Report (2022-06-14)

Date: 2022-06-14

Full text

CRISIS

CORONAVIRUS

IDLE ON EIDL FRAUD:
THE HOW THE TRUMP ADMINISTRATION
WASTED TAXPAYER DOLLARS BY
ON LEAVING THE COVID-19 EIDL
PROGRAM VULNERABLE TO FRAUD

SUBCOMMITTEE

SELECT

STAFF REPORT
JUNE 2022
I EXECUTIVE SUMMARY 1

CRISIS
II BACKGROUND 3

CORONAVIRUS
A. THE PRE-PANDEMIC EIDL PROGRAM 3

B. THE COVID-19 EIDL PROGRAM 5

III FINDINGS 8
A. UNDER THE TRUMP ADMINISTRATION, 8
THE SBA FAILED TO IMPLEMENT BASIC
FRAUD CONTROLS, LEADING TO THE
ON DISTRIBUTION OF TENS OF BILLIONS OF
DOLLARS IN POTENTIALLY FRAUDULENT

SUBCOMMITTEE
COVID-19 EIDL LOANS AND GRANTS

B. THE TRUMP ADMINISTRATION AWARDED 15
A $750 MILLION EIDL PROCESSING
CONTRACT TO A SMALL COMPANY THAT
RELIED ON A SUBCONTRACTOR FOR
NEARLY ALL THE WORK REQUIRED YET
STILL ACCRUED WINDFALL PROFITS AT
TAXPAYERS’ EXPENSE

SELECT

IV RECOMMENDATIONS 22
I. EXECUTIVE SUMMARY

This staff report presents findings from an investigation conducted by the Select
Subcommittee on the Coronavirus Crisis into the Small Business Administration (SBA)
Economic Injury Disaster Loan (EIDL) program’s operation during the pandemic. The Select
Subcommittee initiated this investigation following reports that raised concerns that the Trump
Administration failed to prevent billions of dollars in potential fraud by approving EIDL loans
and grants with significant fraud indicators. The investigation also commenced in light of
reports that SBA had awarded a costly $750 million no-bid contract to aid in implementing the
program.1 While the EIDL program delivered vital relief to millions of eligible small businesses,
$86 billion dollars in EIDL funds were disbursed to applicants with fraud alerts on their
applications.2

The Select Subcommittee’s investigation has uncovered new evidence that, under the
Trump Administration, SBA failed to implement basic safeguards to prevent fraud, even
directing loan reviewers to approve applications with serious fraud alerts without taking steps to
ensure that the applications were legitimate. Subsequent Department of Justice (DOJ)
prosecutions, moreover, have overwhelmingly involved EIDL applications that were submitted
during the period when the Trump Administration failed to implement basic fraud controls,
suggesting that this failure facilitated a large share of the fraud committed against the program.
Further, the Trump Administration’s failure to adequately assess reasonable labor costs required
for its EIDL processing contract also led it to waste hundreds of millions of taxpayer dollars with
more than $340 million of taxpayer funds paid to a company that assigned only six employees to
work on the project.

Specifically, the Select Subcommittee’s investigation found:

The Trump Administration Failed to Implement Basic Fraud Controls, Leading to Billions
of Dollars in Potentially Fraudulent Loans and Grants.

 New documents obtained by the Select Subcommittee show that SBA under the
Trump Administration directed a subcontractor to create a “batch” approval
function that allowed SBA employees to approve COVID-19 EIDL applications
without any review. These documents show that SBA specifically asked its contractor to
create this batch approval function. The Select Subcommittee has learned that SBA loan
reviewers did not even have the ability to open EIDL application files included in batches,
meaning as many as 1.6 million of the 3.9 million loan applications that were ultimately
approved may have been approved with no actual review by an SBA employee. SBA’s
directives further indicate that some applications were included in these batches for
approval without review despite the presence of fraud indicators identified by the
automated processing system run by SBA’s subcontractor.

 The Select Subcommittee uncovered documents showing that, under the Trump
Administration, even when EIDL applications were reviewed by SBA employees, the
reviewers were directed to approve applications containing indications of identity
theft without taking action to ensure the applications were legitimate. The Reference

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Guide distributed to SBA loan officers instructed them to simply approve COVID-19 EIDL
applications with indicators of fraud associated with identity theft, including where the
applicant’s online identity verification had failed and where the applicant’s information
couldn’t be validated—in some cases where there was an indication the applicant may be
deceased—without conducting additional diligence. Early in the Biden Administration,
SBA changed this guidance to direct loan reviewers to both obtain government
identification and ask for personal identifying information by the phone where there were
indications of identity theft.

 A Select Subcommittee analysis has found that the vast majority of DOJ prosecutions
of COVID-19 EIDL fraud have involved fraudulent applications submitted during
the Trump Administration, particularly between March and August of 2020. This
analysis found that 98 percent of DOJ prosecutions of EIDL fraud through May 2022
involve fraudulent applications submitted during the Trump Administration, even as SBA
has continued to disburse tens of billions of dollars in EIDL funds. This disparity is likely
a result of the Biden Administration’s implementation of stronger fraud safeguards,
including requiring that loan reviewers address all fraud alerts before approval, verify tax
information with tax transcripts, and use the Department of the Treasury (Treasury) Do
Not Pay List to identify ineligible applicants.

The Trump Administration Awarded a $750 Million EIDL Processing Contract to a
Company that Relied on a Subcontractor for Nearly All the Work Required Yet Still
Accrued Windfall Profits at Taxpayers’ Expense.

 The Trump Administration awarded its pre-pandemic EIDL contract to a small
business—RER Solutions Inc. (RER)—which did not have the capacity to
immediately scale up loan recommendation services in a catastrophic situation. Prior
to the pandemic, SBA determined that it was appropriate to award its approximately $10
million annual EIDL processing and loan recommendation contract as a small business set
aside to RER, even though there were clear indications that RER would need to rely on its
large firm partner Rocket Loans (Rocket)—which, unlike RER, had significant experience
with relevant lending technology and services—for core contract services. This was
particularly concerning because SBA foresaw the possibility that its EIDL loan
recommendation contractor could be required to quickly scale up its services a hundredfold
in the event of a catastrophic disaster. In light of regulations requiring that 50 percent of
revenue from small business set aside contracts remain with the prime small business
contractor, this decision also created the risk that in an emergency the contract would be
greatly expanded and result in an unjustified windfall for RER at taxpayers’ expense. At
the onset of the pandemic, with demand for millions of EIDL loans and grants, RER’s
existing system run by subcontractor Rocket was not capable of handling the type and
volume of EIDL applications. RER had to further subcontract with Rocket-affiliated
technology firm Rapid Financial Services LLC (Rapid) to build a system capable of
handling the surge in EIDL applications, and Rapid ultimately provided the large majority
of the labor and key inputs necessary to fulfill the COVID-19 EIDL contract.

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 The Trump Administration awarded the $750 million COVID-19 EIDL loan
recommendation contract—the largest individual contract across the entire federal
government to respond to the pandemic’s economic impact—to RER without a
competitive process or an adequate assessment of the reasonable cost of the services
provided. SBA did not use a competitive process for this award and instead modified
RER’s much smaller pre-pandemic contract. Contractor RER, through subcontractor
Rapid, primarily provided automated services that required relatively little labor, and which
reviewed COVID-19 EIDL application information in less than a second to provide fraud
alerts, credit checks, and approval or denial recommendations. Despite this, SBA agreed
to pay RER more than $40 per EIDL application reviewed without assessing whether this
price was reasonable in light of the actual costs the contractor would incur.

 Illustrating the Trump Administration SBA’s failure to ensure the contract was
reasonably priced, RER ultimately netted more than $340 million for the work of just
six employees. RER subcontractor Rapid provided most of the labor and technology
needed to fulfill the contract, employing 163 employees and contractors who contributed
to the company’s work for SBA and providing proprietary software; Rapid received $148
million, just 20 percent of the contract’s proceeds. By contrast, RER subcontractor Rocket
(a Rapid affiliate) received $233 million for just 20 employees it contributed to the
COVID-19 EIDL contract work. Most egregiously, prime contractor RER, which told the
Select Subcommittee that it assigned only six employees to work on the contract and
primarily engaged in “contractual administrative duties,” pocketed $340 million. SBA’s
failure to adequately assess the reasonable cost of the contract, including by considering
reasonable labor and other real costs, cost taxpayers hundreds of millions of dollars and
resulted in a windfall for two private companies who contributed relatively little to the
contract’s performance.

II. BACKGROUND

A. The Pre-Pandemic EIDL Program

SBA’s Economic Injury Disaster Loan program predated the pandemic. Under the EIDL
program, SBA makes loans available to homeowners and small businesses for economic injuries
caused by disasters—typically localized disasters like hurricanes, tornadoes, and earthquakes—
in areas subject to certain disaster and emergency declarations.3 SBA’s Office of Disaster
Assistance (ODA) administers the EIDL program and processed an average of 65,000 EIDL
applications annually before the pandemic.4

1. SBA’s 2018 Contract for EIDL Application Processing and Recommendations

In 2018, SBA solicited contractors to analyze EIDL applications and to quickly provide
SBA with recommendations to approve or decline the applications, with the agency retaining the
final decision on an application’s approval or denial.5 Although SBA’s solicitation noted that the
volume of EIDL applications had recently averaged 65,000 annually, a rate of slightly more than
5,000 per month, SBA made clear that it foresaw the possibility that a catastrophic event could
dramatically increase the volume of loan recommendations required to one million applications

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in 60 days, a rate of 500,000 per month.6 In response to a question from a potential bidder about
this capacity requirement, SBA reiterated that it required contractors be able to scale up their
analysis and recommendation capacity to allow SBA to “make a million decisions in a short
period,” and that this would require the contractor recommend decisions to approve or deny loan
applications at a rate of “12 loans per minute.”7

Although SBA understood that a major catastrophe could require the EIDL program to
quickly surge its processing capacity a hundredfold to aid in making a million loan decisions “in
a short period,” SBA solicited its loan recommendation services contract as a small business set
aside.8 SBA told the Select Subcommittee that the contract was solicited as a small business set
aside in accordance with the federal acquisition regulations “Rule of Two,” which requires that
agencies set contracts aside for small businesses when there is a “reasonable expectation” that
two or more small businesses are likely to offer the solicited services “competitive in terms of
fair market prices, quality, and delivery.”9 SBA ultimately awarded the contract to RER, which
qualified as a small business at that time.10 The 2018 SBA contract with RER had a ceiling of
$10 million for the first year and $100 million over a four year period.11 Despite its
determination that this contract was appropriate to set aside for a small business contractor, SBA
also found that the ultimate small business contractor would need to engage a large firm as a
subcontractor to meet contract requirements.12

2. RER, Rocket Loans, and Rapid Financial Services

To meet SBA’s requirement that a large firm partner with the small business that
obtained the contract, RER partnered with Rocket, a larger company with experience in
supporting personal lending (and subsidiary of Rocket Companies, Inc., which has billions of
dollars in annual revenue).13

Before receiving its EIDL contract, RER’s previous federal contracts were to provide
professional services support for federal agencies. For example, RER contracted with the
Department of Energy for about $1 million per year to provide “general and business
management support services.”14 RER had some experience assisting agencies in making
lending decisions on a much smaller scale than required by the EIDL program, including, for
example, a $165,000 contract with the Department of Housing and Urban Development to
support underwriting 2,460 loans.15

Rocket Loans, by contrast, is a subsidiary of Rocket Companies, which is a financial
technology and financial services company that supports various types of personal lending,
including mortgages, home, and auto loans.16 Rocket Companies had more than $5 billion in
revenue in 2019.17 Rocket ultimately provided the software needed to make loan
recommendations to SBA for the pre-pandemic EIDL contract.18 Rocket has an affiliate (which
is not a subsidiary), Rapid, that did not contribute the pre-pandemic EIDL processing contract
and was brought in later to support EIDL processing during the pandemic. Rapid is a financial
technology company that specializes in underwriting loans to small businesses using an
automated platform that employs data and algorithms to assess risk, identify potential fraud, and
make lending recommendations.19 Before working on EIDL during the pandemic, Rapid had
experience serving 35,000 small businesses related to $2.2 billion in private financing.20

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B. The COVID-19 EIDL Program

1. With the Onset of the Pandemic, Congress Expanded the EIDL Program and SBA
Received an Unprecedented Number of EIDL Applications.

