages a program to detect and deter illegal and improper activities
involving SBA’s programs, operations, and personnel. The criminal investigations staff carries out a full
range of traditional law enforcement functions. Within the division, the Hotline reviews allegations of
waste, fraud, abuse, and severe mismanagement within SBA or its programs made by employees,
contractors, and the public.
A preliminary review of all complaints is conducted to determine the appropriate course of action. As
part of the review process, Hotline staff may coordinate reviews of allegations within OIG, SBA program

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 19
offices, or other government agencies. The Security Operations Staff within the division conducts
required employee and contractor background investigations to achieve a high level of integrity in the
agency's workforce. It makes adjudications on OIG employees and contractors for issuance of PIV cards
pursuant to HSPD-12 background investigations requirements.
The Management and Operations Division provides business support (e. g., budget and financial
management, human resources, IT, data analytics, and procurement) for various OIG functions and
activities.
OIG’s headquarters is in Washington, DC. Our field offices are in Atlanta, Georgia; Chicago, Illinois; Dallas-
Fort Worth, Texas; Detroit, Michigan; Denver, Colorado; Herndon, Virginia; Houston, Texas; Los Angeles,
California; Miami, Florida; New York, New York; Philadelphia, Pennsylvania; Federal Way, Washington;
and Washington, DC.

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Appendixes
Appendix A. Reporting Period Statistical Highlights
Summary of OIG Dollar Accomplishments
Dollar Accomplishments as a Result of Investigations and Related Activities
—
Potential Investigative Recoveries and Fines
$89,678,059
Other Recoveries (e.g., administrative seizures with partner law
enforcement agencies)
44,598,318
Asset Forfeitures Attributed to OIG Investigations
9,702,469
Loans/Contracts Not Approved or Canceled as a Result of Investigations
2,714,347
Investigations Subtotal
146,693,193
Dollar Accomplishments as a Result of Audit Activities
—
Disallowed Costs Agreed to by Management
0
Recommendations that Funds Be Put to Better Use Agreed to by
Management
0
Audit Subtotal
0
Total OIG Dollar Accomplishments
$146,693,193
Efficiency and Effectiveness Activities Related to Audit, Other Reports,
and Follow-up Activities
Reports Issued
16
Recommendations Issued
59
Dollar Value of Costs Questioned
$54,344,357
Dollar Value of Recommendations that Funds Be Put to Better Use
0
Recommendations with Management Decisions
40
Recommendations without a Management Decision
40
Collections as a Result of Questioned Costs
0
Indictments, Convictions, and Case Actions
Indictments from OIG Cases
141
Convictions from OIG Cases
100
Cases Opened
213
Cases Closed
133
SBA Personnel Actions Taken as a Result of Investigation
Dismissals
0
Resignations and Retirements
0
Suspensions
0
Reprimands
0

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Semiannual Report to Congress, Fall 2022 | 21
Program Actions Taken During the Reporting Period as a Result of OIG
Action
Present Responsibility Referrals to the Agency
30
Pending at the Agency as of September 30, 2022
25
Suspensions Issued by the Agency
7
Proposed Debarments Issued by the Agency
25
Final Debarments Issued by the Agency
15
Proposed Debarments Declined by the Agency
0
Administrative Agreements Entered by the Agency in Lieu of Debarment
0
Present Responsibility Actions by Other Agencies
0
Agency Legislative and Regulatory Proposals Reviewed
Legislation, Regulations, Standard Operating Procedures, and Other Issuances Reviewed
60
Comments Provided by OIG to Improve Legislation, Regulations, Standard Operating Procedures,
and Other Issuances
12

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Appendix B. Full-Year Statistical Highlights, FY 2022
Summary of OIG Dollar Accomplishments
Dollar Accomplishments as a Result of Investigations and Related
Activities
—
Potential Investigative Recoveries and Fines
$184,925,326
Other Recoveries (e.g., administrative seizures with partner law
enforcement agencies)
89,564,199
Asset Forfeitures Attributed to OIG Investigations
33,468,574
Loans and Contracts Not Approved or Canceled as a Result of
Investigations
8,865,853
Investigations Subtotal
316,823,952
Dollar Accomplishments as a Result of Audit Activities
—
Disallowed Costs Agreed to by Management
4,500,000,000
Recommendations that Funds Be Put to Better Use Agreed to by
Management
0
Audit Subtotal
4,500,000,000
Total OIG Dollar Accomplishments
$4,816,823,952
Efficiency and Effectiveness Activities Related to Audit, Other Reports,
and Follow-up Activities
Reports Issued
25
Recommendations Issued
129
Dollar Value of Costs Questioned
$4,662,253,423
Dollar Value of Recommendations that Funds Be Put to Better Use
0
Recommendations with Management Decisions
105
Recommendations without Management Decisions
40
Collections as a Result of Questioned Costs
0
Indictments, Convictions, and Case Actions
Indictments from OIG Cases
294
Convictions from OIG Cases
194
Cases Opened
559
Cases Closed
289
Investigations identified an additional number of indictments/convictions than previously reported in the Spring 2022 semiannual
report.
SBA Personnel Actions Taken as a Result of Investigations
Dismissals
0
Resignations and Retirements
0
Suspensions
0
Reprimands
0

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Program Actions Taken During the Fiscal Year as a Result of OIG Action
Present Responsibility Referrals to the Agency
53
Pending at the Agency as of September 30, 2022
49
Suspension Issued by the Agency
7
Proposed Debarments Issued by the Agency
23
Final Debarments Issued by the Agency
15
Proposed Debarments Declined by the Agency
0
Administrative Agreements Entered by the Agency in Lieu of Debarment
0
Present Responsibility Actions by Other Agencies
0
Agency Legislative and Regulatory Proposals Reviewed
Legislation, Regulations, Standard Operating Procedures, and Other
Issuances Reviewed
142
Comment Memoranda Provided by OIG to Improve Legislation,
Regulations, Standard Operating Procedures, and Other Issuances
24

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Appendix C. Reports, Recommendations, and Management
Decisions
Reports Issued
Agency Management
Title
Report
Number
Issue Date
Questioned
Costs
Funds for
Better Use
FY 2021 FISMA Review
22-11
4/28/2022
—
—
Independent Auditors’ Report on SBA’s Fiscal Year 2021
Compliance with the PIIA of 2019
22-12
5/17/2022
—
—
SBA's Controls Over Cash Contributions and Gifts Fiscal Years
2022 and 2021
22-14
6/15/2022
—
—
COVID-19 and Disaster Assistance Information Systems Security
Controls
22-19
9/27/2022
—
—
SBA’s Corrective Actions to Improve Monitoring District Offices’
Customer Service Activities
22-23
9/30/2022
—
—
Program Subtotal
5
—
0
0
Credit/Capital Programs
Title
Report
Number
Issue Date
Questioned
Costs (dollars)
Funds for
Better Use
SBA’s Handling of Potentially Fraudulent PPP Loans
22-13
5/26/2022
—
—
The 7(a) Loan Guaranty Approval Process
22-18
9/20/2022
—
—
Paycheck Protection Program Eligibility for Nonprofit
Organizations
22-21
9/26/2022
3,544,216
—
SBA's Guaranty Purchases for PPP Loans
22-25
9/30/2022
—
—
Program Subtotal
4
—
$3,544,216
0
Disaster Assistance
Title
Report
Number
Issue Date
Questioned
Costs
(dollars)
Funds for
Better Use
SBA’s COVID-19 EIDL Program Data Migration Challenges
22-16
7/19/2022
—
—
Evaluation of COVID-19 EIDL Applications Submitted from
Foreign IP Addresses
22-17
9/12/2022
—
—
Follow-up Inspection of SBA’s Internal Controls to Prevent
COVID-19 EIDLs to Ineligible Applicants
22-22
9/29/2022
1,969,200
—
Program Subtotal
3
—
$1,969,200
0
Contracting and Counseling Programs
Title
Report
Number
Issue Date
Questioned
Costs
(dollars)
Funds for
Better Use
Evaluation Of SBA’s Contract for Disaster Assistance Loan
Recommendation Services
22-10
4/14/2022
$13,046,125
—
Inspection of SBA's Award and Payment Practices in the
Shuttered Venue Operators Grant Program
22-15
7/5/2022
35,784,816
—
SBA’s Implementation of the Women-Owned Small Business
Certification Program
22-20
9/29/2022
—
—
SBA’s Protest Process
22-24
9/30/2022
—
—
Program Subtotal
4
—
$48,830,941
0

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 25
Reports with Questioned Costs (dollars)
IG Act Reporting Requirement
Reports
Recommendations*
Questioned
Costs**
(dollars)
Unsupported
Costs***
(dollars)
A.
No management decision made by
March 31, 2022
2
4
$35,618,105
$10,800,476
B.
Issued during this reporting period
4
6
54,344,357
1,969,200
Subtotal (universe from which management
decisions could be made in this reporting
period)
6
10
89,962,462
12,769,676
C.
Management decisions made during this
reporting period
3
6
49,330,941
0
(i) Disallowed costs
0
0
0
0
(ii) Costs not disallowed
3
6
49,330,941
0
D.
No management decision made by
September 30, 2022
3
4
$40,631,521
$12,769,676
*
Reports may have more than one recommendation.
**
Questioned costs found to be improper.
***
Unsupported costs that may be proper but lack documentation. Unsupported costs are a subset of questioned costs.
Reports with Recommendations that Funds Be Put to Better Use
IG Act Reporting Requirement
Reports
Recommendations
Recommended
Funds for Better
Use
A.
No management decision made by March 31, 2022
—
—
—
B.
Issued during this reporting period
—
—
—

Subtotal (universe from which management decisions
could be made in this reporting period)
—
—
—
C.
Management decisions made during this reporting period
—
—
—
(I) Recommendations agreed to by SBA management
—
—
—
(Ii) Recommendations not agreed to by SBA management
—
—
—
D.
No management decision made by September 30,2022
—
—
—