The Coronavirus Preparedness and Response Supplemental Appropriations Act,
Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Paycheck Protection
Program and Healthcare Enhancement Act, the December Consolidated Appropriations Act,
2021, and the American Rescue Plan directed the SBA to provide EIDLs and EIDL advance
grants to small businesses harmed by the pandemic, which SBA refers to as its “COVID-19
EIDL” program.21 By March 21, 2020, SBA declared all states, the District of Columbia, and all
territories to be disaster areas, making small businesses everywhere in the country eligible for
loans through the COVID-19 EIDL program for the economic injuries suffered as a result of the
pandemic; demand for EIDLs from affected businesses was extraordinarily high.22 Following
passage of the CARES Act on March 27, 2020, small businesses were also eligible for COVID-
19 EIDL advance grants that did not need to be repaid.23 Funds for COVID-19 EIDL grants
were subsequently replenished in the American Rescue Plan and other pandemic relief
legislation.24

The coronavirus crisis led to an unprecedented volume of EIDL applications, with SBA
receiving 4.5 million applications between March 31, 2020, and April 10, 2020, and nearly 18
million applications by July 2021.25 COVID-19 EIDL loans were limited to a $150,000
maximum loan amount (with some periods where the maximum amounts were adjusted to
$500,000), and EIDL advance grants (and later targeted and supplemental targeted grants) of up
to $10,000 were also available for affected small businesses. As of April 2022, SBA had
approved more than 3.9 million COVID-19 EIDL applications and a total of over $378 billion in
EIDLs for American businesses.26 5.8 million EIDL advance grants and 1 million targeted and
supplemental targeted EIDL advance grants totaling $27.5 billion were also disbursed.27

2. SBA Dramatically Expanded RER’s Contract in a Non-Competitive Process.

In late March 2020, SBA engaged with RER and Rocket, as well as Rocket’s affiliate
Rapid, to create new system for providing loan recommendations and analysis for COVID-19
EIDL applications.28 SBA’s existing portal could not handle the volume of EIDL applications,
and Rocket’s existing loan processing system, which more commonly handled EIDLs for home
property damage, was not able to handle the volume and type of applications being submitted in
the COVID-19 EIDL program.29 SBA rushed to create a new system that would send EIDL
application data to Rapid, and where Rapid would provide SBA with recommendations to
approve, manually review, or decline EIDL applications.30 In April 2020, SBA modified its
contract with RER to incorporate the COVID-19 EIDL program without a competitive process,
increasing RER’s total contract ceiling from $100 million to $600 million (and later that year to
$750 million).31 In justifying this modification SBA asserted that the pandemic presented
“exceptional circumstances” given the millions of applications received, and the modification
was ultimately approved by then-SBA Administrator Jovita Carranza.32 The modified contract
with RER was the largest contract awarded by the federal government in service of the response
to the pandemic’s economic impacts.33

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3. SBA COVID-19 EIDL Application Vetting and Approval Process

SBA implemented a process where RER subcontractor Rapid would process EIDL
applications through an automated system which would generate a recommendation to SBA loan
officers on whether to approve, decline, or manually review the COVID-19 EIDL application.
Rapid’s system included automated fraud checks that generated alerts when there were
indications that an EIDL application might be fraudulent.34 Adapting its existing business loan
system, Rapid created the portal where SBA loan officers and Team Leads could review Rapid’s
recommendation to approve a loan, manually review its fraud flags, or decline the loan, and
where SBA Team Leads could ultimately obligate funds.35 Rapid’s system employed automated
fraud checks that included running COVID-19 EIDL application information through third party
data services including Lexis and Iovation Identity Verification, the Lynx Fraud Indicator,
DecisionLogic bank information verification, Experian, and other email, phone, and bank
account verification services.36 These automated fraud check systems would lead to alerts when
“Fraud Check Indicators” were present in an EIDL application, which were flagged for SBA
loan reviewers as “fraud alerts.”37

When fraud alerts were generated by Rapid’s system, the application was generally—
though not always—sent to an SBA loan officer to review the fraud alerts or other flags and
subsequently sent to an SBA Team Lead for final approval or declination.38 When no fraud
indicators were generated, Rapid’s system would send the application directly to an SBA Team
Lead with a recommendation for approval.39 Rapid’s system also allowed loan officers and
Team Leads to access information about loan applicants, fraud alerts, or other information
deficiencies on their applications, to change loan totals, to access contact information for
applicants, and to eventually approve or deny EIDL applications.40

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Although Rapid’s system ran automated fraud checks and provided the portal used by
SBA loan officers and Team Leads, Rocket continued to provide services for funding and
disbursing loans after they were approved through SBA’s Etran payments system.41 Documents
and information obtained by the Select Subcommittee show that RER’s very small staff assigned
to work on this contract largely performed “contractual administrative duties” like negotiating
with SBA and sending the agency invoices and data concerning the number of applications
processed, and high level “project management.”42

SBA greatly expanded its workforce of loan officers and other staff reviewing EIDL
applications after they were processed by Rapid’s system. In total, SBA expanded its relevant
staff more than five-fold to over 8,000 loan officers, Team Leads, and support staff.43 These
loan officers and other staff generally reviewed EIDL application information, including fraud
alerts, after the applications were recommended to approval, denial, or manual review by Rapid’s
system.44 The cost of paying this staff to review EIDL applications was not included in the $750
million contract with RER, and was an additional expense incurred by SBA.45

4. Reports of Fraud Vulnerabilities

Reports and testimony of government watchdogs, including SBA OIG and the
Government Accountability Office (GAO), raised serious concerns about the Trump
Administration SBA’s failure to implement basic safeguards to prevent widespread fraud during
the early operation of the COVID-19 EIDL program.46 An independent watchdog report also
alleged that SBA loan officers did not receive basic guidance on fraud prevention until after SBA
OIG reported that there was significant fraud in the COVID-19 EIDL program and that SBA
failed to provide adequate training to loan officers. This reportedly led loan officers to override
fraud alerts and approve potentially fraudulent EIDL applications.47

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5. The Select Subcommittee’s Investigation

The Select Subcommittee first initiated an investigation of the COVID-19 EIDL program,
and of the Trump Administration’s decision to award such a significant contract supporting the
program without a competitive process, in July 2020.48 Following reports of extensive fraud
vulnerabilities in the COVID-19 EIDL program, the Select Subcommittee expanded its
investigation in early 2021 to include COVID-19 EIDL fraud risks.49 The Select Subcommittee
has requested and received documents and information from SBA, RER, Rocket, and Rapid.50 In
total, the Select Subcommittee has received and reviewed 17,000 pages of documents responsive
to these requests. The Select Subcommittee has also held two briefings with RER and Rapid,
four briefings with SBA regarding the operation of the COVID-19 EIDL program, and a hearing
on fraud in SBA programs that included the SBA Inspector General’s testimony on EIDL
fraud.51

III. FINDINGS

The Select Subcommittee’s investigation has found that, under the Trump
Administration, SBA failed to safeguard taxpayer dollars in the COVID-19 EIDL program.
First, early in the Trump Administration’s implementation of the program, SBA failed to
implement even the most basic safeguards to prevent fraud, including by directing loan officers
to approve applications with serious fraud indicators without appropriate investigation. Second,
SBA failed to rigorously assess the appropriate price of its contract for automated EIDL loan
recommendation and processing services when modifying its existing contract in a
noncompetitive process, leading to windfalls for RER and Rocket that cost taxpayers hundreds of
millions of dollars.

A. Under the Trump Administration, SBA Failed to Implement Basic Fraud
Controls, Leading to the Distribution of Tens of Billions of Dollars in
Potentially Fraudulent COVID-19 EIDL Loans and Grants.

SBA contracted with RER and its subcontractor Rapid to provide automated checks for
indications of fraud in EIDL applications, but SBA retained the role and responsibility of
approving EIDL loans and advance grants. After receiving data from Rapid’s automated review
of EIDL applications, including alerts that fraud indicators were present, SBA loan officers and
Team Leads were responsible for reviewing EIDL applications, ensuring that the applications
were not fraudulent, and ultimately approving the loans.52 Under the Trump Administration,
though, SBA took several steps that significantly increased the vulnerability of the EIDL
program to fraud, including by (i) directing Rapid to create a “batch” approval mechanism that
prevented the designated SBA employee from reviewing applications before approval, (ii)
directing loan officers to approve applications flagged as potentially involving identity theft
without further identity verification, and (iii) directing that Rapid not flag applications containing
some fraud indicators as requiring additional review by loan officers. The Trump
Administration’s decision to remove basic safeguards contributed to the distribution of tens of
billions of dollars in potentially fraudulent loans and grants.

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1. The COVID-19 EIDL Program Was Vulnerable to Widespread Fraud.

As the Select Subcommittee has previously reported, the COVID-19 EIDL program
under the Trump Administration was vulnerable to widespread fraud. SBA OIG found that the
Trump Administration disbursed $86 billion in EIDL loans and advances in response to
potentially fraudulent applications that contained fraud indicators including duplicate IP
addresses, email addresses, physical addresses, bank accounts, bank account information with
discrepancies, links to identity theft, and Employer Identification Numbers (EINs) registered
after the early 2020 cutoff date.53 SBA Inspector General Hannibal “Mike” Ware testified to the
Select Subcommittee in March 2021 that EIDL fraud risk “wasn’t taken as seriously” as fraud
risk in other programs operated by the Trump Administration, and that OIG “notified SBA up
front” as the EIDL program rolled out that “we have to strengthen our controls.”54

Although the precise extent of fraud in the COVID-19 EIDL program is not yet known,
numerous indicators suggest that it was extensive. GAO found that financial institutions filed
more than 20,000 suspicious activity reports (SARs) related to COVID-19 EIDL transactions.55
SBA also disbursed more than 112,000 COVID-19 EIDL loans and 98,000 advance grants that it
later referred to SBA OIG as being related to an identity theft complaint. As of January 2021,
SBA estimated that it had received over 150,000 returned loan statements related to incorrect or
fraudulent addresses, indicating that COVID-19 EIDL identity theft fraud may have been even
more extensive.56 SBA OIG also found that, in 2020, SBA distributed approximately $4.5
billion in $10,000 EIDL advance grants to sole proprietors and independent contractors that they
were categorically ineligible for given the $1,000 per employee advance grant limit.57 These
findings taken together show that the Trump Administration likely permitted the COVID-19
EIDL program to disburse billions of taxpayer dollars in response to fraudulent applications.

2. During the Trump Administration, SBA Created a “Batch” Approval Mechanism
That Facilitated Approval of EIDL Loans with No Review by Loan Officers.

New evidence uncovered by the Select Subcommittee shows that SBA under the Trump
Administration implemented a design that left the COVID-19 EIDL program vulnerable to fraud,
as many applications received no review at all from SBA loan officers or Team Leads. GAO and
SBA OIG have previously criticized SBA’s use of “batch” approval of EIDL applications,
whereby SBA Team Leads could approve dozens of loan applications at once “with little to no
vetting of the loan information” or “with little to no additional review by the team leaders.”58
New evidence obtained by the Select Subcommittee now shows both that SBA specifically
requested that its contractor add this “batch” approval function allowing mass approval of loan
applications without review, and that the system prevented any review whatsoever of EIDL
applications that were included in “batches.”59

SBA’s decision to employ a “batch” approval mechanism required its subcontractor
Rapid to add a function that was not part of its initial planning or existing system, which
envisioned a “detailed review” of COVID-19 EIDL applications “one at time.”60 SBA requested
that Rapid add functionality that would allow SBA loan officers to approve batches of as many
as 500 applications at a time (ultimately, batches included 25 to 50 applications), which would
be the “only inherently governmental check” before funds were obligated and disbursed.61

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These batches of EIDL applications were sent directly to SBA Team Leads and
recommended for approval without any initial review by other SBA loan officers.62 SBA OIG
has pointed out that this batch approval process abandoned SBA’s traditional “Rule of Two”
control, which had previously required that two SBA employees review and approve a loan
application, by only requiring loan approval by a single SBA employee.63

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In practice, applications in batches received no review at all from any SBA employee.
SBA’s Processing and Disbursement Center Director told the Select Subcommittee that the EIDL
application processing system did not even allow SBA Team Leads to open individual EIDL
application files in batches recommended for approval64—making approval without review
essentially automatic without any human laying eyes on application details. Data from Rapid
obtained by the Select Subcommittee shows that as many as 1.6 million EIDL applications may
have been included in “batches” recommended for approval and received no actual review by an
SBA employee in the COVID-19 EIDL program’s early months.65 Nearly all of these
applications were ultimately approved, even as less than 50 percent of those applications
recommended for manual review were approved in the same period.66

Additionally, there are strong indications that some EIDL applications included for
“batch” approval without review contained fraud alerts. SBA provided Rapid with instructions
that it should include applications in batches even when they contained as many as two
indicators of potential fraud.67 These applications, including those with fraud flags, would then
be approved in batches without any further substantive review. This was evidently because SBA
determined that certain fraud indicators—including emails that failed to pass validation, phone
numbers that weren’t associated with the relevant business or owner, international locations, and
businesses whose registration could not be confirmed—were less concerning and directed that
such applications be included in batch files for nearly automatic approval.68 SBA staff told the
Select Subcommittee that these fraud indicators were at the lower end of the hierarchy, and that
they did not present an issue.69

Given the unprecedented demand for EIDL loans and grants at the onset of the pandemic,
SBA’s decision to employ automated fraud checks for efficiency and speed could be defensible.
However, SBA’s judgment to not only have EIDL applications in batches approved without any
actual review by an SBA employee, but to also include applications in those unreviewed batches
that contained fraud indicators, significantly and unjustifiably increased the program’s
vulnerability to fraud.

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3. Even When EIDL Applications Were Manually Reviewed, the Trump
Administration SBA Directed Loan Officers to Approve Loans with Serious
Fraud Indicators.

When Rapid’s automated system found that EIDL applications included what SBA had
determined were serious fraud indicators, the applications were sent to SBA loan reviewers for
manual review before they could be recommended to an SBA Team Lead for ultimate
approval.70 Applications subject to manual review included those where the business owner
information could not be validated, where there was suspected digital identity fraud or suspicious
online behavior, and where there were indications that bank account information was incorrect or
did not match the applicant.71 Documents uncovered by the Select Subcommittee show,
however, that during the Trump Administration, SBA specifically directed loan reviewers to
approve applications with the most serious fraud alerts—including those related to identity
theft—without any attempt to ensure the applications were legitimate.

SBA staff told the Select Subcommittee that it found identity theft to be a particularly
significant source of EIDL fraud.72 This assessment is in accord with the SBA OIG finding that
SBA disbursed EIDL loans and advance grants in over 200,000 cases in response to applications
associated with identity theft complaints.73 Yet, despite the assessment that identity theft was a
significant source of fraud, SBA issued guidance to loan reviewers that directed them to approve
EIDL applications with critical fraud indicators without taking action to ensure the applications
were not the result of identity theft. Specifically, SBA’s Guide for loan officers directed them to
simply “Approve” applications that “failed online identity verification,” and directed loan
reviewers to “Approve” applications where the “Owner/Client information failed validation (info
doesn’t go together, person is listed as deceased, etc.)” without taking action to address the fraud
flag.74

SBA eventually changed these directives to require the loan reviewer to request a form of
government identification when these indicators of identity theft were present.75 By the time
SBA made this modest improvement, however, more than 1.3 million EIDL applications totaling
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over $90 billion had been approved.76 Early in the Biden Administration, SBA included more
detailed instructions that also directed the loan reviewer to call the applicant and further confirm
their identity by asking for personally identifying information.77 The diligence SBA later
required its loan officers to conduct, largely following reports of extensive vulnerabilities in the
program, further demonstrates that earlier directives during the Trump Administration created
intolerable fraud risks.

4. Inadequate Training and High “Production Goals” Requiring Quick Review of
Applications Also Likely Increased COVID-19 EIDL Fraud Vulnerabilities.

Other aspects of the Trump Administration SBA’s early implementation of the COVID-19
EIDL program likely increased fraud risk. Reports indicate that, in addition to being given
directives to approve EIDL applications containing certain fraud indicators, that loan officers—
many of whom were just hired as SBA dramatically increased its processing staff—were given
inadequate training on fraud prevention, particularly before SBA OIG released a critical public
report of COVID-19 EIDL fraud vulnerabilities.78 This comports with a report the Select
Subcommittee received from an SBA contract loan reviewer that trainings were low quality even
as those hired often had little or no experience reviewing loan applications, and that fraud was
rarely, if ever, mentioned in hours-long training sessions early in the program’s operation. This
lack of training regarding how to address indicators of fraud likely increased fraud vulnerability
even for applications containing fraud alerts that SBA’s guidance directed reviewers to take action
to address.

Further, loan officers were given aggressive target goal rates that did not allow sufficient
time to fully review applications and ensure applications were not fraudulent. In October 2020,
SBA OIG reported that loan officers were told to meet a “production goal” of reviewing and
approving or denying four applications per hour, giving them only an average of 15 minutes to
review and resolve issues in a COVID-19 EIDL application. This led to “cursory reviews” that
were less likely to detect fraudulent applications.79 SBA OIG’s report comports with information
13
the Select Subcommittee received from an SBA contract loan reviewer, who indicated that loan
reviewers felt pressure to meet these “production goals,” which the loan reviewer referred to as
“quotas,” at the expense of detecting fraudulent applications. Given these high goal rates for
review, even as SBA slowly improved its directives to loan reviewers regarding fraud alerts, the
loan officers’ limited time to actually address indications of potential fraud likely contributed to
the continued approval of fraudulent applications.

5. The Select Subcommittee’s Analysis of DOJ Prosecutions of EIDL Fraud Indicates
That the Majority of Fraud Was Committed During the Trump Administration’s
Early Implementation of the COVID-19 EIDL Program.

The Select Subcommittee conducted an analysis of all DOJ prosecutions of EIDL fraud
thus far to shed light on the primary methods used to commit fraud against the program by
examining cases where investigators gained sufficient information to bring criminal charges. To
date, DOJ has pursued 117 prosecutions of 177 defendants for COVID-19 EIDL fraud, involving
at least $45 million in fraudulently obtained EIDL funds.80 The Select Subcommittee’s analysis
of these prosecutions has revealed that the vast majority of confirmed EIDL fraud cases—nearly
95 percent—involved applications submitted between late March and August 2020.81 Even as
the Biden Administration continued to approve a significant number of EIDL loans, advance
grants, and loan increases—totaling over $179 billion since February 2021—98 percent of EIDL
fraud prosecutions to date have involved fraudulent applications submitted during the Trump
Administration’s operation of the program.82

The Select Subcommittee’s finding that the overwhelming share of DOJ prosecutions of
COVID-19 EIDL fraud involve fraudulent applications submitted during the Trump
Administration’s early implementation of the program is consistent with the evidence that the
Trump Administration failed to employ even basic safeguards against fraud.83 This finding is
also consistent with indications that, in early 2021, the Biden Administration began
strengthening the program’s fraud controls by requiring that fraud indicators be addressed by
loan officers (including with, as shown above, detailed directions to loan officers on actions that
must be taken when identity theft indicators are present), validating applications against
Department of the Treasury’s (Treasury’s) Do Not Pay List, obtaining Internal Revenue Service
tax transcripts to verify EIDL applicant information, and checking Employer Identification
Numbers (EINs).84

The methods many applicants used to commit EIDL fraud further confirm that the
indicators of potential fraud used by SBA OIG to identify billions of dollars in potential fraud
were present in many cases of confirmed fraud, and the fraud controls added by the Biden
Administration would likely have prevented payment in many such cases had they been
implemented by the Trump Administration:

 51 percent of these prosecutions involved fictitious, inactive, or inoperative
businesses, many of which lacked business registrations entirely, were shell
companies registered after the pandemic began, or were publicly registered as
“inactive.”85 The Biden Administration’s implementation of taxpayer EIN
searches, requirement that fraud alerts be adequately addressed by loan reviewers,

14
and review of tax transcripts have likely made it much more difficult for fictitious
and inactive businesses to obtain fraudulent EIDLs.

 22 percent of the prosecutions involved applicants that used stolen identities to
submit fraudulent applications, and in some of these cases applicants used stolen
identities in conjunction with fictitious business entities.86 SBA’s EIDL processing
system generates fraud alerts that can prevent payment in many of these cases when
loan reviewers are required to address those alerts before EIDL approval, as the
Biden Administration now requires.

 10 percent of the prosecutions involved fraud rings where a central group of
conspirators solicited personal information from many other individuals in order to
submit dozens or hundreds of fraudulent applications.87 These cases show that
large numbers of fraudulent applications often originated from a handful of IP
addresses, generating a fraud indicator that loan reviewers could address to prevent
fraudulent payments.88 While Trump Administration guidance merely directed
loan officers to “review the file” to determine if a “packager” was involved before
approving loans flagged from a high risk IP address, Biden Administration
guidance required loan officers to contact applicants when this fraud indicator is
present and directs them to contact SBA’s Fraud Review Team if fraud or identity
theft is suspected.89

B. The Trump Administration Awarded a $750 Million EIDL Processing
Contract to a Small Company that Relied on a Subcontractor for Nearly All
the Work Required Yet Still Accrued Windfall Profits at Taxpayers’ Expense.

Information obtained by the Select Subcommittee demonstrates that the Trump
Administration’s failure to rigorously assess the costs required to fulfill its automated EIDL
processing and recommendation contract led the agency waste hundreds of millions of taxpayer
dollars. RER received over $340 million for the work of just six employees for one year, while
its subcontractor Rocket received $233 million for the work of just 20 employees in that time.
Rapid, another subcontractor, provided the vast majority of the labor needed, created the
proprietary automated system used, and paid third party data fees—essentially bearing all the
core costs required by the contract—but received only 20 percent of the funds paid by SBA.
This waste was partly caused by SBA’s decision to award its pre-pandemic EIDL contract to a
small business that lacked the ability to surge its loan processing capacity without delegating the
vast majority of the work to a large firm subcontractor, even as SBA foresaw the possibility that
the EIDL program could face a dramatic surge in demand for relief. Given regulations requiring
that prime small business contractors retain 50 percent of a contract’s revenue, the emergency
modification to RER’s contract for the COVID-19 EIDL program resulted in the company
receiving half the contract’s value while doing little of the work. Ultimately, SBA failed to
ensure taxpayers paid a reasonable price for the largest single contract awarded by the federal
government to aid in the response to the pandemic’s economic impacts.

15
1. The Trump Administration’s 2018 Decision to Award Its Pre-Pandemic EIDL
Processing Contract to Small Contractor RER Left SBA Unprepared for the
Pandemic’s Surge in Demand for EIDL Relief.

In 2018, SBA determined to solicit its EIDL processing and loan recommendation
contract as a small business set aside.90 Although the volume of EIDL applications in recent
years had averaged only 65,000 annually, SBA made clear that it envisioned a catastrophic event
could dramatically increase the volume of loan recommendations required.91 SBA specifically
articulated that the required processing could be orders of magnitude larger than it had been in
recent history, requiring SBA to “make a million decisions in a short period,” and that this would
require the contractor recommend decisions at a rate of “12 loans per minute.”92

SBA told the Select Subcommittee that the contract was solicited as a small business set
aside in accordance with the Federal Acquisition Regulations (FAR) “Rule of Two,” which
requires that agencies set contracts aside for small businesses when there is a “reasonable
expectation” that two or more small businesses are likely to offer the solicited services
“competitive in terms of fair market prices, quality, and delivery.”93 SBA ultimately awarded
the contract to RER, a small business.94 Despite SBA’s determination that the contract was
appropriate to set aside for a small business contractor, the agency assessed that the ultimate
small business contractor would need to engage a large firm as a subcontractor to meet contract
requirements.95

This reasonable assessment should have led SBA to question whether any such small
firm contractor/large firm subcontractor arrangement could have been expected to successfully
handle the surge in demand that SBA foresaw in the case of a catastrophic event. Those
concerns should have been particularly acute in the case of awarding a loan recommendation
contract to a company like RER, which was not itself a financial technology company that
specialized in providing automated loan recommendations to aid underwriting. RER, instead,
had experience providing more general support and consulting services support to a range of
federal agencies.96 To meet SBA’s requirement that a large firm partner with the small business
that obtained the contract, RER partnered with Rocket Loans (Rocket), company that did
specialize in providing lending services in partnership with a bank through an online platform
that quickly generated loan offers in response to applications using proprietary technology.97
SBA OIG found strong indications that Rocket performed the “primary and vital” services
required for the pre-pandemic contract, including by providing the recommendation software
required for the automated loan recommendations that the contract centered on.98

At the onset of the pandemic, demand for EIDLs surged and SBA’s existing application
portal and RER’s existing processing system (which was provided by Rocket) were not capable
of effectively handling the dramatically increased volume of applications from small
businesses.99 The application volume was even greater than the “million [EIDL applications] in
a short period” that SBA foresaw as a possibility, with 4.5 million EIDL applications submitted
by April 10, 2020.100 In order to handle this increased volume, SBA began working with Rapid,
a new RER subcontractor (and corporate affiliate of Rocket), to build a new system to handle
processing the increased volume of EIDL applications.101

16
Given that SBA foresaw that a catastrophic event could lead to a dramatic increase in
application volume, SBA’s decision to issue the EIDL loan recommendation contract as a small
business set aside to RER may have violated the FAR given the indications that RER would not
be “competitive in terms of … quality, and delivery” particularly when faced with a catastrophic
event.102 SBA should have been aware that RER lacked capacity to significantly contribute in
such an event given that SBA OIG found that RER’s pre-pandemic contract proposal, teaming
agreement with Rocket, and SBA’s Award Decision Memorandum contained clear indications
that Rocket, not RER, would provide the “primary and vital” services required by the contract.103
It is certainly possible that some small businesses—particularly those that specialized in lending
technology services—may have been capable of providing loan recommendation services to
SBA without undue reliance on a large firm partner, and with capacity to scale those services in
the event of catastrophe, but RER did not have the capability to provide those core services.104

There are also indications that SBA failed to take other steps necessary to ensure that the
cost of the original contract was reasonable. SBA OIG found that SBA failed to properly assess
what labor costs and other direct costs would be involved in carrying out the contract to ensure
that the price paid to RER was “fair and reasonable in accordance with [Federal Acquisition
Regulations] and agency policy,” and as RER’s proposed price exceeded a previous independent
government estimate by 55 percent.105

As discussed below, an additional concern with issuing a contract that where an
emergency small firm contractor/large firm subcontractor arrangement was foreseen stems from
regulations and a statutory provision requiring 50 percent of small business set aside services
contract revenue to be retained by the prime contractor and not paid to large business
subcontractors.106 If a catastrophic event occurred that created an enormous surge in the needed
services, that small business could receive an enormous windfall from a contract expanded under
emergency conditions even as its large business subcontractor handled nearly all the additional
workload.