U.S. Small Business Administration | Office of Inspector General
26 | Fall 2022 Semiannual Report to Congress
Reports from Prior Periods with Overdue Management Decisions
Report
Number
Report Title
Issue Date
Recommendation
Reason for Delay
Timetable for
Resolution
21-08
SBA’s Use of Vendors
Without a Contract
2/3/2021
Ratify the over $10.8 million in
payments in accordance with
the FAR and 48 C.F.R. § 1.602-3.
SBA verbally agreed
that ratification of
unauthorized
commitments was
necessary but has not
yet submitted a
proposed
management
decision.
12/31/2022
22-06
COVID-19 EIDL Program
Recipients on the
Department of Treasury's Do
Not Pay List
11/30/2021
Use Treasury’s DNP analysis to
systemically flag COVID-19 EIDL
and Emergency EIDL grant
recipients who were found in
Treasury’s DNP system and not
previously reported by OIG.
Review the applications and
determine whether they are
deemed ineligible. If the
applicant is deemed ineligible,
recover any disbursed funds,
and flag the application.
We are working with
the agency to
determine if recovery
actions are being
undertaken for
applications deemed
ineligible
12/31/2022
22-06
COVID-19 EIDL Program
Recipients on the
Department of Treasury's Do
Not Pay List
11/30/2021
For all COVID-19 EIDLs and
Emergency EIDL grants
identified and flagged as
potentially ineligible above,
include those transactions in
SBA’s 2021 improper payments
estimation process.
We are working with
the agency to
determine how
results of flagged
transactions are being
recorded with regard
to improper
payments.
12/31/2022
22-08
SBA’s Business Development
Assistance to 8(a) Program
Participants
2/14/2022
Implement a standard process
to approve initial business plans
and monitor to ensure that
business plans are reviewed
annually, to include appropriate
updates for specific targets,
objectives, and goals for the
business development of
program participants, in
accordance with 13 CFR
124.403(a) and section
7(j)(10)(D) of the Small Business
Act.
OIG met with
program officials and
reached verbal
agreement on
corrective actions
that would resolve
the
recommendations.
Program officials
submitted proposed
management decision
on 8/24/2022. OIG is
reviewing the
proposed actions.
10/30/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 27
22-08
SBA’s Business Development
Assistance to 8(a) Program
Participants
2/14/2022
Implement a standard process
to capture, track, and recognize
substantial achievement of the
specific targets, objectives, and
goals for the areas of finance,
marketing, and management on
8(a) program participant
business plans, in accordance
with 13 CFR 124.112(f) and
section 7(j)(10)(A) of the Small
Business Act.
OIG met with
program officials and
reached verbal
agreement on
corrective actions
that would resolve
the
recommendations.
Program officials
submitted proposed
management decision
on 8/24/2022. OIG is
reviewing the
proposed actions.
10/30/2022
22-08
SBA’s Business Development
Assistance to 8(a) Program
Participants
2/14/2022
Implement a process to ensure
the systematic collection of
accurate and complete data on
program results and operations
to make sure all program
reporting requirements are met,
in accordance with section
7(j)(16)(A) of the Small Business
Act and Standards for Internal
Control in the Federal
Government Principles for
Information and
Communication.
OIG met with
program officials and
reached verbal
agreement on
corrective actions
that would resolve
the
recommendations.
Program officials
submitted proposed
management decision
on 8/24/2022. OIG is
reviewing the
proposed actions.
10/30/2022
22-08
SBA’s Business Development
Assistance to 8(a) Program
Participants
2/14/2022
Implement requirements for
management to monitor that
Business Opportunity Specialists
consistently assess program
participant’s development
needs, counsel participants,
conduct annual field visits, and
maintain required
documentation, as required by
standard operating procedures.
OIG met with
program officials and
reached verbal
agreement on
corrective actions
that would resolve
the
recommendations.
Program officials
submitted proposed
management decision
on 8/24/2022. OIG is
reviewing the
proposed actions.
10/30/2022

U.S. Small Business Administration | Office of Inspector General
28 | Fall 2022 Semiannual Report to Congress
Reports from Prior Periods with Open Recommendations as of September
30, 2022
Report
Number
Title
Date Issued
Number of Open
Recommendations
Aggregate
Potential Cost
Savings (dollars)
18-03
Independent Auditor’s Report on the SBA’s FY
2017 Financial Statements
11/14/2017
1
—
18-13
Evaluation of SBA 7(a) Loans Made to Poultry
Farmers
3/6/2018
1
—
19-15
OIG High-Risk 7(a) Loan Review Program
7/10/20191
1
$3,000,297
19-16
Office of Inspector General High-Risk 7(a) Loan
Review Program
8/14/2019
1
1,367,417
19-17
Evaluation of SBA’s All Small Mentor-Protege
Program
9/17/2019
1
—
20-03
Audit of SBA's Oversight of High-Risk Lenders
11/12/2019
4
13,313,560
20-08
Audit of the SBA's Community Advantage Pilot
Program
3/18/2020
5
51,472,944
20-20
Audit of SBA’s Compliance with the Debt
Collection Improvement Act, as Amended
9/30/2020
10
—
21-02
Inspection of SBA’s Initial Disaster Assistance
Response to the Coronavirus Pandemic
10/28/2020
4
—
21-07
Inspection of SBA's Implementation of the
Paycheck Protection Program
1/14/2021
1
—
21-08
SBA’s Use of Vendors Without a Contract
2/3/2021
3
—
21-09
Duplicate Loans Made Under the Paycheck
Protection Program
3/15/2021
4
—
21-11
Evaluation of SBA’s Award Procedures for the
Coronavirus Aid, Relief, and Economic Security
Act Entrepreneurial Development Cooperative
Agreements
3/30/2021
2
—
21-14
Audit of SBA’s Oversight of Women’s Business
Centers’ Compliance with Cooperative
Agreement Financial Requirements
5/4/2021
8
785,961
21-15
SBA’s Handling of Identity Theft in the COVID-
19 Economic Injury Disaster Loan Program
5/6/2021
2
—
21-16
SBA’s FY 2020 Compliance with PIIA
5/12/2021
2
—
22-01
SBA's Emergency EIDL Grants to Sole
Proprietors and Independent Contractors
10/7/2021
1
4,500,000,000
22-04
Independent Auditors’ Report on SBA’s
Compliance with DATA Act Reporting
11/8/2021
1
—
22-05
Independent Auditors’ Report on SBA’s FY
2021 Financial Statements
11/15/2021
11
—
22-06
COVID-19 EIDL Program Recipients on the
Department of Treasury's Do Not Pay List
11/30/2021
2
—
22-07
SBA’s Oversight of the Grant Recipient’s
Implementation of the CARES Act Resource
Partners Training Portal
1/18/2022
5
—
22-08
SBA’s Business Development Assistance to 8(a)
Program Participants
2/14/2022
8
—
22-09
SBA’S Paycheck Protection Program Loan
Review Processes
2/28/2022
1
—
—
Total
—
79
$4,569,940,179

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 29
Significant Recommendations from Prior Reporting Periods without
Final Action as of September 30, 2022
Report
Number
Date Issued
Num
ber
Recommendation
Date of
Management
Decision
Final Action Target Date
18-03
11/14/2017
2
Monitor and perform procedures
over the service organization’s
attestation report regarding user
control considerations. This
assessment should be performed
annually.
1/10/2018
10/31/2022
18-13
3/6/2018
2
Review the arrangements between
integrators and growers under the
revised regulations, and establish
and implement controls, such as
supplemental guidance, to ensure
SBA loan specialists and lenders
make appropriate affiliation
determinations.
3/1/2018
03/15/2023
19-15
7/10/2019
1
Require the lender to bring the loan
into compliance or, if not possible,
seek recovery of $3,000,297 plus
interest on the guaranty paid by
SBA.
7/11/2019
05/27/2022
19-16
8/14/2019
1
Require the lender to bring the loan
into compliance or, if not possible,
seek recovery of $1,367,417 plus
interest on the guaranty paid by
SBA.
8/15/2019
10/31/2022
19-17
9/17/2019
3
Recommend that the Administrator
require the Associate Administrator
for the Office of Government
Contracting and Business
Development to prioritize staff
resources to ensure application
reviews and annual evaluations are
conducted in accordance with
regulatory and program
requirements.
2/4/2020
09/30/2022
19-17
9/17/2019
4
Ensure that certify.SBA.gov has the
functionality needed for program
officials to conduct application
reviews and annual evaluations.
9/17/2019
09/30/2022
20-03
11/12/2019
1
Develop and implement policies and
procedures to document OCRM's
justification for not conducting
planned reviews and identifying and
prioritizing additional lenders for
review.
11/15/2019
12/30/2022

U.S. Small Business Administration | Office of Inspector General
30 | Fall 2022 Semiannual Report to Congress
20-03
11/12/2019
2
Develop and implement a
comprehensive database to manage
its oversight of high-risk lenders to
ensure performance of all planned
reviews, implementation of risk
mitigation actions, and
identification of noncompliant
lender and systemic material loan
deficiencies.
11/15/2019
09/30/2023
20-03
11/12/2019
6
Determine whether the lenders
corrected the deficiencies on the 21
loans purchased for a total of $13.3
million. If not, require the lenders to
bring the loans into compliance or,
if not possible, seek recovery of the
guaranty paid by SBA from lenders.
11/15/2019
09/29/2022
20-08
3/18/2020
1
Evaluate options that facilitate the
Community Advantage (CA) pilot
program’s ability to effectively
expand access to capital in
underserved markets.
6/30/2020
09/30/2022
20-08
3/18/2020
2
Evaluate whether it is feasible to
align the maximum interest rates
charged under the CA pilot program
with comparable 7(a) program
rates, excluding SBA Express.
6/30/2020
09/30/2022
20-08
3/18/2020
4
Establish methods to assess
whether lenders have the expertise
needed to provide M&TA to
underserved borrowers and to
address any lender deficiencies
regarding M&TA.
6/30/2020
09/30/2022
20-08
3/18/2020
5
Require lenders to complete the
data fields related to the M&TA
provided and enhance the annual
CA performance analysis by
including the evaluation of the
performance associated with the
various types of M&TA.
6/30/2020
09/30/2022
20-08
3/18/2020
6
Establish a process to periodically
assess the performance of CA loans
approved with SBSS scores under
140, to determine whether the
recently implemented SBA approval
requirement is adequately
mitigating the risk of loss.
6/30/2020
06/30/2022
20-20
9/30/2020
1
Review all loans assigned to the
resolution center that are 180 days
or more delinquent and classified
with code 66 (Lien or
Mortgage/Refer to Treasury Offset
Program Only) and 00 (Clear
Existing Status Code) and transfer
the loans to Treasury Cross-
Servicing, unless verified as exempt
when the temporary suspension of
debt collection activities because of
the pandemic is lifted.
9/16/2020
12/15/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 31
20-20
9/30/2020
10
Perform a cost benefit analysis to
determine if SBA should begin
assessing fees to offset the cost of
processing and handling delinquent
disaster loans.
9/16/2020
12/15/2022
20-20
9/30/2020
2
Revise SOP 50 52 to clearly
communicate that all loans with
collateral must be evaluated for
foreclosure and placed in
foreclosure status before they are
180 days delinquent.
9/16/2020
12/15/2022
20-20
9/30/2020
3
Revise SOP 50 52 2 to clearly
communicate that all debts 180
days delinquent must be
transferred to Treasury Cross-
Servicing unless the debt meets a
valid transfer exemption.
9/16/2020
12/15/2022
20-20
9/30/2020
4
Establish requirements to provide
annual training on Debt Collection
Improvement Act requirements to
all staff of the resolution center.
9/16/2020
4/29/2022
20-20
9/30/2020
5
Ensure that information used to
monitor compliance with the Debt
Collection Improvement Act
includes all loans assigned to the
resolution center as identified in the
Capital Access Financial System.
9/16/2020
4/29/2022
20-20
9/30/2020
6
Review all loans currently assigned
to the Center and designated
exempt from Treasury Offset
Program and verify that each of the
obligors is exempt from referral to
Treasury Offset Program, and if not,
refer the obligors to Treasury Offset
Program, as required.
9/16/2020
12/15/2022
20-20
9/30/2020
7
Review all loans currently assigned
to the Center and designated as
exempt from Treasury Cross-
Servicing that are 180 days or more
delinquent and verify that each of
the obligors is exempt from transfer
to Treasury Cross-Servicing, and if
not, transfer the debt to Treasury
Cross-Servicing, as required when
the temporary suspension of debt
collection activities due to COVID-
19 is lifted.
9/16/2020
12/15/2022
20-20
9/30/2020
8
Establish policies and procedures to
require routine follow-up on
delinquent loans to ensure full
compliance with the Debt Collection
Improvement Act.
9/16/2020
4/29/2022
20-20
9/30/2020
9
Reiterate the requirements for
workout agreements to responsible
personnel to ensure compliance
with the Debt Collection
Improvement Act.
9/16/2020
12/15/2022