2. After the Onset of the Pandemic, SBA Expanded RER’s Contract to $750 Million
for COVID-19 EIDL Services—the Largest Contract Awarded by the Federal
Government to Respond to the Economic Impact of the Pandemic—Without A
Competitive Process or Taking Reasonable Costs into Account.

With the onset of the pandemic in March 2020, SBA began to work with RER and its
new subcontractor, Rocket-affiliate Rapid, to develop a system for processing EIDL applications
and receiving loan recommendations from Rapid’s system.107 SBA modified RER’s contract
through a non-competitive process to dramatically increase the contract’s ceiling to $600 million,
and later to $750 million. It ultimately paid out at least $740 million.108 This substantial
contract was the largest individual contract awarded across the federal government in 2020 for
goods or services needed to support the response to the pandemic’s economic impacts—dwarfing
other technical support contracts for the economic response to the pandemic and surpassed by
only a handful of contracts related to the public health response to the pandemic, such as
contracts to manufacture or distribute coronavirus vaccines.109 SBA told the Select

17
Subcommittee that it was necessary to modify the existing contract, rather than use a competitive
bid process, in order to respond quickly to the coronavirus crisis.110

In expanding RER’s contract, however, SBA OIG found that SBA carried forward the
problems with its initial RER contract by failing to properly assess the labor costs and other
direct costs necessary to carry out the contract to ensure that that the government was paying a
fair and reasonable price.111 Documents obtained by the Select Subcommittee show SBA’s
agreement with RER and the agency’s justification of its contract costs continued to be based on
an assessment of the cost per EIDL application recommendation without consideration of actual
labor costs required. SBA continued to assess the cost of the contract on this per loan basis even
though the Rapid loan recommendation system was automated and the COVID-19 EIDL contract
allowed that automated system to operate at scale with relatively little additional labor.112

Under the Trump Administration, SBA asserted that the approximately $41 per EIDL
application that SBA paid for automated loan recommendation services has been a reasonable
taxpayer value.113 Indeed, SBA assessed that its $750 million contract with RER “saved the
American taxpayer billions of dollars,” by comparing the rate SBA paid per COVID-19 EIDL
recommendation to the rate it paid at a much smaller scale for EIDL recommendations before the
pandemic.114 This method of assessing the reasonableness of the cost of the contract fails to
consider the reasonable costs that the contractor would actually incur by providing the service
paid for. Rapid’s loan recommendation system was automated, and documents obtained by the
Select Subcommittee show it processed each EIDL application in less than a second, with
processing continuing overnight with little or no human intervention.115 Although Rapid
employees did work to create the system, maintain it, and to make adjustments and solve
problems, essentially no labor was required to process each additional loan application through
Rapid’s system, but SBA paid RER and its subcontractors on a per application basis.116 The
Select Subcommittee obtained information that confirms SBA OIG’s assessment that SBA failed
to assess the labor costs required for the EIDL processing contract. As of March 2021, by which
time SBA had paid RER $740 million, RER, Rocket, and Rapid together had only employed 189
people in total who had worked on the contract in the previous year (including former employees
who worked for only part of this period).117

While there are costs other than labor incurred in creating an automated platform,
maintaining it, and paying third party data providers (for example, for credit and fraud check
services), SBA did not appear to consider these costs rigorously to ensure that the agency paid a
reasonable price for loan recommendation services. Documents obtained by the Select
Subcommittee show the third-party data fees Rapid’s system incurred when processing EIDL
applications were a small fraction of what SBA paid RER and its subcontractors. The credit risk
assessment, identity verification, fraud detection, public records search, bank account validation,
and email verification service fees for EIDL applications processed through February 2, 2021,
cost only $39 million, which was only 5 percent of the $738 million SBA paid RER through that
time.118 Moreover, SBA also paid a flat fee of at least $2.3 million each month—totaling more
than $25 million—in addition to the fixed fee per loan recommendation to cover other staffing,
data, and technology costs RER and its subcontractors might incur.119

RER, for its part, attempts to justify the reasonableness of its contract by comparing the

18
$41 per application processed that it received to the higher fees charged by banks for originating
Paycheck Protect Program loans and SBA’s costs for fulling processing loans in other, smaller
disasters.120 This comparison is faulty. RER wrongly equates the automated processing it and its
subcontractor Rapid provided—with no manual review of applications—to the full service
provided by a traditional bank originating loans and to SBA when it handled the full loan
evaluation, consideration, and approval process. The comparison is particularly inapt because
SBA expended significant additional resources beyond those included in RER’s contract to
employ approximately 8,000 loan officers, Team Leads, and other staffers (over 5,000 of whom
were SBA employees, with contract workers making up the remainder) to manually review EIDL
applications after they were processed by Rapid’s automated system.121 SBA spent hundreds of
millions of additional dollars internally to conduct the labor-intensive work of reviewing EIDL
applications after they were processed through Rapid’s automated system.122 These substantial
costs incurred to review EIDL applications after they were processed by Rapid’s system were
separately borne by SBA, not by RER or its subcontractors.

3. RER Received a Windfall of More Than $340 Million—After Paying Its
Subcontractors and Hard Costs—for the Work of Just Six Employees.

The breakdown of SBA funds received by RER, Rocket, and Rapid compared with the
resources expended by each firm clarifies the dramatic extent to which RER’s $750 million
contract far exceeded reasonable costs. RER subcontracted with Rocket, which further
subcontracted with Rapid. Evidence the Select Subcommittee obtained from these companies
makes clear that Rapid provided the vast majority of resources necessary to carry out SBA’s
contract but received only a fraction of the taxpayer funds paid for those services. Rocket and,
especially, RER consequently received a windfall in taxpayer dollars relative to their costs or
work rendered for the taxpayers.

Out of the $738 million SBA paid on its contract through February 2021, RER received
$357 million (48%), Rocket received $233 million (32%), and Rapid received $148 million
(20%).123 But Rapid employed 163 people working on the SBA contract (86 percent of all
contract personnel which contributed to contract), incurred $39 million in direct costs paid to
third party data providers associated with running fraud and other checks on EIDL applications
through its automated system, and provided its proprietary technology that Rocket asserted
Rapid spent nine years and nearly a million hours developing.124 The Select Subcommittee’s
review of email communications between SBA and the contractors shows extensive engagement
with Rapid employees surrounding the development and operation of the COVID-19 EIDL
recommendation system, usually without including any employees from prime contractor RER.

RER, by contrast, assigned only six employees to work on this contract for which it
pocketed $357 million after paying its subcontractors.125 RER also did not provide the complex
proprietary technology necessary for the contract’s execution or directly incur costs for third
party data services used by Rapid’s system. Instead, RER’s small staff assigned to work on this
contract largely performed “contractual administrative duties” like negotiating with SBA and
sending the agency invoices and data concerning the number of applications processed, and high
level “project management.”126 RER represented to the Select Subcommittee that it paid 51% of
the “hard costs” identified by Rocket on invoices for services including credit checks and other

19
third-party data, but these costs totaled only $31.7 million in the invoices RER produced.127
Subtracting RER’s share of the hard costs paid and payments to subcontractors, the company still
received more than $340 million for the work of six employees in less than a year.

Rocket identified only 20 employees who worked on the SBA contract through March
2021, for which it pocketed $233 million.128 The invoices Rocket received from Rapid show,
moreover, that Rapid paid the costs incurred through third party data providers (for services like
credit checks and fraud detection data) out of the $148 million Rapid received.129 The public
filings of Rocket’s parent company show that as Rocket received this windfall, its revenues
surged 15-fold, from less than $25 million in 2019 to more than $393 million in 2020.130 In
2021, with the large majority of the COVID-19 EIDL contract payments already paid out in the
prior year, Rocket’s revenue declined to $95 million.131 Rocket’s parent reported that the
company lost $200 million in income in 2021 “mainly as a result of a reduction in revenues
earned from processing economic injury disaster loans offered by the Small Business
Administration in response to the COVID-19 pandemic,” further demonstrating the enormous
revenue Rocket derived from the EIDL contract that it dedicated few employees to.132

20
Documents obtained by the Select Subcommittee also demonstrate that Rapid employees
conducted the large majority of detailed discussions with SBA about developing and operating
the automated EIDL processing and recommendation system.133 In one email, SBA staff raised
concerns with RER about the frequency of RER’s subcontractors direct communications with
SBA and demanded that RER assert its role as SBA’s prime contractor.134 Specifically, an SBA
procurement executive wrote to RER’s Chief Executive Officer that “RER Solutions is the prime
[contractor] and must assert its position as the prime – the subcontractors are running around
RER and communicating without regard to RER,” and also noted that Rapid employees were
holding meetings with SBA that changed agency directions without RER’s involvement.135
Federal Acquisition Regulations require that the prime contractor, not agency officials, manage
their subcontractors work, a provision that may have been violated by Rapid’s extensive direct
contacts with SBA officials without RER’s involvement.136

When the Select Subcommittee asked SBA staff about the apparent windfall of nearly
$350 million RER received while it assigned only six employees to the contract and its
subcontractor did most of the work required, SBA contracting staff responded that they
determined what mattered was the quality of the work not the just the number of employees
engaged.137 Yet they also stated that they did not have insight into the share of work performed
by each contractor and subcontractor, making it unclear, even if they were disbursing funds
based on work quality, which company should be given credit (and therefore money) for the
quality of which aspects of the work.138

SBA staff also cited the fact that RER was required to receive more than 50 percent of
federal contract funds—regardless of the amount of work the company performed relative to its
subcontractors—in order to comply with the federal acquisition regulations mentioned above
intended to prevent so-called “pass through” small business set aside contracts, where a large
firm receives the majority of the revenue.139 As a factual matter, this does appear to be correct,
and there is no emergency exception for circumstances where a catastrophic event requires an
agency to dramatically expand the contract on an emergency basis while the small business
contractor needs to rely on a large firm to handle the increased workload.140 (SBA regulations
do contain a minor exception to the 50 percent requirement for certain “direct costs,” which
explains why RER received slightly less that 50 percent of the contract’s total value).141

Yet the fact that SBA’s discretion was limited by this requirement is no defense of the
waste of taxpayer funds. This overpayment was foreseeable at the time of the initial decision in
2018 to award the contract to RER given agency officials’ knowledge that the company would
need to rely on one or more large subcontractors to perform the core loan recommendation
services even on the initial pre-pandemic contract, and would consequently need to rely on large
subcontractors even more heavily to fulfill an expanded contract to handle a surge in EIDL
applications following a catastrophe.142 SBA should have anticipated that in the event of such a
crisis, under the existing law, RER would likely reap a significant windfall in revenue even as
large firm subcontractors completed nearly all the necessary work. Yet the contract was awarded
anyway, and in the nearly eighteen months between the initial award and the onset of the
pandemic, SBA appears to have made no effort to prevent this wasteful outcome. In following
one regulation, SBA appears to have violated another: to obtain a “fair and reasonable price.”143

21
IV. RECOMMENDATIONS

A. SBA OIG Should Continue to Assess the Precise Extent of Fraud Committed
Against the COVID-19 EIDL Program.

SBA OIG previously identified tens of billions of dollars in EIDL funds approved in
response to applications containing serious fraud alerts and has identified other indicia of the
extent of fraud committed against the program including applications associated with identity
theft and returned loan statements. However, taxpayers still do not know the precise extent of
fraud committed against the program. In the coming year, most COVID-19 EIDL loans will start
to enter repayment, which will offer an opportunity for SBA and SBA OIG to accurately assess
the full extent of fraud in the loan portion of the program. Identifying the amount of fraud
committed against the EIDL program is vital both to efforts to recover taxpayer dollars and to
avoiding fraud vulnerabilities in future emergencies. SBA and SBA OIG should also continue to
refer instances of fraud identified with evidence of who perpetrated the fraud to DOJ for
prosecution and/or civil actions to recover taxpayer funds or use SBA’s own authority to bring
civil actions to recover taxpayer funds.