U.S. Small Business Administration | Office of Inspector General
32 | Fall 2022 Semiannual Report to Congress
21-02
10/28/2020
1
Review all loans that had a bank
account number changed from that
shown on the original application to
determine if the changes were
legitimate or fraudulent. If not
legitimate, work to recover the
funds, deobligate any undisbursed
funds, and refer to the OIG.
12/8/2020
12/30/2022
21-02
10/28/2020
3
Review duplicate loans to Internet
Protocol addresses, email
addresses, business addresses, and
bank accounts to determine if there
are undisbursed funds that should
be suspended until the duplicate
loans are assessed for eligibility.
12/8/2020
12/30/2022
21-02
10/28/2020
5
Strengthen or establish controls to
ensure multiple loans are provided
only to eligible applicants and
prevent the erroneous duplication
of loans.
12/8/2020
12/30/2022
21-02
10/28/2020
6
Strengthen data integrity to make it
possible to determine if the
inaccurate information allowed
loans to be made to ineligible
entities and to strengthen SBA’s
ability to service loans
appropriately.
12/8/2020
12/30/2022
21-07
1/14/2021
1
Review the loans identified as
potentially ineligible to determine if
the businesses met eligibility
requirements. If not, take
appropriate action related to loan
guaranty and forgiveness.
1/14/2021
9/30/2022
21-08
2/3/2021
1
Require responsible personnel to
execute a contract for foreclosure
and real estate services to ensure
the procurement of services are
obtained and authorized in
accordance with the Federal
Acquisition Regulation
requirements.
2/1/2021
04/30/2022
21-08
2/3/2021
2
Ensure that vendors used to provide
foreclosure and real estate services
are registered in SAM, as required.
2/1/2021
04/30/2022
21-08
2/3/2021
3
Ratify the over $10.8 million in
payments in accordance with the
FAR and 48C.F.R. § 1.602-3.
—
—
21-09
3/15/2021
1
Review the OIG identified potential
duplicate disbursements for
eligibility and take action to recover
any improper payments as
applicable.
3/31/2021
09/30/2022
21-09
3/15/2021
2
Review SBA controls related to all
PPP loan reviews to ensure that
duplicate loans are not forgiven and
not subject to an SBA guaranty, as
appropriate.
3/31/2021
09/30/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 33
21-09
3/15/2021
3
Strengthen E-Tran controls for
future PPP type programs, which
includes keeping E-Tran controls
that align with program
requirements on at all times.
3/23/2021
09/30/2022
21-09
3/15/2021
4
Review the issues that SBA
identified involving the actions of
lenders, such as providing
incorrectly formatted data and
submitting the same application
through multiple platforms and
determine how to strengthen
controls and guidance as
appropriate to ensure lenders meet
program requirements for future
PPP type programs.
3/23/2021
4/30/2022
21-11
3/30/2021
1
Enforce standard operating
procedures requiring clearly defined
performance goals and include
performance targets in all future
SBDC and WBC cooperative
agreements and grants to
objectively measure performance
results.
3/24/2021
11/30/2021
21-11
3/30/2021
2
Collect and analyze the CARES Act
entrepreneurial development
cooperative agreement recipient’s
performance results and establish a
framework for setting goals for
technical assistance programs in
response to future disasters. Retain
the analysis in program files for
future guidance.
03/24/2021
11/30/2021
21-14
05/04/2021
1
Implement financial oversight
procedures for the Women’s
Business Center (WBC) program
that ensure the program office
enforces WBC cooperative
agreement requirements. Program
officials should ensure WBCs use
federal funds only for allowable,
allocable, and reasonable expenses,
adhere to contract award
procedures, and separate project
costs by funding source.
05/04/2021
08/30/2022
21-14
05/04/2021
2
Remedy $523,790 in unsupported
matching funds, unsupported
program income, and the resulting
portion of the federal funds
reimbursed for the unmet match,
and $186,537 in unsupported
expenses.
05/04/2021
09/29/2024
21-14
05/04/2021
3
Recover $31,215 for improperly
awarded contracts and $31,424 in
unallowable or unallocable
expenses.
05/04/2021
09/29/2024

U.S. Small Business Administration | Office of Inspector General
34 | Fall 2022 Semiannual Report to Congress
21-14
05/04/2021
4
Implement policies and procedures
for conducting thorough financial
compliance reviews and coordinate
with the Office of Field Operations
to train field office personnel
responsible for semiannual site
visits
05/04/2021
08/31/2022
21-14
05/04/2021
5
Establish policies holding program
officials accountable for promptly
following up on financial
examination results and enforcing
cooperative agreement
requirements.
05/04/2021
08/31/2022
21-14
05/04/2021
6
Require higher-level reviewers to
clearly justify and document
approving or denying disbursement
of funds if the decisions differ from
the recommendations of lower-
level reviewers; justification
documentation should be kept in
the official cooperative agreement
file.
05/04/2021
12/31/2021
21-14
05/04/2021
7
Review expenses for the $28,089
reallocation of budget expenses we
detailed in this report to ensure
these costs are allowable and
document the rationale for the
reallocation or recover costs that
are unallowable.
05/04/2021
09/29/2024
21-14
05/04/2021
8
Require program officials to enforce
the cooperative agreement terms
and conditions and deobligate or
withhold payments if WBCs do not
submit accurate financial reports on
time.
05/04/2021
08/31/2022
21-15
05/06/2021
4
Develop a process to remove any
fraudulent loans and related
Uniform Commercial Code filing
fees from its financial records.
03/03/2022
06/30/2022
21-15
05/06/2021
5
Review over 150,000 returned
billing statements and resolve any
that involve identity theft, then
refer fraudulent loans to OIG.
03/03/2022
06/30/2022
21-16
05/12/2021
10
Collaborate with the Chief Financial
Officer to ensure a timely and
complete reconciliation is
performed on the population
subject to sampling for improper
payment reviews.
08/06/2021
11/01/2022
21-16
05/12/2021
11
Coordinate with the Office of
Disaster Assistance’s statistician to
ensure the estimated improper
payment amounts are calculated
consistently and the sampling
methodology adequately describes
the criteria for stratification.
08/06/2021
11/01/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 35
22-01
10/07/2021
1
Review the applications of sole
proprietors and independent
contractors that included numbers
of employees but no Employer
Identification Number; and remedy
the $3.5 billion disbursed to sole
proprietors and $1 billion disbursed
to independent contractors that
exceeded the amount allowed by
SBA’s policy.
10/04/2021
12/15/2022
22-04
11/8/2021
2
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Disaster
Assistance to enforce that
documentation is maintained to
evidence changes to a loan and
ensure that awarding actions are
entered into the source systems in a
timely manner.
09/01/2022
09/30/2023
22-05
11/15/2021
18
KPMG recommends the
Administrator coordinate with the
Associate Administrator of Capital
Access to continually evaluate the
established policy for Security
Operation Center 1 reports that
requires new service organizations
to provide a SOC 1 report over the
control environment that is relevant
and significant to the processing
and recording of SBA’s transactions.
If a SOC 1 report cannot be
obtained, identify, and evaluate
relevant controls at the service
organizations that have an impact
on SBA’s internal controls over
financial reporting.
01/10/2022
10/31/2022

U.S. Small Business Administration | Office of Inspector General
36 | Fall 2022 Semiannual Report to Congress
22-05
11/15/2021
19
KPMG recommends the
Administrator coordinate with the
Associate Administrator of Capital
Access to assess the risk posed by
the service organization’s control
environment and obtain sufficient
assurance over the operating
effectiveness of relevant and
significant controls to determine
the integrity of transactions
processed on behalf of and
recorded by SBA. If a SOC 1 report is
obtained for the relevant control
environment at the service
organization, determine and
document the following:
SOC 1 report is sufficiently scoped
to cover transaction processing and
related control activities performed
by the service organization on
behalf of SBA (e.g., that services,
business applications and other
information technology, service
organization departments and
locations, control objectives and
activities, and other aspects of
scope that are relevant to SBA’s
internal controls over financial
reporting are included in the scope
of SOC 1 reports).
All exceptions noted in the SOC 1
report – not just those described in
the independent service auditor’s
report – are evaluated to determine
applicability to SBA’s internal
controls over financial reporting,
the potential impact to SBA’s
financial statements, and mitigating
controls other considerations made
during their risk assessment.
All complementary user entity
controls described in the SOC 1
reports are evaluated using current
information and with consideration
to their applicability to SBA’s
internal controls over financial
reporting.
Evaluation procedures performed to
assess whether complementary
user entity controls and other SBA-
performed controls were tested and
found effective and, if they are not,
the impact of such deficiencies on
SBA’s internal controls over
financial reporting.
All complementary subservice
organization controls described in
SOC 1 reports are evaluated to
01/10/2022
10/31/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 37
determine whether they provided
services and performed controls
considered relevant to SBA’s
internal controls over financial
reporting and, if relevant subservice
organizations were identified, an
evaluation is performed to obtain
an understanding of the subservice
organization(s) and their controls.
SOC 1 reports cover the appropriate
period or corresponding gap letters
provide sufficient coverage to
assess impacts on SBA’s internal
controls over financial reporting.
Service Organizations Used for Loan
Guarantee Programs
Management did not obtain
reasonable assurance on the
operating effectiveness of internal
controls in multiple service
organizations’ control environments
relevant to the financial service
providers for the 7(a) and 504 loan
guarantee programs, and the PPP
and Restaurant Revitalization
program application intake
platform. With regards to the
financial service providers for the
7(a) and 504 loan guarantee
programs, the relevant control
environments include the
facilitation, maintenance, and
reporting of the account balances
for the respective secondary market
programs. With regards to the
application intake platform, the
relevant control environment
includes the operation of the PPP
loan forgiveness, PPP loan approval,
and Restaurant Revitalization
program modules, the data
transmissions over the internet
between the relevant modules and
SBA systems used in the configured
checks, the cloud-based
infrastructure hosting provider, and
the application controls within the
application intake platform.
In addition, management did not
provide evidence of adequate
monitoring activities performed
over the relevant internal control
environments at the respective
service organizations, such as
obtaining and reviewing an
attestation report on the design,
implementation, and operating
effectiveness of controls at the