B. SBA Should Identify All COVID-19 EIDL Applications Approved Early in
the Trump Administration’s Implementation of the Program that Contained
Serious Identity Theft Fraud Alerts in Order to Aid in Relieving Identity
Theft Victims From Fraudulently Incurred Debts.

Identity theft was a significant source of fraud committed against the EIDL program and
is a method of fraud that jeopardizes the credit and financial standing of individuals whose
identities were stolen. SBA has indicated that in 2021 it set up a process for handling identity
theft complaints, including by releasing victims from liability and referring cases to law
enforcement.144 To aid these efforts, SBA should identify all approved EIDL loans that
contained fraud alerts suggestive of possible identity theft before SBA updated its guidance to
loan reviewers in June 2020 to require action to verify applicants’ identities.

C. In Future Noncompetitive Contracts for Automated Technological Services,
SBA Should Consider the Labor and Other Costs Actually Necessary to
Provide the Services Required.

SBA assessed the reasonableness of the cost of its contract with RER for automated
EIDL application processing and recommendation services based on the cost of processing each
application without considering the relatively small labor and non-labor costs actually required to
fulfill the contract. This led to a contract award that resulted in RER receiving over $340 million
for the work of only six employees and Rocket receiving $233 million for the work of only 20
employees, as a third company, Rapid, provided the processing system, paid a significant share
of the costs and employed the large majority of employees working to fulfill the contract. In
future contracts, particularly those that include automated technological services, SBA should
include an assessment of the actual costs contractors will incur in providing the solicited services
to ensure that taxpayers pay reasonable and fair price.

22
1
Select Subcommittee on the Coronavirus Crisis, Press Release: Clyburn and Velázquez Ramp up
Investigation into SBA Loan Program Plagued by Fraud (Feb. 11, 2021) (online at
https://coronavirus.house.gov/news/press-releases/clyburn-and-vel-zquez-ramp-investigation-sba-loan-program-
plagued-fraud); Select Subcommittee on the Coronavirus Crisis, Press Release: Chairs Launch Investigation into
$500 Million Contract in SBA Emergency Loan Program Plagued by Errors and Delays (July 30, 2020) (online at
https://coronavirus.house.gov/news/press-releases/chairs-launch-investigation-500-million-contract-sba-emergency-
loan-program).
2
Memorandum from Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis,
The Biden Administration’s Efforts to Root Out Fraud in Pandemic Relief Programs and Bring Wrongdoers to
Justice (June 13, 2022) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/The%20Biden%20Administration%27s%
20Efforts%20to%20Root%20Out%20Fraud%20in%20Pandemic%20Relief%20Programs%20and%20Bring%20Wr
ongdoers%20to%20Justice.pdf); Small Business Administration, Office of Inspector General, Inspection of Small
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020)
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from
Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis, Lowering the Guardrails: How
the Trump Administration Failed to Prevent Billions in Pandemic Small Business Fraud (Mar. 25, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-03-25%20Staff%20Memo%20-
%20Small%20Business%20Fraud.pdf).
3
15 U.S.C. § 636; 13 C.F.R. § 123.5 (2022).
4
Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation
Services (Oct. 4, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).
5
Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation
Services (Oct. 4, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).
6
Id.
7
Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf).
8
Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation
Services (Oct. 4, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).
9
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (July 9, 2021); 48 C.F.R. § 19.502-2.
10
Small Business Administration, Solicitation/Contract/Order for Commercial Items (Dec. 14, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Briefing by Staff, Small Business Administration,
to Staff, Select Subcommittee on the Coronavirus Crisis (July 9, 2021).
11
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Small Business Administration, Solicitation/Contract/Order for
Commercial Items (Dec. 14, 2018) (online at

23
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf).
12
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
13
RER Solutions Inc., Excerpt of Subcontract Agreement (Apr. 1, 2019) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Solutions%20Inc.%20Excerpt%
20of%20Subcontract%20Agreement_Redacted.pdf); Small Business Administration, Office of Inspector General,
Evaluation of SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf); Rocket Loans, Our Loans (online
at www.rocketloans.com/) (accessed May 27, 2022); Rocket Companies, Inc., Press Release: Rocket Companies
Announces Fourth Quarter and Full Year 2021 Results (Feb. 24, 2022) (online at www.prnewswire.com/news-
releases/rocket-companies-announces-fourth-quarter-and-full-year-2021-results-
301490108.html#:~:text=Full%20Year%20Financial%20Highlights&text=Generated%20total%20revenue%2C%20
net%20of%20%2412.9%20billion%20and%20Adjusted%20Revenue,on%20sale%20margin%20of%203.13%25).
14
Contractor Performance Assessment Report, RER Solutions, Inc. (July 7, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20306%20prior%20contract%20as
sessment_Redacted.pdf).
15
Contractor Performance Assessment Report, RER Solutions, Inc. (July 1, 2015) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20309%20prior%20contract%20as
sess_Redacted.pdf).
16
Rocket Companies, Securities and Exchange Commission Form 10-K (Mar. 1, 2022) (online at
https://ir.rocketcompanies.com/financials/sec-filings/default.aspx).
17
Id.
18
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
19
Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf).
20
Id.
21
Coronavirus Preparedness and Response Supplemental Appropriations Act, Pub. L. No. 116-123 (2020);
Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136, (2020); Paycheck Protection Program and
Health Care Enhancement Act, Pub. L. 116-139 (2020); Consolidated Appropriations Act, 2021, Pub. L. 116-260
(2020); American Rescue Plan Act, Pub. L. No. 117-2 (2021).
22
Small Business Administration Office of Inspector General, Inspection of Small Business
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
23
Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136 (2020).
24
Coronavirus Preparedness and Response Supplemental Appropriations Act, Pub. L. No. 116-123 (2020);
Coronavirus Aid, Relief, and Economic Security Act; Pub. L. 116-136, (2020); Paycheck Protection Program and
Health Care Enhancement Act, Pub. L. 116-139 (2020); Consolidated Appropriations Act, 2021, Pub. L. 116-260
(2020); American Rescue Plan Act, Pub. L. No. 117-2 (2021).
25
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Government Accountability Office, Economic Injury Disaster Loan
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf).
24
26
Small Business Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL
Advances, Supplemental Targeted Advances (Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-
04/COVID-19%20EIDL%20TA%20STA_04282022_Public-508.pdf); As Pandemic Aid Was Rushed to Main
Street, Criminals Seized on Covid Relief Programs, CNBC (Apr. 15, 2021) (online at
www.cnbc.com/2021/04/15/as-pandemic-aid-was-rushed-to-main-street-criminals-seized-on-ppp-eidl-.html);
Government Accountability Office, COVID-19 Loans: SBA Has Begun to Take Steps to Improve Oversight and
Fraud Risk Management (Apr. 20, 2021) (GAO-21-498T) (online at www.gao.gov/products/gao-21-498t).
27
Small Business Administration, Disaster Assistance Update EIDL Advance (July 15, 2020) (online at
www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-19%20Advance%207.15.20-508.pdf); Small Business
Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL Advances, Supplemental
Targeted Advances (Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-04/COVID-
19%20EIDL%20TA%20STA_04282022_Public-508.pdf); Targeted advances were $10,000 grants available to
small businesses in low-income communities that saw more than a 30% reduction in revenue for an eight-week or
longer period during the pandemic, and supplemental targeted advances were $5,000 additional grants available to
businesses in low-income areas that saw a more than 50% economic loss for an eight-week period during the
pandemic. Small Business Administration, About Targeted EIDL Advance and Supplemental Targeted Advance
(online at www.sba.gov/funding-programs/loans/covid-19-relief-options/covid-19-economic-injury-disaster-
loan/about-targeted-eidl-advance-supplemental-targeted-advance) (accessed June 9, 2022).
28
Small Business Administration, Office of Inspector General, Inspection of Small Business
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Email from Chief Executive
Officer, RER Solutions, Inc., to Senior Loan Officer, Small Business Administration (Mar. 20, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf).
29
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf); Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov.
24, 2020) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf).
30
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Government Accountability Office, Economic Injury Disaster Loan
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); Email from Chief Executive Officer, RER
Solutions, Inc., to Senior Loan Officer, Small Business Administration (Mar. 20, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf).
31
USASpending, Contract Summary RER Solutions, Inc. (online at
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20,
2022); Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020) (online
at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf).
32
Id.
33
Coronavirus Contracts Tracking Federal Purchases to Fight the Coronavirus, ProPublica (online at
https://projects.propublica.org/coronavirus-contracts/contracts) (accessed May 19, 2022); In 2021, SBA modestly
increased the ceiling on the COVID-19 EIDL contract to $800 million, but as of SBA OIG’s recent report only
slightly more than $750 million had actually been paid to RER and its subcontractors. USASpending, Contract
Summary RER Solutions, Inc. (online at
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20,
2022); Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
25
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
34
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions Needed
to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Evaluation of
SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf).
35
Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis
(Mar. 3, 2021); Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf).
36
Rapid Financial Services, LLC, Rapid Decision Release Note (May 6, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20Decision%20Release%20Note
%205.6.2020.pdf); Decision Logic, How It Works (online at www.decisionlogic.com/HowItWorks.aspx) (accessed
May 19, 2022).
37
Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the
Coronavirus Crisis (Mar. 3, 2021)
38
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
39
Id.; Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (Feb. 2, 2022).
40
Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis
(Mar. 3, 2021); Screenshot of Rapid Loan Officer Portal, Briefing by Rapid Financial Services, LLC, to Staff, Select
Subcommittee on the Coronavirus Crisis (Mar. 3, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Screenshot%20Loan%20Officer%20Porta
l%2C%20Sumary%20%26%20Fraud%20Badge.pdf).
41
Briefing by Rapid Financial Services, LLC, to Staff, Select Subcommittee on the Coronavirus Crisis
(Mar. 3, 2021); Screenshot of E-Tran Overview, Briefing by Rapid Financial Services, LLC, to Staff, Select
Subcommittee on the Coronavirus Crisis (Mar. 3, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Screenshot%20%20E-
Tran%20Diagram.pdf).
42
Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf); Letter from
Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and
Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf).
43
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
44
Id.
26
45
SBA dramatically increased its number processing staff and contractors at a salary range that suggests the
costs were hundreds of millions of dollars. Government Accountability Office, Economic Injury Disaster Loan
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); USAJOBS, Loan Specialist (General) –
Virtual, Small Business Administration, Office of Disaster Assistance (ODA) Processing and Disbursement Center
(PDC) (online at www.usajobs.gov/job/563879000) (accessed May 20, 2022).
46
Government Accountability Office, Small Business Administration: Actions Needed to Improve
COVID-19 Loans' Internal Controls and Reduce Their Susceptibility to Fraud (Mar. 24, 2021) (GAO-21-472T)
(online at www.gao.gov/products/gao-21-472t); Small Business Administration, Office of Inspector General,
Inspection of Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic
(Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Select
Subcommittee on the Coronavirus Crisis, Hearing on Rooting Out Fraud in Small Business Relief Programs (Mar.
25, 2021) (online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-rooting-out-
fraud-small-business-relief-programs).
47
Project on Government Oversight, “A Disaster”: Small Business Administration Scrambling to Stop
Pandemic Loan Fraud (Sept. 9, 2020) (online at www.pogo.org/investigation/2020/09/a-disaster-small-business-
administration-scrambling-to-stop-pandemic-loan-fraud).
48
Select Subcommittee on the Coronavirus Crisis, Press Release: Chairs Launch Investigation into $500
Million Contract in SBA Emergency Loan Program Plagued by Errors and Delays (July 30, 2020) (online at
https://coronavirus.house.gov/news/press-releases/chairs-launch-investigation-500-million-contract-sba-emergency-
loan-program).
49
Select Subcommittee on the Coronavirus Crisis, Press Release: Clyburn and Velázquez Ramp up
Investigation into SBA Loan Program Plagued by Fraud (Feb. 11, 2021) (online at
https://coronavirus.house.gov/news/press-releases/clyburn-and-vel-zquez-ramp-investigation-sba-loan-program-
plagued-fraud ); Select Subcommittee on the Coronavirus Crisis, Press Release: Chairs Clyburn and Velázquez
Seek Key Disaster Loan Program Documents Withheld by Trump Administration (May 11, 2021) (online at
https://coronavirus.house.gov/news/press-releases/chairs-clyburn-and-vel-zquez-seek-key-disaster-loan-program-
documents-withheld).
50
Id.
51
Select Subcommittee on the Coronavirus Crisis, Hearing on Rooting Out Fraud in Small Business Relief
Programs (Mar. 25, 2021) (online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-
rooting-out-fraud-small-business-relief-programs).
52
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
53
Memorandum from Majority Staff to Members of the Select Subcommittee on the Coronavirus Crisis,
The Biden Administration’s Efforts to Root Out Fraud in Pandemic Relief Programs and Bring Wrongdoers to
Justice (June 13, 2022) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/The%20Biden%20Administration%27s%
20Efforts%20to%20Root%20Out%20Fraud%20in%20Pandemic%20Relief%20Programs%20and%20Bring%20Wr
ongdoers%20to%20Justice.pdf); Small Business Administration, Office of Inspector General, Inspection of Small
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020)
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from
Majority Staff to Members of the Select Subcommittee on the Coronavirus, Lowering the Guardrails: How the
Trump Administration Failed to Prevent Billions in Pandemic Small Business Fraud (Mar. 25, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-03-25%20Staff%20Memo%20-
%20Small%20Business%20Fraud.pdf).
54
Select Subcommittee on the Coronavirus Crisis, Testimony of Inspector General Hannibal “Mike” Ware,
Small Business Administration, Hearing on Rooting Out Fraud in Small Business Relief Programs (Mar. 25, 2021)
(online at https://coronavirus.house.gov/subcommittee-activity/hearings/remote-hearing-rooting-out-fraud-small-
business-relief-programs).
27
55
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
56
Small Business Administration, SBA’s Handling of Identity Theft in the COVID-19 Economic Injury
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).
57
Small Business Administration, Office of Inspector General, SBA’s Emergency EIDL Grants to Sole
Proprietors and Independent Contractors (Oct. 7, 2021) (online at www.sba.gov/sites/default/files/2021-
10/SBA%20OIG%20Report%2022-01%20.pdf).
58
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Inspection of
Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020)
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
59
Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business
Administration (Mar. 30, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf); Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on
the Coronavirus Crisis (Feb. 2, 2022).
60
Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business
Administration (Mar. 30, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf).
61
Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small Business
Administration (Mar. 30, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted.pdf); Small Business Administration, Office of Inspector General, Inspection of Small
Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020)
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
62
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
63
Small Business Administration, Office of Inspector General, Inspection of Small Business
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
64
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (Feb. 2, 2022).
65
SBA did curtail its use of batch approval in August 2020 after SBA OIG issued a critical report on EIDL
fraud, but 3.3 million EIDLs had already been approved by this time. Small Business Administration, Office of
Inspector General, Inspection of Small Business Administration’s Initial Disaster Assistance Response to the
Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf). As of June 10, 2021, SBA data shows that 3.8 million EIDL
applications had been approved in total. Data provided to the Select Subcommittee by Rapid shows that as of June
11, 2021, approximately 2.2 million applications had been approved following a recommendation for manual
review, and approximately 1.6 million applications had been recommended directly to SBA Team Leads for
approval, indicating that all or almost all applications sent directly to Team Leads for batch approval were ultimately
approved. Small Business Administration, Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL
Advances, Supplemental Targeted Advances (June 10, 2021) (online at www.sba.gov/sites/default/files/2021-
06/COVID-19%20EIDL%20TA%20STA_6.10.2021_Public-508_0.pdf); Email from Counsel, Rapid Financial
Services LLC, to Staff, Select Subcommittee on the Coronavirus Crisis (June 23, 2021) (online at

28
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Counsel%20for%20Rapid%20t
o%20SSCC%20Staff_Redacted.pdf).
66
Email from Counsel, Rapid Financial Services LLC, to Staff, Select Subcommittee on the Coronavirus
Crisis (June 23, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Counsel%20for%20Rapid%20t
o%20SSCC%20Staff_Redacted.pdf).
67
Small Business Administration, Office of Inspector General, Inspection of Small Business
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf); Memorandum from Director,
Office of Grants Management, Small Business Administration, to Chief Financial Officer, Small Business
Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar.
11, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); One SBA staff member told the Select Subcommittee that, to their recollection,
applications with fraud flags were not included in batches, but this conflicts with the memorandum to provided to
SBA’s contractor and subcontractors to implement the batch policy, the findings of the SBA OIG, and the
representations made to the Select Subcommittee by RER Solutions about the instructions it received regarding the
rules for inclusion in batches. Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on
the Coronavirus Crisis (Feb. 2, 2022).
68
Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf).
69
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (Feb. 2, 2022).
70
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
71
Memorandum from Director, Office of Grants Management, Small Business Administration, to Chief
Financial Officer, Small Business Administration, Authorization for Payments from RER Solutions (Apr. 7, 2020)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Memorandum%204.7.20%20fraud%20in
dicators_Redacted.pdf); Government Accountability Office, Economic Injury Disaster Loan Program: Additional
Actions Needed to Improve Communication With Applicants and Address Fraud Risks (July 2021) (GAO-21-589)
(online at www.gao.gov/assets/gao-21-589.pdf).
72
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (July 29, 2021).
73
Small Business Administration, SBA’s Handling of Identity Theft in the COVID-19 Economic Injury
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).
74
Small Business Administration, SBA Rapid Decision Reference Guide (May 15, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
205.15.20_Redacted.pdf).
75
Id.
76
Small Business Administration, Disaster Assistance Update Nationwide EIDL Loans (June 12, 2020)
(online at www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-19%20Loan%206.12.20-508_0.pdf); Small
29
Business Administration, SBA Rapid Decision Reference Guide (June 12, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
206.12.20_Redacted.pdf).
77
Small Business Administration, SBA Rapid Decision Reference Guide (April 20, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
204.20.21_Redacted.pdf).
78
Project on Government Oversight, “A Disaster”: Small Business Administration Scrambling to Stop
Pandemic Loan Fraud (Sept. 9, 2020) (online at www.pogo.org/investigation/2020/09/a-disaster-small-business-
administration-scrambling-to-stop-pandemic-loan-fraud).
79
Small Business Administration, Office of the Inspector General, Inspection of Small Business
Administration’s Initial Disaster Response to Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
80
Complaint, United States v. Nobbe, No. 1:20-MJ-3236 (S.D. Fla. July 24, 2020), ECF No. 1; Complaint,
United States v. One, No. 0:20-MJ-6325 (S.D. Fla. Aug. 6, 2020), ECF No. 1; Indictment, United States v. Lewis,
No. 1:20-CR-3361 (M.D.N.C. Aug. 8, 2020), ECF No. 1; Complaint, United States v. Casutt, No. 2:20-MJ-666
(D. Nev. Aug. 10, 2020), ECF No. 1; Affidavit, United States v. Redfern, No. 1:20-MJ-256 (M.D.N.C. Aug. 25,
2020), ECF No. 2; Complaint, United States v. Stanley, et al., No. 1:20-MJ-3470 (S.D. Fla. Aug. 26, 2020), ECF
No. 3; Information, United States v. Horner, No. 4:21-CR-00242 (M.D. Pa. Aug. 31, 2021), ECF No. 1; Complaint,
United States v. Lavanture, No. 1:20-MJ-452 (N.D.N.Y. Sept. 9, 2020), ECF No. 1; Complaint and Affidavit,
United States v. Trapp, No. 1:20-MJ-915 (E.D.N.Y. Oct. 6, 2020), ECF No. 1; Complaint, United States v.
Carpenter, et al., No. 2:20-CR-179 (W.D. Tenn. Oct. 6, 2020), ECF No. 1; Complaint, United States v. Hsu, No.
2:20-MJ-691 (W.D. Wash. Oct. 26, 2020), ECF No. 1; Complaint, United States v. Ayvazyan, et al., No. 2:20-CR-
579 (C.D. Cal. Nov. 3, 2020), ECF No. 1; Indictment, United States v. Williams, No. 1:20-CR-105 (S.D. Ga. Nov. 5,
2020), ECF No. 1; Indictment, United States v. Nelson, et al., No. 1:20-CR-103 (S.D. Ga. Nov. 5, 2020), ECF No. 1;
Indictment, United States v. Plummer, No. 1:20-CR-106 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United
States v. Coleman, No. 1:20-CR-107 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United States v. Mack, No.
1:20-CR-104 (S.D. Ga. Nov. 5, 2020), ECF No. 1; Indictment, United States v. Williams, No. 1:20-CR-109 (S.D.
Ga. Nov. 19, 2020), ECF No.1; Indictment, United States v. Jones, No. 3:20-CR-30073 (C.D. Ill. Dec. 2, 2020),
ECF No. 1; Indictment, United States v. Garrido-Baez, No. 3:20-CR-30072 (C.D. Ill. Dec. 2, 2020), ECF No. 1;
Complaint, United States v. Kanyike, No. 2:20-MJ-5936 (C.D. Cal. Dec. 8, 2020), ECF No.1; Indictment, United
States v. Jones, No. 3:20-CR-438 (W.D.N.C. Dec. 16, 2020), ECF No. 1; Indictment, United States v. Smith, No. 20-
CR-922 (N.D. Ill. Dec. 17, 2020), ECF No. 1; Complaint, United States v. Cruz, No. 1:21-CR-10019 (D. Mass. Dec.
18, 2020), ECF No. 4; Complaint, United States v. Clawson, No. 3:20-MJ-294 (D. Or. Dec. 21, 2020), ECF No. 1;
Complaint, United States v. Unitan, No. 3:20-MJ-293 (D. Or. Dec. 21, 2020), ECF No. 1; Complaint, United States
v. Caraballo, No. 1:21-MJ-2014 (S.D. Fla. Jan. 6, 2021), ECF No. 1; Affidavit, United States v. Pape, et al.,
No. 5:21-MJ-0007 (E.D. Tex. Jan. 12, 2021), ECF No. 2; Complaint, United States v. Oworae, No. 4:21-MJ-4014
(D. Mass. Jan. 20, 2021), ECF No. 1; Complaint, United States v. Burden, No. 4:21-MJ-70194 (N.D. Cal. Feb. 3,
2021), ECF No. 1; Indictment, United States v. Bolen, No. 3:21-CR-30013 (C.D. Ill. Feb. 3, 2021), ECF No. 1;
Indictment, United States v. Prioleau, No. 3:21-CR-49-MOC (W.D.N.C. Feb. 17, 2021), ECF No. 1; Indictment,
United States v. Clifron, No. 3:21-CR-46 (W.D.N.C. Feb. 17, 2021), ECF No. 1; Information, United States v.
Kirkland, No. 6:21-CR-2 (S.D. Ga. Feb. 19, 2021), ECF No. 1; Indictment, United States v. Bella, No. 1:21-CR-31
(W.D.N.Y. Feb. 23, 2021), ECF No. 1; Complaint, United States v. Cordor, No. 4:21-CR-40016 (D. Mass. Mar. 4,
2021), ECF No. 4; Complaint, United States v. Spierdowis, No. 1:21-MJ-1074 (D. Mass. Mar. 4, 2021), ECF No. 1;
First Superseding Indictment, United States v. Grigoryan, et al., No. 2:20-CR-579 (C.D. Cal. Mar. 9, 2021), ECF
No. 154; Indictment, United States v. Kornaker, No. 1:21-CR-37 (W.D.N.Y. Mar. 10, 2021), ECF No. 13;
Indictment, United States v. Fiege, No. 0:21-CR-55-MJD-LIB (D. Minn. Mar. 11, 2021), ECF No. 1; Indictment,
United States v. Lawson, et al., No. 3:21-CR-6 (N.D. Ga. Mar. 16, 2021), ECF No. 1; Complaint, United States v.
Ayers, et al., No. 7:21-MJ-3110 (S.D.N.Y. Mar. 23, 2021), ECF No. 2; Complaint, United States v. Hannah,
No. 2:21-9168 (D.N.J. Mar. 23, 2021), ECF No. 1; Complaint, United States v. Venant, No. 8:21-MJ-1295 (M.D.
Fla. Mar. 26, 2021), ECF No. 1; Complaint, United States v. Kwak, et al., No. 1:21-CR-199 (N.D. Ga. Apr. 1, 2021),
ECF No. 1; Affidavit, United States v. Brooks, No. 8:21-MJ-695 (D. Md. Apr. 2, 2021), ECF No. 2; Complaint,
United States v. Onah, No. 3:21-MJ-191 (N.D.N.Y. Apr. 2, 2021), ECF No. 1; Indictment, United States v. Isbaih,
No. 1:21-CR-208 (N.D. Ill. Apr. 5, 2021), ECF No. 1; Indictment, United States v. Bella, et al., No. 1:21-CR-247
(S.D.N.Y. Apr. 14, 2021), ECF No. 3; Indictment, United States v. Hilaire, No. 1:21-CR-39WES-PAS (D.R.I. Apr.
30
16, 2021), ECF No. 1; Complaint, United States v. Zimmerman, No. 2:21-MJ-8050 (D.N.J. Apr. 21, 2021), ECF
No. 1; Indictment, United States v. Pounds, et al., No. 5:21-CR-317-PAB (N.D. Ohio Apr. 29, 2021), ECF No. 1;
Complaint, United States v. Bennett, et al., No. 1:21-MJ-7102 (D.N.J. May 14, 2021), ECF No. 1; Indictment,
United States v. Taylor, No. 3:21-CR-132-FDW (W.D.N.C. May 18, 2021), ECF No. 3; Indictment, United States v.
Foreman, et al., No. 1:21-CR-165 (D. Colo. May 18, 2021), ECF No. 1; Indictment, United States v. Lysne,
No. 3:21-CR-167 (D. Or. May 19, 2021), ECF No. 1; Complaint, United States v. Hannesyan, No. 2:21-CR-284
(C.D. Cal. May 24, 2021), ECF No. 1; Information, United States v. Lain, No. 1:21-CR-175 (D. Colo. May 26,
2021), ECF No. 1; Indictment, United States v. Aquino, No. 1:21-CR-144 (E.D. Cal. May 27, 2021), ECF No. 1;
Indictment, United States v. Vaughn, No. 6:21-CR-34 (E.D. Ky. May 27, 2021), ECF No. 1; Indictment, United
States v. Cherry, No. 4:20-CR-27 (E.D. Mich. May 29, 2021), ECF No. 1; Complaint, United States v. Klasinc,
No. 1:21-CR-5835 (S.D.N.Y. June 5, 2021), ECF No. 1; Indictment, United States v. Ahiekpor, No. 2:20-CR-00094
(S.D. Ohio June 23, 2020), ECF No. 22; Complaint, United States v. Sanay, et al., No. 1:21-MJ-668 (E.D.N.Y. June
8, 2021), ECF No. 1; Information, United States v. Zaghab, No. 21-CR-188 (D. Colo. June 8, 2021), ECF No. 1;
Information, United States v. Carter, No. 1:21-CR-204 (D. Md. June 9, 2021), ECF No. 1; Indictment, United States
v. Porch, et al., No. 4:21-CR-23 (M.D. Ga. June 9, 2021), ECF No. 1; Information, United States v. Bush, No. 3:21-
CR-74 (E.D. Tenn. June 10, 2021), ECF No. 1; Information, United States v. Grubb, No. 1:21-CR-175 (M.D. Pa.
June 22, 2021), ECF No. 1; Indictment, United States v. Soto, No. 1:21-CR-49-CFC (D. Del. July 6, 2021), ECF
No. 2; Indictment, United States v. Miller, No. 1:21-CR-10228-FDS (D. Mass. July 7, 2021), ECF No. 9;
Indictment, United States v. Bolte, No. 1:21-CR-46-SPW (D. Mont. July 8, 2021), ECF No. 2; Indictment, United
States v. Henson, et al., No. 2:21-CR-601DJH (D. Ariz. Aug. 3, 2021), ECF No. 3; Complaint, United States v.
Mansouri, No. 1:21-MJ-5143 (W.D.N.Y. Aug. 3, 2021), ECF No. 1; Indictment, United States v. Eldabbagh,
No. 1:21-CR-523 (D.D.C. Aug. 17, 2021), ECF No. 1; Indictment, United States v. Bruey, et al., No. 2:21-CR-74
(M.D. Fla. Aug. 25, 2021), ECF No. 3; Information, United States v. Curry, No. 1:21-CR-20415 (S.D. Fla. Aug. 5,
2021), ECF No. 1; Information, United States v. Savath, No. 1:21-CR-10269 (D. Mass. Sept. 13, 2021), ECF No. 1;
Indictment, United States v. Capps, No. 6:21-CR-10073 (D. Kan. Sept. 8, 2021), ECF No. 1; Information, United
States v. Howell, No. 3:21-CR-00109 (E.D. Tenn. Aug. 18, 2021), ECF No. 1; Complaint, United States v. Larkins,
No. 21-8190 (D.N.J. Sept. 15, 2021), ECF No. 1; Information, United States v. Blackman, No. 2:21-CR-00724
(D.N.J. Sept. 16, 2021), ECF No. 55; Complaint, United States v. Okeke, et al., No. 1:21-MJ-1092 (E.D.N.Y. Sept.
23, 2021), ECF No. 1; Indictment, United States v. Jones, No. 2:21-CR-00417 (W.D. Pa. Sept. 28, 2021), ECF No.
3; Information, United States v. Cavanaugh, No. 2:21-CR-00155 (D. Me. Sept. 29, 2021), ECF No. 1; Complaint,
United States v. Carter, et al., No. 21-MJ-9734 (S.D.N.Y Oct. 14, 2021), ECF No. 1; Indictment, United States v.
Knight, No. 2:21-CR-00043 (S.D. Ga. Oct. 5, 2021), ECF No. 3; Indictment, United States v. Casey, No. 1:20-CR-
10202 (D. Mass. Sept. 23, 2021), ECF No. 1; Indictment, United States v. Levons, No. 3:21-CR-00340 (M.D. Pa.
Nov. 2, 2021), ECF No. 1; Indictment, United States v. Sparks, et al., No. 2:21-CR-00189-JLR (W.D. Wash. Nov.
10, 2021), ECF No. 1; Complaint, United States v. Kaeding, No. 1:21-MJ-04220 (S.D. Fla. Nov. 17, 2021), ECF No.
1; Complaint, United States v. Shibley, No. 2:20-MJ-00385-MLP (W.D. Wash. June 29, 2020), ECF No. 1;
Complaint, United States v. Osborne, No. 2:21-CR-00456 (E.D. Pa. Nov. 23, 2021), ECF No. 1; Complaint, United
States v. Kantar, No. 2:21-MJ-02124 (W.D. Pa. Nov. 30, 2021), ECF No. 1; Third Superseding Indictment, United
States v. Greenberg, No. 20-CR-00097 (M.D. Fla. Mar. 31, 2021), ECF No. 90; Indictment, United States v. Ilori,
No. 1:21-cr-00746 (S.D.N.Y. Dec. 8, 2021), ECF No. 6; Indictment, United States v. Encarnacion, No. 2:21-mj-
13427 (D.N.J. Dec. 13, 2021), ECF No. 1; Information, United States v. Saintvil, No. 1:21-cr-00013 (N.D. Fla.
March 23, 2021), ECF No. 1; Complaint, United States v. Lloyd, No. 6:21-mj-00001 (D. Or. Jan. 5, 2021), ECF No.
1; Superseding Information, United States v. Fernandez, No. 1:21-cr-10046 (D. Mass. July 9, 2021), ECF No. 37;
Information, United States v. Dorsey, No. 8:21-cr-00370 (D.S.C. Sept. 16, 2021), ECF No. 1; Information, United
States v. Thornton, No. 6:21-cr-00098 (M.D. Fla. Jan. 19, 2021), ECF No. 1; Information, United States v. Eustache,
No. 6:21-cr-00098 (M.D. Fla. July 8, 2021), ECF No. 1; Indictment, United States v. Tifekchian, No. 3:21-cr-00244
(D. Or. July 13, 2021), ECF No. 1; Complaint, United States v. Laventure, No. 1:20-cr-00290 (N.D.N.Y. Mar. 3,
2020), ECF No. 1; Complaint, United States v Darius, No. 2:22-mj-10018 (D.N.J. Jan. 25, 2022), ECF No. 1;
Complaint, United States v. Garcias, No. 2:21-mj-09344 (D.N.J June 23, 2021), ECF. No. 1; Affidavit in Support of
Complaint, United States v. Phillips, No. 1:21-mj-03581 (D. Md. Dec. 22, 2021), ECF No. 2; Information, United
States v. Rivera, No. 1:22-cr-20028 (S.D. Fla. Jan. 28, 2022), ECF No. 1; Complaint, United States v. Budamala,
No. 2:22-cr-00077 (C.D. Cal. Feb. 24, 2022), ECF No. 1; Complaint, United States v. Schoepflin et al., No. 2:22-cr-
00121 (C.D. Cal Apr. 1, 2022), ECF No. 1; Indictment, United States v. Rickerson, No. 5:22-cr-00013 (W.D.N.C
Mar. 5, 2022), ECF No. 3; Indictment, United States v. Hutchins, No. 1:22-cr-00042 (W.D.N.Y Mar. 24, 2022), ECF
No. 1; Complaint, United States v. Daniel Tisone, No. 2:22-cr-00038 (M.D. Fla. Mar. 30, 2022), ECF No. 3;