U.S. Small Business Administration | Office of Inspector General
38 | Fall 2022 Semiannual Report to Congress
service organization. Management
also did not provide evidence
whether adequate user entity
controls were designed,
implemented, and operated
effectively to complement the
service organization’s controls.
22-05
11/15/2021
20
KPMG recommends the
Administrator coordinate with the
Associate Administrator of Capital
Access to continually evaluate the
established policy for SOC 1 reports
that requires new service
organizations to provide a SOC 1
report over the control
environment that is relevant and
significant to the processing and
recording of SBA’s transactions. If a
SOC 1 report cannot be obtained,
identify, and evaluate relevant
controls at the service organizations
that have an impact on SBA’s
internal controls over financial
reporting.
01/10/2022
10/31/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 39
22-05
11/15/2021
21
KPMG recommends the
Administrator coordinate with the
Associate Administrator of Capital
Access to assess the risk posed by
the service organization’s control
environment and obtain sufficient
assurance over the operating
effectiveness of relevant and
significant controls to determine
the integrity of transactions
processed on behalf of and
recorded by SBA. If a SOC 1 report is
obtained for the relevant control
environment at the service
organization, determine and
document the following:
SOC 1 report is sufficiently scoped
to cover transaction processing and
related control activities performed
by the service organization on
behalf of SBA (e.g., that services,
business applications and other
information technology, service
organization departments and
locations, control objectives and
activities, and other aspects of
scope that are relevant to SBA’s
internal controls over financial
reporting are included in the scope
of SOC 1 reports).
All exceptions noted in the SOC 1
report – not just those described in
the independent service auditor’s
report – are evaluated to determine
applicability to SBA’s internal
controls over financial reporting,
the potential impact to SBA’s
financial statements, and mitigating
controls other considerations made
during their risk assessment.
All complementary user entity
controls described in the SOC 1
reports are evaluated using current
information and with consideration
to their applicability to SBA’s
internal controls over financial
reporting.
Evaluation procedures performed to
assess whether complementary
user entity controls and other SBA-
performed controls were tested and
found effective and, if they are not,
the impact of such deficiencies on
SBA’s internal controls over
financial reporting.
All complementary subservice
organization controls described in
SOC 1 reports are evaluated to
01/10/2022
12/31/2021

U.S. Small Business Administration | Office of Inspector General
40 | Fall 2022 Semiannual Report to Congress
determine whether they provided
services and performed controls
considered relevant to SBA’s
internal controls over financial
reporting and, if relevant subservice
organizations were identified, an
evaluation is performed to obtain
an understanding of the subservice
organization(s) and their controls.
SOC 1 reports cover the appropriate
period or corresponding gap letters
provide sufficient coverage to
assess impacts on SBA’s internal
controls over financial reporting.
Service Organizations Used for Loan
Guarantee Programs
Management did not obtain
reasonable assurance on the
operating effectiveness of internal
controls in multiple service
organizations’ control environments
relevant to the financial service
providers for the 7(a) and 504 loan
guarantee programs, and the PPP
and Restaurant Revitalization
program application intake
platform. With regards to the
financial service providers for the
7(a) and 504 loan guarantee
programs, the relevant control
environments include the
facilitation, maintenance, and
reporting of the account balances
for the respective secondary market
programs. With regards to the
application intake platform, the
relevant control environment
includes the operation of the PPP
loan forgiveness, PPP loan approval,
and Restaurant Revitalization
program modules, the data
transmissions over the internet
between the relevant modules and
SBA systems used in the configured
checks, the cloud-based
infrastructure hosting provider, and
the application controls within the
application intake platform.
In addition, management did not
provide evidence of adequate
monitoring activities performed
over the relevant internal control
environments at the respective
service organizations, such as
obtaining and reviewing an
attestation report on the design,
implementation, and operating
effectiveness of controls at the

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 41
service organization. Management
also did not provide evidence
whether adequate user entity
controls were designed,
implemented, and operated
effectively to complement the
service organization’s controls.
22-05
11/15/2021
24
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Disaster
Assistance to design and implement
effective monitoring controls, to
ensure that SVOG award recipients
are complying with the program’s
terms and to ensure complete,
accurate, and timely reporting for
the use of the award.
01/10/2022
10/07/2022
22-05
11/15/2021
32
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to consider allocating
resources to implement
enforcement processes that ensure
the accounts of separated users are
removed timely from SBA systems.
01/10/2022
09/30/2022
22-05
11/15/2021
33
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to validate that the
identified accounts of separated
users were not utilized after
separation had occurred.
01/10/2022
06/30/2022
22-05
11/15/2021
34
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to ensure suspects
responsible for removing accounts
of separated users are aware of the
process and periodically sent
reminders of their responsibilities.
01/10/2022
08/30/2022
22-05
11/15/2021
35
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to implement controls and a
monitoring process to ensure that
patches applied to the database and
operating system and application
changes are appropriately tested
prior to being moved into the
production environment.
01/10/2022
09/30/2002

U.S. Small Business Administration | Office of Inspector General
42 | Fall 2022 Semiannual Report to Congress
22-05
11/15/2021
36
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to update the system
configuration management plan to
require internal control
documentation for patch
management and application
changes as required by the
Government Accountability Office’s
Standards for Internal Control in the
Federal Government.
01/10/2022
09/30/2002
22-05
11/15/2021
37
KPMG recommends the
Administrator coordinate with the
Associate Administrator for Capital
Access to periodically train
personnel involved with the
implementation of database and
operating system patches, and the
review and approval of application
changes, to follow the respective
controls and requirements of the
patch management and application
change management processes in
accordance with existing policies.
01/10/2022
09/30/2002
22-06
11/30/2021
2
Use Treasury’s DNP analysis to
systemically flag COVID-19 EIDL and
Emergency EIDL grant recipients
who were found in Treasury’s DNP
system and not previously reported
by OIG. Review the applications and
determine whether they are
deemed ineligible. If the applicant is
deemed ineligible, recover any
disbursed funds, and flag the
application as ineligible
—
—
22-06
11/30/2021
3
For all COVID-19 EIDLs and
Emergency EIDL grants identified
and flagged as potentially ineligible
above, include those transactions in
SBA’s 2021 improper payments
estimation process.
—
—
22-07
01/18/2022
1
Require the grant recipient to
enhance its marketing and outreach
strategy to include plans to reach a
greater number of small businesses
and resource-partner counselors
and mentors. The grant recipient
should also set clear performance
goals with realistic targets before
SBA awards any additional funds for
the COVID-19 resource and training
portal, as required by CARES Act
Section 1103(c)(2).
01/18/2022
06/30/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 43
22-07
01/18/2022
2
Implement procedures for
enhanced financial oversight of the
CARES Act Resource Partner
Training Portal program to ensure
the program office enforces the
grant requirements and follows
federal procurement standards
when using noncompetitive
contracting options. The
requirements include a price or cost
analysis for awards that exceed the
simplified acquisition threshold.
Another requirement ensures the
grant recipient adheres to the terms
in the Notice of Award.
01/18/2022
06/30/2022
22-07
01/18/2022
3
Evaluate whether the contract costs
for web development services and
media services are reasonable and
remedy any violations.
01/18/2022
06/30/2022
22-07
01/18/2022
4
Assess and recover the amount
spent on the unallowable
contracted project management
services expenses incurred during
the performance of the grant
04/01/2022
08/01/2022
22-08
02/14/2022
1
Implement a standard process to
approve initial business plans and
monitor to ensure that business
plans are reviewed annually, to
include appropriate updates for
specific targets, objectives, and
goals for the business development
of program participants, in
accordance with 13 CFR 124.403(a)
and section 7(j)(10)(D) of the Small
Business Act.
—
—
22-08
02/14/2022
2
Implement a standard process to
capture, track, and recognize
substantial achievement of the
specific targets, objectives, and
goals for the areas of finance,
marketing, and management on
8(a) program participant business
plans, in accordance with 13 CFR
124.112(f) and section 7(j)(10)(A) of
the Small Business Act.
—
—