31
Indictment, United States v. Rybin, No. 4:22-cr-00056 (S.D. Ga. Apr. 14, 2022), ECF No. 1; Indictment, United
States v. Israyelyan, No. 2:21-cr-00425 (C.D. Cal. Sept. 10, 2021), ECF No. 1.
81
111 of the 117 DOJ prosecutions for EIDL fraud involved applications submitted in the first five months
of the program under the Trump Administration.
82
Small Business Administration, Disaster Assistance Update Nationwide EIDL Loans (Feb. 1, 2021)
(online at www.sba.gov/sites/default/files/2021-02/EIDL%20COVID-
19%20Loan%20%20Approvals%20by%20State%2002.01.2021_FOIA-508_0.pdf); Small Business Administration,
Disaster Assistance Update Nationwide COVID EIDL, Targeted EIDL Advances, Supplemental Targeted Advances
(Apr. 28, 2022) (online at www.sba.gov/sites/default/files/2022-04/COVID-
19%20EIDL%20TA%20STA_04282022_Public-508.pdf).
83
Small Business Administration, Office of the Inspector General, Serious Concerns of Potential Fraud in
EIDL Program Pertaining to the Response to COVID-19 (July 28, 2020) (online at www.sba.gov/document/report-
20-16-serious-concerns-potential-fraud-eidl-program-pertaining-response-covid-19); Small Business
Administration, Office of the Inspector General, Inspection of Small Business Administration’s Initial Disaster
Response to Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf).
84
Government Accountability Office, SBA Has Begun to Take Steps to Improve Oversight and Fraud Risk
Management (Apr. 20, 2021) (GAO-21-498T) (online at https://gao.gov/assets/gao-21-498t.pdf); Small Business
Administration, Office of the Inspector General, Top Management and Performance Challenges Facing the Small
Business Administration Fiscal Year 2022 (Oct. 15, 2021) (online at www.sba.gov/sites/default/files/2021-
10/SBA%20OIG%20Report%2022-02.pdf).
85
See, e.g., Complaint, United States v. Casutt, No. 2:20-MJ-666-BNW (D. Nev. Aug. 10, 2020), ECF
No. 1; Complaint, United States v. Williams, No. 1:20-CR-00109-JRH-BKE (S.D. Ga. Nov. 19, 2020), ECF No. 1;
Complaint, United States v. Jones, No. 3:20CR438 (W.D.N.C. Dec. 16, 2020), ECF No. 1; Complaint, United States
v. Smith, No. 20CR922 (N.D. Ill. Dec. 17, 2020), ECF No. 1.
86
See, e.g., Complaint, United States v. Mack, No. 1:20-CR-00104-DHB-BKE (S.D. Ga. Nov. 5, 2020),
ECF No. 1; Complaint, United States v. Unitan, No. 3:20-MJ-00293 (D. Ore. Dec. 21, 2020), ECF No. 1;
Complaint, United States v. Zimmerman, No. 2:21-MJ-08050-JSA (D.N.J. Apr. 21, 2021), ECF No. 1; Complaint,
United States v. Miller, No. 1:21-CR-10228-FDS (D. Mass. July 27, 2021), ECF No. 1.
87
See, e.g., Complaint, United States v. Pape, et al., No. 5:21-MJ-00007-CMC (E.D. Tex. Jan. 12, 2021),
ECF No. 1; Complaint, United States v. Lawson, et al., No. 3:21-CR-00006-TCB-RGV (N.D. Ga. Mar. 16, 2021),
ECF No. 1; Complaint, United States v. Pounds, et al., No. 5:21-CR-00317-PAB (N.D. Ohio Apr. 29, 2021), ECF
No. 1.
88
Only about a quarter of the DOJ fraud cases involved EIDLs obtained for real, operational businesses
that subsequently misused EIDL funds or that inflated revenue and employee numbers to obtain larger awards than
they were eligible for.
89
Small Business Administration, SBA Rapid Decision Reference Guide (May 15, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
205.15.20_Redacted.pdf); Small Business Administration, SBA Rapid Decision Reference Guide (Apr. 20, 2021)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/SBA%20Rapid%20Decision%20Guide%
204.20.21_Redacted.pdf).
90
Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation
Services (Oct. 4, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).
91
Small Business Administration, Solicitation 73351018R0010, Data Analysis and Loan Recommendation
Services (Oct. 4, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%2073351018R0010%2C%20
Data%20Analysis%20and%20Loan%20Recommendation_Redacted%23.pdf).
32
92
Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf).
93
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (July 9, 2021); 48 C.F.R. § 19.502-2.
94
Small Business Administration, Solicitation/Contract/Order for Commercial Items (Dec. 14, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Briefing by Staff, Small Business Administration,
to Staff, Select Subcommittee on the Coronavirus Crisis (July 9, 2021).
95
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
96
Contractor Performance Assessment Reports, RER Solutions, Inc. (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Contractor%20Assessment%20
Reports%20all%20produced_Redacted.pdf).
97
RER Solutions, Inc., Excerpt of Subcontract Agreement (Apr. 1, 2019) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Solutions%20Inc.%20Excerpt%
20of%20Subcontract%20Agreement_Redacted.pdf); Small Business Administration, Office of Inspector General,
Evaluation of SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf); Rocket Companies, Securities
and Exchange Commission Form 10-K (Mar. 1, 2022) (online at https://ir.rocketcompanies.com/financials/sec-
filings/default.aspx); Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for
Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf).
98
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
99
Small Business Administration, Office of Inspector General, Inspection of Small Business
Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at
www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
100
Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted.pdf); Small Business
Administration, Office of Inspector General, Inspection of Small Business Administration’s Initial Disaster
Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020) (online at www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-02.pdf).
101
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf); Small Business Administration, Office of Inspector General, Inspection of
Small Business Administration’s Initial Disaster Assistance Response to the Coronavirus Pandemic (Oct. 28, 2020)
(online at www.sba.gov/sites/default/files/2020-10/SBA%20OIG%20Report%2021-02.pdf).
102
Small Business Administration, Amendment of Solicitation Questions and Answers (Sept. 24, 2018)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20Q
uestions%20and%20Answers%20SBA%20B08_73351018R0010_Amend_Redacted%20%23.pdf ); Small Business
Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster Assistance Loan
Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); 48 C.F.R. § 19.502-2.
33
103
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
104
Id.
105
Id.
106
15 U.S.C. § 657s; 13 C.F.R. § 125.6.
107
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf); Email from Chief Executive Officer, RER Solutions, Inc., to Senior
Loan Officer, Small Business Administration (Mar. 20, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20CEO%20Email%20SBA%203.2
0.20_Redacted.pdf).
108
In 2021, SBA modestly increased the contract’s ceiling to $800 million to complete COVID EIDL
processing services. USASpending, Contract Summary RER Solutions, Inc. (online at
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20,
2022). Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
109
Coronavirus Contracts Tracking Federal Purchases to Fight the Coronavirus, ProPublica (online at
https://projects.propublica.org/coronavirus-contracts/contracts) (accessed May 19, 2022); USASpending, Contract
Summary RER Solutions, Inc. (online at
www.usaspending.gov/award/CONT_AWD_73351020F0071_7300_73351019D0001_7300) (accessed May 20,
2022).
110
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (July 9, 2021).
111
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
112
Small Business Administration, Contractor Performance Assessment Report (Oct. 29, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Contractor%20Performance%20Assessm
ent%20Report%20RER%20EIDL_Redacted.pdf); Small Business Administration, Solicitation/Contract/Order for
Commercial Items (Dec. 14, 2018) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Solicitation%20Contract%20Order%20fo
r%20Commercial%20Items%2012.14.2018_Redacted%23.pdf); Small Business Administration, Amendment of
Solicitation/Modification of Contract (May 15, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf).
113
Small Business Administration, Contractor Performance Assessment Report (Oct. 29, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Contractor%20Performance%20Assessm
ent%20Report%20RER%20EIDL_Redacted.pdf).
114
Id.
115
Email from Chief Technology Officer, Rapid Financial Services, LLC, to Chief Executive Officer, RER
Solutions, Inc. (Apr. 13, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20Rapid%20CTO%20to%20RER
%20CEO%204.13.20_Redacted.pdf).
116
Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf); Letter from
34
Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and
Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf).
117
Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 11, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); Letter from Counsel, Rapid Financial Services, LLC, to Chairman James E.
Clyburn, Select Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small
Business (Mar. 7, 2021) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2021-
03-07%20Rapid%20Finance%20Letter%20highlighted.pdf); Rocket Loans Specific Responses to Committees’
Document Requests (Feb. 25, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Exhibit%20A%20-
%20Rocket%20Loans%20Response%20to%20Subcommittee%202.25.2021%20Rocket%2020%20employees.pdf).
118
Email from Counsel, RER Solutions, Inc., to Staff, Select Subcommittee on the Coronavirus Crisis (July
2, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20from%20Cousel%20RER%20t
o%20SSCC%207.2.21_Redacted.pdf).
119
Small Business Administration, Amendment of Solicitation/Modification of Contract (May 15, 2020)
(online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Amendment%20of%20Solicitation%20M
odification%20of%20Contract%203.29.20%2066.67%20dollars%20per%20rec_Redacte%23.pdf).
120
Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf).
121
Government Accountability Office, Economic Injury Disaster Loan Program: Additional Actions
Needed to Improve Communication with Applicants and Address Fraud Risks (July 2021) (GAO-21-589) (online at
www.gao.gov/assets/gao-21-589.pdf).
122
SBA dramatically increased its number processing staff and contractors at a salary range that suggests
the costs were hundreds of millions of dollars. Government Accountability Office, Economic Injury Disaster Loan
Program: Additional Actions Needed to Improve Communication with Applicants and Address Fraud Risks (July
2021) (GAO-21-589) (online at www.gao.gov/assets/gao-21-589.pdf); USAJOBS, Loan Specialist (General) –
Virtual, Small Business Administration, Office of Disaster Assistance (ODA) Processing and Disbursement Center
(PDC) (online at www.usajobs.gov/job/563879000) (accessed May 20, 2022).
123
The precise numbers, based on invoices and information provided by the companies are a total of
$738,294,057.09 paid by SBA to RER, with $232,931,265.65 paid to and kept by Rocket, and $148,024,480.79 paid
to Rapid. Cite all invoices and Rapid’s 3.7.21 letter. RER Solutions, Inc. Invoices to SBA Office of Disaster
Assistance, Contract 73351019D0001 (May 11, 2020 - Feb. 1, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf).
124
Letter from Counsel, Rapid Financial Services, LLC, to Chairman James E. Clyburn, Select
Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar.
7, 2021) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2021-03-
07%20Rapid%20Finance%20Letter%20highlighted.pdf); Letter from Counsel, Rocket Loans, to Chairman James E.
Clyburn, Select Subcommittee on the Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small

35
Business (Nov. 24, 2020) (online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-
11-24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf).
125
RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract 73351019D0001 (May 11,
2020 - Feb. 1, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf); Letter from Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Mar. 11, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Letter%20Counsel%20RER%20to%20Ch
airman%203.11.21_Redacted.pdf); Small Business Administration, Office of Inspector General, Evaluation of
SBA’s Contract for Disaster Assistance Loan Recommendations Services (Apr. 14, 2022) (online at
www.sba.gov/sites/default/files/2022-04/SBA%20OIG%20Report%2022-10.pdf).
126
Letter from Counsel, Rocket Loans, to Chairman James E. Clyburn, Select Subcommittee on the
Coronavirus Crisis, and Chairwoman Nydia Velazquez, Committee on Small Business (Nov. 24, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-11-
24%20Rocket%20Ltr%20to%20Committees%20from%20Rocket%20Loans%20highlighted.pdf); Letter from
Counsel, RER Solutions, Inc., to Chairman James E. Clyburn, Select Subcommittee on the Coronavirus Crisis, and
Chairwoman Nydia Velazquez, Committee on Small Business (Oct. 2, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/2020-10-
02%20Ltr%20N%20Eggleston%20to%20Chairpersons%20and%20Committee%20Members%20-
%20signed%20highlighted.pdf).
127
Rapid, as a subcontractor to subcontractor Rocket, sent its invoices to Rocket. Rocket then sent its
invoices to RER. Consequently the “hard costs” in Rocket’s invoices to RER duplicate third party processing fees
that were actually paid by Rapid. Email from Counsel, RER Solutions, Inc., to Staff, Select Subcommittee on the
Coronavirus Crisis (July 2, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Email%20from%20Cousel%20RER%20t
o%20SSCC%207.2.21_Redacted.pdf); RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract
73351019D0001 (May 11, 2020 - Feb. 1, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf).
128
After repeated requests that Rocket identify the number of employees that contributed to its work on the
COVID-19 EIDL contract, Rocket stated that “at least” 20 employees contributed and included its executives (who
presumably divided their time substantially between the SBA contract and other company matters) in the list of
identified employees. The Select Subcommittee sees no indication in the documents produced that significantly
more than 20 Rocket employees contributed, and the company’s inability to identify other employees beyond those
20 strongly suggest any additional employees who worked on the COVID-19 EIDL contract did not make
significant contributions. Rocket Loans Specific Responses to Committees’ Document Requests (Feb. 25, 2021)
(online at https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Exhibit%20A%20-
%20Rocket%20Loans%20Response%20to%20Subcommittee%202.25.2021%20Rocket%2020%20employees.pdf).
129
RER Solutions, Inc. Invoices to SBA Office of Disaster Assistance, Contract 73351019D0001 (May 11,
2020 - Feb. 1, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rocket Loans Invoices to RER Solutions, Inc., Task Order 2 (May 11, 2020 - Feb. 4, 2021) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/RER%20Rocket%20invoices%20redacte
d.pdf); Rapid Financial Services, LLC Invoices to Rocket Loans (July 2, 2020 - Feb. 2, 2021) (online at

36
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rocket%20and%20Rapid%20Invoices_R
edacted.pdf).
130
Rocket Companies, Securities and Exchange Commission Form 10-K (Mar. 1, 2022) (online at
https://ir.rocketcompanies.com/financials/sec-filings/default.aspx).
131
Id.
132
Id.
133
See, e.g., Email from Chief Technology Officer, Rapid Financial Services, LLC, to Staff, Small
Business Administration (Mar. 30, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/Rapid%20CTO%20to%20Rivera%20SB
A%203.30.20_Redacted%20%23.pdf).
134
Chief Executive Officer, RER Solutions, Inc., to Senior Procurement Executive and Head of the
Contracting Activity, Office of the Chief Financial Officer, Small Business Administration (Apr. 22, 2020) (online
at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/cricizing%20RER%20asking%20it%20as
sert%20that%20it%20is%20the%20prime%201.27.2022.set%205%2027-29_Redacted.pdf).
135
Id.
136
F.A.R. Part 42.02(e)(2); Chief Executive Officer, RER Solutions, Inc., to Senior Procurement Executive
and Head of the Contracting Activity, Office of the Chief Financial Officer, Small Business Administration (Apr.
22, 2020) (online at
https://coronavirus.house.gov/sites/democrats.coronavirus.house.gov/files/cricizing%20RER%20asking%20it%20as
sert%20that%20it%20is%20the%20prime%201.27.2022.set%205%2027-29_Redacted.pdf).
137
Briefing by Staff, Small Business Administration, to Staff, Select Subcommittee on the Coronavirus
Crisis (July 9, 2021).
138
Id.
139
Id.; 13 C.F.R. § 125.6.
140
15 U.S.C. § 657s; 13 C.F.R. § 125.6.
141
13 C.F.R. § 125.6.
142
Small Business Administration, Office of Inspector General, Evaluation of SBA’s Contract for Disaster
Assistance Loan Recommendations Services (Apr. 14, 2022) (online at www.sba.gov/sites/default/files/2022-
04/SBA%20OIG%20Report%2022-10.pdf).
143
F.A.R. Part 15.402.
144
Small Business Administration, SBA’s Handling of Identity Theft In the COVID-19 Economic Injury
Disaster Loan Program (May 6, 2021) (online at www.sba.gov/sites/default/files/2021-
05/SBA%20OIG%20%20Report%2021-15.pdf).

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