U.S. Small Business Administration | Office of Inspector General
44 | Fall 2022 Semiannual Report to Congress
22-08
02/14/2022
4
Implement a process that uses
outcome-based performance goals
for regular data-driven reviews and
align program leaders’ personal
performance plans with the goals so
program office leaders are held
accountable for improving program
data quality, identifying effective
practices, and validating promising
initiatives, that aligns with OMB
Circular A-11 Part 6 – The Federal
Performance Framework for
Improving Program and Service
Delivery guidance.
05/27/2022
06/03/2022
22-08
02/14/2022
5
Implement a process to ensure the
systematic collection of accurate
and complete data on program
results and operations to make sure
all program reporting requirements
are met, in accordance with section
7(j)(16)(A) of the Small Business Act
and Standards for Internal Control
in the Federal Government
Principles for Information and
Communication.
—
—
22-08
02/14/2022
6
Implement requirements for
management to monitor that
Business Opportunity Specialists
consistently assess program
participant’s development needs,
counsel participants, conduct
annual field visits, and maintain
required documentation, as
required by standard operating
procedures.
—
—
22-08
02/14/2022
7
Ensure all employees performing
Business Opportunity Specialist
duties maintain a current Federal
Acquisition Certification in
Contracting Level 1 Certification
within a year of appointment in
accordance with section 4(g) of the
Small Business Act.
02/14/2022
12/01/2022
22-08
02/14/2022
8
Use lessons learned from servicing
8(a) firms in an entirely virtual
environment to coordinate district
office resources and share best
practices in order to equitably serve
all 8(a) program participants. Align
assigned Business Opportunity
Specialist staffing levels accordingly
to be consistent with ideal workload
ratios as determined by the
program office.
02/14/2022
12/01/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 45
Significant Recommendations from this Reporting Period
Report
Number
Title
Date Issued
Recommendation
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Implement procedures to ensure contracting officers use effective
proposal analysis techniques to determine prices are fair and reasonable
in accordance with FAR 15.404.
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Implement procedures to require contracting officers to assess
compliance with size requirements when small businesses propose
using subcontractors to perform significant work requirements.
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Request a formal size determination in accordance with FAR 19.302 to
evaluate whether the loan processing contractor exceeded the size
standard and remedy any violation in accordance with 15 U.S.C. 645(d).
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Implement procedures to assess prospective firms’ ability to comply
with subcontracting limitations prior to contract award.
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Implement procedures to monitor post-award compliance with
subcontracting limitations.
22-10
SBA’s Contract
Disaster for
Assistance Loan
Recommendation
Services
4/14/2022
Before exercising options or awarding additional task orders against the
contract, assess alternative contracting actions, such as pursuing
another contract using competitive procedures to ensure fair and
reasonable prices. SBA should then document the determination in the
award file.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Design and implement a quality assurance program to ensure that SBA
system software inventory and contractor managed systems are
maintained, as required by the National Institute of Standards and
Technology (NIST) Special Publication 800-53.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Ensure the continuity of operations plan is tested annually, as required
by Federal Continuity Directive 1.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Implement an agency-wide policy for the management of supply-chain
risks associated with the development, acquisition, maintenance, and
disposal of systems, system components, and system services. This
policy should address key controls outlined in NIST 800-53, such as the
procurement of third-party services, high-value asset identification, and
counterfeit component prevention.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Ensure timelines are incorporated into policies requiring baseline scan
vulnerabilities be remediated in a timely manner. Also, ensure these
vulnerabilities are tracked appropriately through the Plan of Action and
Milestones process as required by NIST 800-53.

U.S. Small Business Administration | Office of Inspector General
46 | Fall 2022 Semiannual Report to Congress
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Ensure systems under control undergo vulnerability scans and address
identified vulnerabilities as part of the patch management process, as
required by SOP 90 47 5.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Communicate and reinforce to program offices required system owner
responsibilities to approve, establish, activate, modify, review, disable,
and remove accounts in accordance with SOP 90 47 5.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Require audit logging of administrator activity so an independent
reviewer can monitor and mitigate risks, as required by SOP 90 47 5.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Establish warning banners for systems that lack them to communicate
user responsibilities and prevent unauthorized disclosure, as required by
SOP 90 47 5.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Perform periodic reviews of users with administrator privileges to
ensure risk designation of their position aligns with their duties, as
required by SOP 90 47 5.
22-11
Fiscal Year 2021
Federal Information
Security
Modernization Act
Review
4/28/2022
Create a business impact analysis incorporating all elements SOP 90 47 5
requires.
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Enhance existing procedures using the framework in GAO’s Standards
for Internal Control in the Federal Government (Green Book) to design
and implement robust internal and quality control processes to ensure
complete and accurate reporting of annual improper payment results,
formalized risk assessment processes to ensure all programs are
considered, and to ensure the sampling methodology documentation is
consistent and updated annually with the population, sample results,
and information in the payment integrity section of the AFR and
accompanying materials.
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Provide training to responsible staff involved in the payment integrity
reporting process regarding the updates to existing procedures.
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Ensure that there are adequate quality control reviews over improper
payment disclosures in the AFR and the accompanying materials.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 47
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Continue to provide training and collaborate with program office staff,
as needed, to ensure the timely and complete reconciliation of the
population of transactions used for estimating improper payments to
the general ledger is performed.
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Formally document and implement additional preventative and
monitoring controls to determine the eligibility of borrowers prior to
approval and disbursement of loans.
22-12
Independent
Auditors’ Report on
SBA’s Fiscal Year
2021 Compliance
with the Payment
Integrity
Information Act of
2019
5/17/2022
Ensure that the sampling and estimation methodology plan and results
are updated and adequately describe the criteria for stratification of the
population by disaster size, including how it was determined and
whether it was consistently applied.
22-13
SBA’s Handling of
Potentially
Fraudulent
Paycheck
Protection Program
Loans
5/26/2022
Establish clearly defined and detailed roles, responsibilities, and
processes for all SBA offices and officials responsible for managing and
handling potentially fraudulent PPP loans to reduce the risk of ineligible
applicants receiving PPP forgiveness and the risk of fraud and financial
loss in the PPP and when implementing similar future programs.
22-13
SBA’s Handling of
Potentially
Fraudulent
Paycheck
Protection Program
Loans
5/26/2022
Provide lenders formal guidance to effectively and consistently handle
potentially fraudulent PPP loans and ensure lenders have sufficient
guidance when implementing similar future programs.
22-14
SBA's Controls Over
Cash Contributions
and Gifts, Fiscal
Years 2022 and
2021
6/15/2022
Enhance the tracking system to include alerts to ensure the responsible
program official timely coordinates with the fiscal agent to receive the
final accounting report and uses the report to close out all cosponsored
activities within 90 days, as required by SOP 90 75 5. In the event the
fiscal agent receives cash contributions or pays expenses after
submitting their final report to the responsible program official, the
fiscal agent should amend their accounting report and submit their
report to the responsible program official to amend the report and
update the SBA Form 2299.
22-14
SBA's Controls Over
Cash Contributions
and Gifts, Fiscal
Years 2022 and
2021
6/15/2022
Implement quality control procedures to ensure that required fiscal
agent and SBA documents for future National Small Business Week
cosponsored activities are timely, complete, accurate, and can be relied
on.
22-15
SBA's Award and
Payment Practices
in the Shuttered
Venue Operators
Grant Program
7/5/2022
Establish procedures to use a risk-based approach for disbursing award
funds for future disaster grant programs.

U.S. Small Business Administration | Office of Inspector General
48 | Fall 2022 Semiannual Report to Congress
22-15
SBA's Award and
Payment Practices
in the Shuttered
Venue Operators
Grant Program
7/5/2022
Ensure all SVOG program notices of award are signed by an authorized
government official and remedy awards that were not entered into by
an authorized government official.
22-15
SBA's Award and
Payment Practices
in the Shuttered
Venue Operators
Grant Program
7/5/2022
Require the reconciliation of the grant recipient’s budget to the final
award amount prior to awarding a grant, including ensuring receipt of
revised budgets, when changes are needed, prior to disbursing grant
awards. Furthermore, discontinue the disbursement of grant awards
prior to the receipt of a revised budget.
22-15
SBA's Award and
Payment Practices
in the Shuttered
Venue Operators
Grant Program
7/5/2022
Reassess SBA’s flexibility in allowing waivers for budget changes
between line items or implement monitoring procedures to mitigate
risks of recipients using funds for unallowable expenses during the grant
performance period.
22-17
COVID-19 Economic
Injury Disaster Loan
Applications
Submitted from
Foreign IP
Addresses
9/12/2022
Thoroughly review each COVID-19 EIDL, grant, and advance application
submitted from foreign IP addresses that were approved and funded
and verify eligibility. If ineligibility or evidence of potential fraud is
found, SBA should stop any further or future disbursements, recover
any disbursed funds, and refer fraudulent loans to OIG for investigation.
22-17
COVID-19 Economic
Injury Disaster Loan
Applications
Submitted from
Foreign IP
Addresses
9/12/2022
Examine controls related to foreign IP addresses and ensure these
controls are more effective in future disaster processing systems.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Ensure the existing SBA System Development Methodology is updated
to include supply chain risk-management practices as required by OMB
Circular A-130 and high-value asset system designation guidance. Also,
ensure high-value asset system risks are incorporated into the
enterprise risk management framework, as recommended by OMB M-
19-03 and SBA SOP 90 47 6.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Communicate and enforce the SBA System Development Methodology
in which a traceability matrix is used to ensure that system
requirements can be tested and demonstrated in the operational
system. Ensure all requirements are aligned with the contractual
acceptance criteria.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Implement in updated agency guidance, the requirements of OMB
Circular No. A-123 that stipulate a SOC 1 Type 2 report is needed for all
new and existing financial systems. This guidance should also require
confirmation at least annually that the controls are functioning as
designed.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Enforce the requirement to establish and implement internal controls to
ensure appropriate program officials perform and document contract
reviews to ensure that information security is appropriately addressed
in the contracting language, as required by OMB Circular A-130 and SBA
SOP 90 47 6.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
In conjunction with the Enterprise Risk Management Board, implement
enterprise-wide privacy risk mitigation practices that can be assimilated
into new and existing system program designs.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Complete an initial assessment and authorization for each information
system and all agency-designated common controls before operation.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 49
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Transition information systems and common controls to an ongoing
authorization process (when eligible for such a process) with the formal
approval of the respective authorizing officials or reauthorize
information systems and common controls as needed, on a time or
event-driven basis in accordance with agency risk tolerance, as required
by OMB Circular No. A-130 and SOP 90 47 6.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Review and update POA&Ms at least quarterly as required by
SOP 90 47 6.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Ensure data-sharing agreements are reviewed annually as required by
SBA SOP 90 47 6.
22-19
COVID-19 and
Disaster Assistance
Information
Systems Security
Controls
9/27/2022
Implement an automated process to document and monitor system
changes as recommended by NIST SP 800-53 Rev. 5.
22-20
SBA’s
Implementation of
the Women-Owned
Small Business
Certification
Program
9/29/2022
Update application instructions and require WOSB applicants to submit
documentation for program officials to verify the business meets small
business size standards.
22-20
SBA’s
Implementation of
the Women-Owned
Small Business
Certification
Program
9/29/2022
Assess the technological resources, staffing levels, and service contracts
needed to reduce application wait time and ensure application reviews
are conducted in a prompt manner in accordance with regulatory
requirements in 13 CFR 127.300. Use the results of the assessment to
improve processing times.
22-20
SBA’s
Implementation of
the Women-Owned
Small Business
Certification
Program
9/29/2022
Develop standard operating procedures to ensure program officials
assess third-party certifications, establish a risk-based sampling plan for
selecting files to review, and document the results of the compliance
reviews.
22-21
Paycheck
Protection Program
Eligibility for
Nonprofit
Organizations
9/26/2022
Review the 179 PPP loans, totaling approximately $684 million, for
compliance with affiliation and size standards to ensure eligibility
requirements were met and seek remedy or repayment for all loans
deemed ineligible.
22-21
Paycheck
Protection Program
Eligibility for
Nonprofit
Organizations
9/26/2022
Seek remedy or repayment of a PPP loan in the amount of $3.5 million.
22-22
Follow-up
Inspection of SBA’s
Internal Controls to
Prevent COVID-19
EIDLs to Ineligible
Applicants
9/29/2022
Review the 20 loans identified in this report as ineligible for the COVID-
19 EIDL that the applicants received and recover approximately $2
million improperly disbursed to the applicants.

U.S. Small Business Administration | Office of Inspector General
50 | Fall 2022 Semiannual Report to Congress
22-22
Follow-up
Inspection of SBA’s
Internal Controls to
Prevent COVID-19
EIDLs to Ineligible
Applicants
9/29/2022
Review the COVID-19 EIDL disbursements with suspect Taxpayer
Identification Numbers made after December 27, 2020 to determine if
the loan file contains conclusive evidence that the applicant business
existed on January 31, 2020, and therefore, met the CARES Act eligibility
requirements. If not, flag the borrower as ineligible and recover the
funds.
22-25
SBA's Guaranty
Purchases for PPP
Loans
9/30/2022
Stay the April 27, 2022 decision to end collections on purchased PPP
loans with an outstanding balance of $100,000 or less until a
comprehensive cost benefit analysis is conducted.
22-25
SBA's Guaranty
Purchases for PPP
Loans
9/30/2022
Explore alternative means of collections for PPP loans with an
outstanding balance of $100,000 or less.
22-25
SBA's Guaranty
Purchases for PPP
Loans
9/30/2022
Conduct an initial and periodic cost benefit analysis on PPP purchase
guarantees with comprehensive estimates to sufficiently assess whether
the cost of collecting loans of $100,000 or less is more than the recovery
amount and pursue collections based on results of the analysis.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 51
Significant Management Decisions – OIG Disagreement
There was one significant management decision OIG disagreed with during this reporting period
regarding SBA’s Guaranty Purchases for Paycheck Protection Program Loans (Report 22-25), September
30, 2022.
Summary: OIG issued this management advisory to express concerns regarding SBA’s decision to end
collections on purchased PPP loans with an outstanding balance of $100,000 or less. We began reviewing
SBA’s process for approving PPP guaranty purchases in anticipation of the significant number of
delinquent PPP loans that lenders will be submitting for guaranty purchase. A guaranty purchase is
defined as SBA’s purchase of the guaranteed portion of a loan. During the review, we learned of SBA’s
decision to end collections on these loans and found that expedited management action was needed to
determine whether it is cost effective to pursue collections on these loans. We believe management
attention is needed to ensure effective stewardship of billions of dollars in potential funds owed to
taxpayers. Further, ending collections could incentivize ineligible borrowers to obtain loans valued at
$100,000 or less in similar future loan programs. We made three recommendations. Management
disagreed with recommendations 1 and 2 and agreed with recommendation 3. The following is a
summary of the recommendations with which SBA management disagreed.
Recommendation 1: We recommended the Administrator stay the April 27, 2022 decision to end
collections on purchased PPP loans with an outstanding balance of $100,000 or less until a
comprehensive cost benefit analysis is conducted.
SBA managers disagreed, stating their decision to end collection on these loans complied with the Debt
Collection Improvement Act, that it does not require the agency to conduct a comprehensive cost benefit
analysis. It only requires that the agency demonstrate "the cost of collecting the claim is likely to be more
than the amount recovered," which SBA stated they have completed.
Although SBA provided documentation of its analysis to show it complied with the Act requirement that
the costs of collecting the claim is likely to be more than the amount recovered, OIG believes the analysis
was not comprehensive and did not sufficiently support SBA’s conclusion that the costs to collect would
exceed recoveries for PPP.
Notwithstanding, we closed this recommendation because SBA agreed with OIG recommendation 3 to
conduct an initial and periodic cost benefit analysis on PPP purchase guarantees with comprehensive
estimates to sufficiently assess whether the cost of collecting loans of $100,000 or less is more than the
recovery amount and pursue collections based on results of the analysis. In the interim, absent a
comprehensive cost benefit analysis, there is risk that key factors affecting costs and recovery amounts
may be missing in SBA’s assessment.
Recommendation 2: We recommended the Administrator explore alternative means of collections for
PPP loans with an outstanding balance of $100,000 or less.
Management disagreed, stating that alternative means of enforced collection would not be cost effective
due to the lack of collateral and personal guaranties. However, management did not provide supporting
evidence for its conclusion. In accordance with our audit follow-up policy, we will attempt to reach
agreement with management on this unresolved recommendation. If agreement is not reached, we will
elevate the disputed issue to the designated audit follow-up official.

U.S. Small Business Administration | Office of Inspector General
52 | Fall 2022 Semiannual Report to Congress
Significant Revised Management Decisions
There were no significant revised management decisions during this reporting period.
Federal Financial Management Improvement Act
The OIG’s Independent Public Accountant, KPMG, did not render an opinion on the compliance with the
Federal Financial Management Improvement Act, but their test work in the FY 2021 financial statement
disclosed instances in which SBA’s financial management systems did not substantially comply with
federal financial management systems requirements and applicable federal accounting standards. The
results disclosed no instances in which SBA’s financial management systems did not substantially comply
with the United States Standard General Ledger at the transaction level.
Instances of Interference
There were no attempts by SBA officials to interfere with OIG independence during the reporting period.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 53
Appendix D. Investigations Reporting Statistics
Investigative Reports Issued
Report Type
Number of Reports
Report of Investigation
95
Preliminary Case Closing Reports of Investigation
—
Total
95
Persons Referred for Prosecution
Referred To
Number of Persons
Department of Justice
113
State Attorney
0
Local Attorney
1
Total
114*
*Number includes persons and entities referred for prosecution
Pandemic-Related Investigative Statistics
SBA OIG
Investigations
Indict/Complaint
Arrests
Convictions
PPP/EIDL/SV/RFF*
203
123
119
93
Investment Fraud
6
18
10
7
Total
209
141
129
100
*PPP stands for Paycheck Protection Program. EIDL stands for Economic Injury Disaster Loan. RFF stands for Restaurant
Revitalization Fund
Whistleblower Retaliation Cases
There were no OIG investigations involving whistleblower retaliation during the reporting period.
Investigations Involving a Senior Government Employee Where
Misconduct Was Substantiated
There was one OIG investigation involving a senior government employee where misconduct was
substantiated during the reporting period. We investigated and substantiated an allegation that a Deputy
District Director violated ethical standards by utilizing their position in SBA to influence the Economic
Injury Disaster Loan (EIDL) application process for a law firm. On February 9, 2022, this matter was
presented to the Offices of the U.S. Attorneys, Southern District of Florida, for prosecution, where it was
declined in lieu of available administrative remedies. OIG referred the matter to SBA managers for their
determination as to the relevance of OIG’s findings. OIG is pending SBA management response.
Investigations Involving a Senior Government Employee That Is Closed
and Not Disclosed to the Public
There were no OIG investigations that are closed and not disclosed to the public involving a senior
government employee during this reporting period.

U.S. Small Business Administration | Office of Inspector General
54 | Fall 2022 Semiannual Report to Congress
Appendix E. Legal Actions Summary
April 1, 2022 – September 30, 2022
State
Program
Jointly
with
Alleged Violation(s) Prosecuted
Legal Action
OH
BL
FHFA/OIG, FBI,
IRS/CI, FRB/OIG
As part of the scheme, suspects conspired to
submit over 34 fraudulent loan applications and
obtained over $15 million in CARES Act funds.
Suspects purchased luxury homes, diamonds,
jewelry, and cryptocurrency.
Suspect 1 was sentenced to
120 months incarceration
and 3 years of supervised
release. Suspect 2 was
sentenced to 78 months
incarceration and 3 years
supervised release. Suspect 3
was sentenced to 24 months
incarceration and 2 years
supervised release. Suspect 4
was sentenced 3 years
supervised release. Suspects
were ordered to pay $21.9
million in restitution.
OR
BL/DL
FBI, TIGTA
Suspect defrauded SBA and financial institutions
for over $900,000 in loans through the PPP and
EIDL programs. Suspect misused proceeds for
personal use such as gambling, vacations, and
the purchase of illegal narcotics.
Suspect was sentenced to 21
months incarceration, 5
years of supervised release,
and ordered to pay $910,733
in restitution.
CA
BL/DL
FRB/OIG, IRS/CI,
TIGTA
As part of the scheme, subject submitted six
fraudulent PPP loan applications to two banks
on behalf of four companies. Subject
successfully obtained over $1.5 million in
fraudulent funds. Subject submitted falsified
bank records, phony lease agreements, altered
incorporation records, fake IRS records and
bogus employee information.
Subject was sentenced to 30
months incarceration, 3
years of supervised release,
and ordered to pay $1.5
million in restitution.
MD
BL
FDIC/OIG, FBI,
IRS/CI
Suspect made material misrepresentations to a
financial institution to gain approval for PPP
loans and obtained over $300,000. Suspect
purchased a luxury car, furniture, and other
personal items.
Suspect was sentenced to 6
months incarceration, 3
years of supervised release,
and ordered to pay $305,854
in restitution.
TN
DL
IRS/CI, TIGTA
Suspects defrauded and conspired to submit
over 400 EIDL loans securing over $1.1 million
by using false payroll information and providing
materially false information on loan
applications.
Suspect 1 was sentenced to
time served and 1 year of
supervised release. Suspect 2
was sentenced to 18 months
incarceration and 2 years of
supervised release. Suspect 3
was sentenced to 24 months
incarceration and 2 years of
supervised release. Suspects
were ordered to pay $38,900
in restitution and a $10,000
fine.
MN
BL
FBI, FDIC/OIG,
IRS/CI
Subject made false statement in the attempt to
obtain multiple PPP loans totaling over $1
million. Subject made several false statements
and manipulated bank statements within the
application.
Subject was sentenced to 81
months incarceration, 3
years of supervised release,
and ordered to pay $23,491
in restitution.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 55
ID
GC
DCIS, GSA/OIG
Suspect participated in a fraud scheme and
conspired in obtaining over $11 million in
government contracts for a set-aside service-
disabled veteran-owned small business. Suspect
falsified the designation to obtain the contract.
Suspect was sentenced to 14
months incarceration, 3
years supervised release, and
ordered to pay $480,039 in
restitution, and a $7,500
fine.
SC
GC
DCIS, USDA,
AFOSI
Suspect created fictitious certifications, which
were submitted to SBA to remain in the 8(a)
program. Suspect received over $85 million in
contracts, primarily from the US Air Force.
Suspect was sentenced to 12
months’ probation.
WA
GC
DCIS, Army/CID,
AFOSI, DHS/HSI,
DOJ/OIG,
GSA/OIG
Suspect falsely represented as a government
employee/contracting officer, and sub-
contracted several jobs awarded to their
company (who was previously debarred).
Suspect forged a US Navy contracting officer’s
signature and filed false and fictitious US Army
contracts in which he could claim compensation
for payment of work that was in fact completed
by the sub-contractors.
Suspect was sentenced to 40
months in incarceration and
3 years of supervised
release.
AL
BL
TIGTA, DHS/HSI
Suspects made multiple false statements and
obtained over 10 PPP loans over $500,000.
Suspect 1 was sentenced to
9 months incarceration and 3
years supervised release.
Suspect 2 was sentenced to
time served and 3 years of
probation. Suspect 3 was
sentenced to time served
and 3 years of probation.
Suspects were ordered to
pay $23,332 in restitution.
FL
DL
FBI, USSS
Subject submitted 13 EIDL applications to SBA
seeking over $100,000 in COVID-19 relief funds.
Subject was sentenced to 2
months incarceration, 18
months supervised release,
and was ordered to pay
$115,063 in restitution.
MA
BL/DL
IRS/CI
Subject devised a scheme and applied for over
$2 million in PPP loans through SBA-approved
lenders. Subject misrepresented the number of
employees and payroll expenses.
Subject was sentenced to 39
months incarceration, 3
years supervised release, and
was ordered to pay $2
million dollars in restitution.
OK
BL
FRB/OIG
Suspect made false assertions and certifications
concerning PPP loans totaling $5.4 million.
Suspect was sentenced to 48
months of confinement, 5
months of supervised
released, and ordered to pay
$150,000 in restitution.
NH
GC
VA/OIG, FBI
Suspect participated in a fraud scheme with the
SBA-guaranteed loan program by providing
false information to the banks about his
businesses and personal income.
Suspect was sentenced to 48
months incarceration, 2
years of supervised release,
and ordered to pay $2.4
million in restitution
OR
BL
TIGTA, FBI
Subject submitted false information about his
employment as an independent contractor and
revenue.
Subject was sentenced to 18
months’ probation and was
ordered to pay $18,750 in
restitution.

U.S. Small Business Administration | Office of Inspector General
56 | Fall 2022 Semiannual Report to Congress
FL
BL
FBI, FDIC/OIG,
USSS, SSA/OIG,
USPIS
Subjects conspired with others to defraud
various financial institutions by creating over
700 bank accounts and shell companies with
stolen and synthetic identities. The defendant
and co-conspirators filed hundreds of
fraudulent PPP loan applications totaling over
$11 million dollars for a fee on behalf of other
suspects.
Subject 1 was sentenced to
60 months incarceration and
3 years of supervised
release. Subject 2 was
sentenced to 12 months
incarceration and 3 years
supervisor release. Subjects
were ordered to pay $11.3
million in restitution.
FL
BL
FBI, FDIC/OIG
Suspects submitted multiple fraudulent PPP
loan applications totaling over $300,000,
including falsified supporting documentation,
for companies they owned and/or controlled.
Suspect 1 was sentenced to
60 months of incarceration,
2 years supervised release,
and ordered to pay $136,285
in restitution. Suspect 2 was
sentenced to 30 months of
incarceration, 2 years
supervised release, and
ordered to pay $135,285 in
restitution.
FL
BL
IRS/CI, USSS
Suspect submitted false and fraudulent PPP
applications and received over $700,000.
Suspect was sentenced to 27
months incarceration, 3
years of supervised release,
and ordered to pay $730,585
in restitution.
AR
BL
FBI, DOL/OIG
Suspect made false assertions and certifications
concerning PPP loans and PUA benefits totaling
over $500,000.
Suspect was sentenced to 27
months incarceration, 5
years supervised release, and
ordered to pay $469,082 in
restitution.
MN
DL
USPIS
Suspect participated in a fraud scheme and
conspired to obtain EIDL funds and over 15
state unemployment benefits using stolen
identities.
Suspect was sentenced to 78
months in incarceration, 3
months supervised release,
and was ordered to pay
$284,355 in restitution.
MI
DL
FBI
Suspect used a position within SBA to access the
SBA database to retrieve Personally Identifiable
Information to apply for EIDLs. Suspect used the
information to secure funds then spent on
lavish personal purchases such as a Land Rover.
Suspect was sentenced to 75
months incarceration, 3
years supervised release, and
ordered to pay $18,606 in
restitution.
NY
BL/DL
FBI, IRS/CI
Suspect made material misrepresentations to a
financial institution and filed 15 fraudulent loan
applications seeking more than $13 million
dollars in forgivable loans through the PPP
under the CARES Act.
Suspect was sentenced to 24
months incarceration, 3
years of supervised release,
and ordered to pay over $1.3
million in restitution.
GA
DL
FBI
Subject submitted fraudulent EIDL applications
and obtained over $300,000 in CARES Act funds.
Subject was sentenced to 18
months incarceration, 1 year
of supervised release, and
ordered to pay $319,000 in
restitution.
GA
BL
IRS/CI
Subject made multiple false statements and
attempted to obtain multiple PPP loans over
$500,000.
Subject was sentenced to 24
months incarceration, 3
years of supervised release,
and ordered to pay $507,800
in restitution.
GA
DL
FBI, TIGTA, USSS
Subject made multiple false statements and
attempted to obtain 184 fraudulent EIDL loans
over $2.5 million.
Subject was sentenced to
480 months in incarceration
for violation of the RICO.

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 57
CA
BL
IRS/CI
Subject conspired to submit over three
fraudulent loan applications and obtained over
$940,000 in CARES Act funds.
Subject was sentenced to 41
months incarceration, 5
years of supervised release,
and ordered to pay $306,415
in restitution.
CA
BL
FBI, FDIC/OIG,
TIGTA
Subject submitted false and fraudulent PPP
applications and received over $3 million in loan
proceeds.
Subject was sentenced to
135 months incarceration, 5
years of supervised release,
and ordered to pay $3
million in restitution.
FL
BL
FBI, FHFA/OIG
Suspect submitted false and fraudulent PPP
applications and received over $100,000 in loan
proceeds.
Suspect was sentenced to 24
months incarceration, 3
years of supervised release,
and ordered to pay $121,659
in restitution.
CO
BL
TIGTA
Suspect defrauded the government of over $1
million in PPP funds by providing materially
false representation of 10 shell companies.
Suspect was sentenced to 19
months incarceration, 3
years of supervised release,
and ordered to pay $916,653
in restitution.
WA
DL
FBI, TIGTA
Suspect created fraudulent documents,
businesses and false identities and received
over $50,000 in loan proceeds.
Suspect was sentenced to 5
years of supervised release
and ordered to pay $54,900
in restitution.
GA
BL
ATF, FBI, IRS/CI,
USSS
Subject made false statement and fraudulently
applied for 120 PPP loans and received more
than $2.3 million in PPP. Subject received
unlawful kickbacks of more than $300,000 from
co-conspirators and used the proceeds to
purchase luxury vehicles and jewelry.
Subject was sentenced to 60
months incarceration, 3
years of supervised release,
and ordered to pay $2.5
million in restitution.
VA
BL/DL
FBI
Suspects made multiple false statements and
attempted to obtain multiple PPP and EIDL
loans over $1.5 million.
Suspect 1 was sentenced to
33 months incarceration and
3 years of supervised
release. Suspect 2 was
sentenced to 12 months
incarceration and 3 years
supervised release. Suspect 3
was sentenced to 14 months
incarceration and 3 years of
supervised release. Suspects
were ordered to pay over
$1.5 million in restitution.
AL
DL
USSS
Subject made multiple false statements and
attempted to obtain an EIDL loans over
$20,000.
Subject was sentenced to 48
months incarceration, 5
years of supervised release,
and ordered to pay $23,333
in restitution.
IA
BL
FBI, IRS/CI,
TIGTA
Subject submitted fraudulent PPP applications
and obtained over $1.2 million in CARES Act
funds.
Subject was sentenced to 40
months incarceration, 2
years of supervised release,
and ordered to pay over $1
million in restitution.

U.S. Small Business Administration | Office of Inspector General
58 | Fall 2022 Semiannual Report to Congress
IA
GC
FRB/OIG,
FDIC/OIG
Subjects originated SBA loans on behalf of
various financial institutions and fraudulently
obtained guarantees for loans that the SBA
deemed ineligible and provided false
information in connection with SBA loan
originations to make them appear eligible.
Subject 1 was sentenced to
14 months incarceration and
3 years of supervised
release. Subject 2 was
ordered to pay a $500 fine.
Suspects were ordered to
pay $4.5 million in
restitution.
MS
GC
DCIS, USDA,
GSA/OIG,
VA/OIG
Suspect participated in a fraud scheme and
conspired to operated companies with straw
owners who qualified as socially and
economically disadvantaged suspects and
service-disabled veterans, but who did not
actually control the companies.
Suspect was sentenced to 36
months incarceration, 1 year
of supervised release, and
ordered to pay $698,551 in
restitution.

Table Notes:

Legal Actions Summary Program Codes
BL………..Business Loans
DL……….Disaster Loans
GC………Government Contracting and Section 8(a) Business Development
IA………..Internal Affairs
OT………Other

Joint-investigation Agency Acronyms
Defense Criminal Investigative Service (DCIS)
Department of Commerce Office of Inspector General (DOC/OIG)
Department of Energy Office of Inspector General (DOE/OIG)
Department of Health and Human Services Office of Inspector General (HHS/OIG)
Department of Homeland Security Homeland Security Investigations (DHS/HSI)
Department of Homeland Security Immigration and Customs Enforcement (DHS/ICE)
Department of Homeland Security Office of Inspector General (DHS/OIG)
Department of Justice Office of Inspector General (DOJ/OIG)
Department of Justice Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
Department of State Office of Inspector General (DOS/OIG)
Department of Transportation Office of Inspector General (DOT/OIG)
Department of Treasury Inspector General for Tax Administration (TIGTA)
Department of Treasury Special Inspector General for the Troubled Asset Relief Program (SIGTARP)
Department of Veterans Affairs Office of Inspector General (VA/OIG)
Federal Bureau of Investigation (FBI)
Federal Deposit Insurance Corporation Office of Inspector General (FDIC/OIG)
Federal Housing Finance Agency Office of Inspector General (FHFA/OIG)
Federal Reserve Board Office of Inspector General (FRB/OIG)
General Services Administration Office of Inspector General (GSA/OIG)
Internal Revenue Service – Criminal Investigation (IRS/CI)
National Aeronautics and Space Administration Office of Inspector General (NASA/OIG)
State of California Employment Development Department (State of CA/EDD)
United States Airforce Office of Special Investigations (AFOSI)
United States Army/Criminal Investigation Division (Army/CID)
United States Department of Agriculture Office of Inspector General (USDA/OIG)
United States Naval Criminal Investigative Service (NCIS)
United States Postal Inspection Service (USPIS)
United States Secret Service (USSS)

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 59
Appendix F. Cosponsored and Other Activities
SBA’s authorization to cosponsor events requires OIG to report to Congress on the Administrator’s use of
that authority semiannually. The following list of activities was provided by the Office of Strategic
Alliances.
Name/Subject of Event
Name of Cosponsor(s)
Event
Location
Date Fully
Executed
The Bottom Line: Timely
Resources and Information for
America’s Small Businesses
HQ/Office of Communications & Public Liaison -
Small Business Majority
Virtual
9/28/2022
National Small Business Week
2023
HQ/Office of Communications & Public Liaison -
Service Corp of Retired Executives Inc.
Associations, DBA SCORE
Virtual/Nationwide 9/28/2022
Small Business Outreach
Hawaii District Office - Better Business Bureau -
Great West and Pacific
Virtual/Nationwide 9/26/2022
2022 Small Business Saturday
(SBS) Campaign
HQ/Office of Communications & Public Liaison -
American Express Travel Related Services Co. Inc.,
Women Impacting Public Policy Inc.
Virtual/Nationwide 9/22/2022
The Small Business Resiliency
Initiative
San Francisco District Office - U.S. Resiliency
Council
Virtual/Nationwide 9/16/2022
Business Bridge Webinar Series
Utah District Office - Utah Governor’s Office of
Economic Opportunity
Virtual Webinars
9/11/2022
Regional SBA Lender Training
Event
Rhode Island District Office - South Eastern
Economic Development Corporation, Rhode Island
Society of Certified Public Accountants
Middletown, RI
9/11/2022
Selling to the Government
Training Series
Wyoming District Office - Wyoming Procurement
Technical Assistance Center
Virtual/Wyoming
Statewide
9/11/2022
Spirit of Small Business Awards
Los Angeles District Office - Pacific Coast Business
Times
Santa Barbara, CA  8/25/2022
Nebraska District Office - Lincoln City Libraries
Small Business Workshop Series
September 1, 8,
15, 22, 2022
8/8/2022
Senator Leahy’s 25th Annual
Women’s Economic Opportunity
Conference
Vermont District Office - The Office of U.S. Senator
Patrick Leahy, Vermont Small Business
Development Center, Vermont Technical College,
Vermont Agency of Transportation, Vermont
Community Loan Fund, Vermont Procurement
Technical Assistance Center, Vermont Department
of Labor, Vermont Manufacturing Extension
Center, Vermont Agency of Human Services Office
of Economic Opportunity, The Vermont Women’s
Fund, The Center for Women & Enterprise,
Vermont Center for Emerging Technologies, SCORE
Vermont, Community Capital of Vermont, U.S.
Department of Agriculture Rural Development,
Vermont Network Against Domestic and Sexual
Violence, Vermont Works for Women
Randolph Center,
VT
8/3/2022
Conversation Series with Surdna
Foundation
HQ/Office of Women's Business Ownership -
Surdna Foundation
Virtual
7/21/2022
ChallengeHer Campaign
HQ/Office of Government Contracting - Women
Impacting Public Policy Inc.; American Express
Travel Related Services Company Inc.
Virtual
6/15/2022
2022 Small Business Breakfast
and Awards Ceremony
Puerto Rico & Virgin Islands DO - Puerto Rico
Bankers Association
Carolina, PR
5/10/2022
Business Education and
Resiliency Boot Camp Series
Washington Metro District Office - Greater
Washington Hispanic Chamber of Commerce
Washington, DC
5/4/2022

U.S. Small Business Administration | Office of Inspector General
60 | Fall 2022 Semiannual Report to Congress
2022 Vermont Small Business
Awards Ceremony
Vermont District Office - Vermont Business
Magazine
Waterbury, VT
4/21/2022
Infrastructure Bill Preparation
Program
Illinois District Office - Illinois Procurement
Technical Assistance Center
Virtual
4/19/2022
2022 Hawaii National Small
Business Week Awards Event
Hawaii District Office - Maui Chamber of
Commerce, Patsy T Mink Center for Business &
Leadership Women’s Business Center
Honolulu, HI
4/19/2022
2022 Small Business Week
Awards Program
Maine District Office - New Hampshire Bankers
Association
Bedford, NH
4/19/2022
Connecticut’s Celebration of
National Small Business Week
2022
Connecticut District Office - Connecticut
Department of Community and Economic
Development
New Haven, CT
4/14/2022
National Small Business Week
2022
HQ/Office of Communications and Public Liaison -
Google LLC, T-Mobile USA Inc.
Virtual
4/14/2022
National Small Business Week -
Salute to Small Business Awards
Luncheon
Rhode Island District Office - Rhode Island Society
of Certified Public Accountants
North Kingstown,
RI
4/8/2022

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 61
Appendix G. External Peer Reviews
Section 5(a) of the IG Act requires OIGs to report peer review results in the Semiannual Reports to
Congress. The following information is provided in accordance with these requirements:
Audits Division
The Government Auditing Standards, or Yellow Book, issued by the Comptroller General of the United
States requires that audit organizations performing audits and attestation engagements in accordance
with the Yellow Book must have an external peer review performed by reviewers independent of the
audit organization being reviewed at least once every 3 years. OIG’s Audits Division was reviewed by the
National Science Foundation OIG for the period ending March 31, 2021. SBA OIG received a peer review
rating of pass.
Similarly, the Council of the Inspectors General on Integrity and Efficiency (CIGIE) requires that
organizations that conduct inspections and evaluations under the Quality Standards for Inspection and
Evaluation, or Blue Book, must have an external peer review at least once every 3 years. During FY 2020,
our Audits Division underwent a Blue Book peer review conducted by the Department of Justice OIG. OIG
generally met Blue Book standards.
Investigations Division
Section 6(e)(7) of the IG Act, Attorney General Guidelines for Offices of Inspector General with Statutory
Law Enforcement Authority, and the CIGIE Quality Standards for Investigations require external peer
reviews of OIG investigative functions be conducted every 3 years.
In 2017, the U.S. Federal Deposit Insurance Corporation OIG reviewed our Investigations Division. The
reviewers found the system of internal safeguards and management procedures for the investigative
function of OIG was compliant with the quality standards established by CIGIE and the applicable
Attorney General Guidelines. (OIGs can be assessed as either compliant or noncompliant.) No
recommendations were offered.

U.S. Small Business Administration | Office of Inspector General
62 | Fall 2022 Semiannual Report to Congress
Appendix H. Office of Inspector General Reporting
Requirements
Under the Inspector General Act of 1978, as amended, OIG provides independent, objective oversight
to improve the integrity, accountability, and performance of SBA and its programs for the benefit of the
American people.
Although SBA’s programs are essential to strengthening America’s economy, the agency faces several
challenges in carrying out its mission. Access our annual report of the agency’s top management and
performance challenges on our OIG Reports web page.
OIG plays a critical role in addressing these and other challenges by conducting audits to identify
wasteful expenditures and program mismanagement; investigating fraud and other wrongdoing; and
taking other actions to deter and detect waste, fraud, abuse, and inefficiencies in SBA programs and
operations.
OIG’s activities also help to ensure that SBA employees possess a high level of integrity. This is critical to
the proper administration of SBA’s programs because it helps ensure SBA resources are used by those
who need them the most. Copies of OIG reports and other products are available at our OIG Reports
web page.
Reporting Requirements in the Inspector General Act of 1978, As
Amended
Section
Reporting Requirement
Location
4(a)(2)
Review of legislation and regulations
Other Significant OIG Activities
5(a)(1)
Significant problems, abuses, and deficiencies
Throughout
5(a)(2)
Recommendations with respect to significant
problems, abuses, and deficiencies
Significant Recommendations from This Reporting
Period
5(a)(3)
Prior significant recommendations on which
corrective action has not been completed
Significant Recommendations from Prior Reporting
Periods Without Final Action as of September 30,
2019
5(a)(4)
Matters referred to prosecutive authorities
Legal Actions Summary
5(a)(5)
Instances in which requested information was
refused
N/A
5(a)(6)
List of audit, inspection, and evaluation reports
Reports Issued; Reports with Questioned Costs
5(a)(7)
Significant reports
Throughout
5(a)(8)
Audit, inspection, and evaluation statistical tables
Statistical Highlights
5(a)(9)
Audit, inspection, and evaluation reports with
recommendations that funds be put to better use
Reports with Recommendations That Funds Be Put to
Better Use
5(a)(10)
Audit, inspection, and evaluation reports without
management decision, without comment within 60
days, or with unimplemented recommendations
Reports from Prior Periods with Overdue
Management Decisions; Reports from Prior Periods
with Open Recommendations as of September 30,
2019
5(a)(11)
Revised management decisions
Significant Revised Management Decisions
5(a)(12)
Management decisions with which the Inspector
General disagrees
Significant Management Decisions with Which OIG
Disagrees
5(a)(13)
Information described under section 05(b) of the
Federal Financial Management Improvement Act of
1996
Federal Financial Management Improvement Act
5(a)(14)–(16)
Peer review results
External Peer Reviews

U.S. Small Business Administration | Office of Inspector General
Semiannual Report to Congress, Fall 2022 | 63
5(a)(17),(18)
Investigative statistical tables and supporting
metrics
Investigations Reporting Statistics
5(a)(19)
Investigations involving a senior government
employee where allegations of misconduct were
substantiated
Investigations Involving a Senior Government
Employee Where Misconduct Was Substantiated
5(a)(20)
Whistleblower retaliation
Whistleblower Retaliation Cases
5(a)(21)
Attempts to interfere with the independence of OIG
Instances of Interference
5(a)(22)
Each closed inspection, evaluation, and audit not
disclosed to the public; each closed investigation
involving a senior government employee not
disclosed to the public
Investigations Involving a Senior Government
Employee That Is Closed and Not Disclosed to the
Public

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