Sba Final Decision

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Exhibit A
SBA FINAL DECISION
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United States
Small Business Administration
Office of Hearings and Appeals

Paycheck Protection Program Appeal of:
Twinco, Inc.
Appellant
Appealed from:
SBA PPP Loan Number 5046657206
Issued:  January 24 , 2023
Docket No. PPP- 5046657206

Appearances:
For the Appellant: Ryan Espegard, Attorney
For the Small Business Administration: Jayson Pang, Attorney

Decision
1. Introduction and Jurisdiction
Twinco, Inc. (Twinco or Appellant) submitted SBA Form 2483, Paycheck Protection Program
Borrower Application (“the Application”) dated April 7, 2020. (AR 153-54).
Subsequently, PPP loan number 5046657206 (“the Loan”) was disbursed to Twinco by the
Lender on or about April 30, 2020, in the amount of $332,863.62. (AR 35).
On July 22, 2021, Twinco executed a Paycheck Protection Program PPP Loan Forgiveness
Application Form 3508EZ requesting forgiveness for the full amount of the Loan. (AR 155).
On or about October 21, 2022, the SBA issued its Final Loan Review Decision (FLRD)
denying forgiveness of the Loan.  Loan Decision (Dkt. 02) (AR 15- 16).  It is this decision that Twinco
has appealed.
On November 18, 2022, Twinco filed an appeal asking the Office of Hearings and Appeals
(OHA) reverse the SBA’s decision and find that Twinco is eligible for the PPP loan disbursed and its
forgiveness. (Appeal Petition Dkt. 1).
On November 29, 2022, OHA issued the Order. (Dkt. 4). The Administrative Record (“AR”)
was filed by the SBA on December 17, 2022. (Dkt. 5). Twinco filed an Objection to Administrative
Record December 26, 2022. (Dkt. 6).
OHA conducts PPP appeals under the authority of 13 C.F.R. part 134 Subpart L. (13 C.F.R. §
134.1201 et seq.)
2. Factual Background
A. Twinco’s Loan Application and Request for Loan Forgiveness
On March 27, 2020, the Coronavirus Aid, Recovery and Economic Security Act (CARES Act)
became law, giving businesses the opportunity to apply for potentially forgivable loans through the
PPP. P.L.116-136 (March 27, 2020).  As a result, Twinco applied for and received a loan in the amount
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of $332,863.62, for which it asked for forgiveness.
B. Twinco’s Appeal and the SBA’s Response
The FLRD denied forgiveness of the loan and stated:
“After review of the documentation provided, the SBA concludes that,
the Borrower or any owner of the Borrower, was suspended, debarred,
proposed for debarment, declared ineligible, or voluntarily excluded
from participation by a Federal department or agency within the past
three years.
To be eligible for a PPP loan, by submitting the loan application the
Borrower certifies that neither the Applicant or any owner of the
Applicant have within the past three years been: (a) debarred,
suspended, declared ineligible or voluntarily excluded from
participation in a transaction by any Federal Agency; (b) formally
proposed for debarment, with a final determination still pending; (c)
indicted, convicted, or had a civil judgment rendered against you for any
of the offenses listed in the regulations or (d) delinquent on any amounts
owed to the U.S. Government or its instrumentalities as of the date of
execution of this Certification.
Principal Jasmel Sing Singha with SS# ending in 9526 a 51% owner
of Twinco, Inc. was reported on SAM.gov due to a notice of
suspension issued on February 16, 2018. The Office of Credit Risk
Management confirms the suspension was terminated as of July 19,
2022. The borrower is confirmed to be ineligible since they were
suspended within 3 years of the application date of April 7, 2020.
Additionally, the suspension was in place at the time of the application.”
Emphasis added.
On November 18, 2022, Twinco submitted an Appeal Petition.  It later submitted a Reply on
January 19, 2023, in reply to SBA’s Response filed on January 10, 2023.
Twinco stated it is a corporation that operates several Wendy’s restaurant franchise locations
in Washington State. Twinco is owned by Jasmel Sangha and Susheel Sangha.  Noting that the SBA
previously withdrew another FLRD regarding the same loan, it asserts that the indefinite suspension
violates regulations governing suspension and debarment, violates due process, is clearly erroneous
and should be reversed.
Twinco acknowledged that the SBA issued a Notice of Suspension to Jasmel Sangha on
February 16, 2018.  The Notice of Suspension explained that it was because Jasmel Sangha was facing
pending criminal charges and that it was temporary in nature. Those charges were resolved when
Sangha pleaded guilty to a misdemeanor and the corresponding Judgment and Sentence was entered
on June 22, 2018.
Twinco asserts that the SBA’s temporary suspension was supposed to terminate on that date,
with the SBA then having the option to pursue debarment if it felt debarment was appropriate. The
SBA did not pursue debarment.
Jasmel Sangha did not inform Susheel Sangha or Tanveer Sangha of the Notice of Suspension
when he was managing Twinco. Susheel Sangha and Tanveer Sangha first learned of the suspension
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after Jasmel Sangha’s stroke and during the appeal of the Original Decision.
Twinco argues that its suspension should have ended on its own when a criminal case was
concluded in June 2018, without any action on its part, i.e., the suspension was self-executing once
the judgement was entered concluding the case.  It further stated that “[i]f legal proceedings were not
initiated, ‘a suspension may not exceed 12 months.’” 2 CFR 180.760(a). In other words, without the
legal proceedings that concluded in June 2018, the suspension would necessarily have terminated in
12 months after the date of the suspension, or by February 16, 2019. Thus, either way, the suspension
was terminated pursuant 2 CFR 180.760 prior to the Application’s submission in April 2020.
It then argues that the SBA never proposed debarment and never provided Sangha the
corresponding minimum due process associated with the proceedings. In lieu of debarment, the SBA
apparently maintained an indefinite suspension in violation of OMB guidelines and without due
process. Had debarment been proposed and Sangha given due process, then Sangha would have
presented evidence and argument resulting in any debarment concluding prior to the April 2020
application. Sangha’s wrongdoing was limited to a single occasion, which was promptly corrected by
Sangha without any loss to the government. He also took responsibility with a guilty plea to a
misdemeanor and promptly completed his required community service.
The SBA, in its Response, notes that Twinco’s “Appeal Petition adequately recounts the
events that gave rise to Jasmel Sangha (“Sangha”), a 51% owner of Appellant, being suspended via
the Notice of Suspension to Jasmel Sangha on February 16, 2018.”
The Notice of Suspension states, in part,
You, Jasmel Singh Sangha, face a number of charges listed in the
attached Criminal Information. Specifically, you were charged in the
State of Washington with the intent to deprive another of property,
wrongfully obtaining such property belonging to Bank of the West and
SBA by color of aid of deception (RCW 9A.56.020(1)). You were also
specifica11y charged in the State of Washington with the appropriation
of lost and misdelivered property with value that did exceed $5,000,
such property belonging to Bank of the West and SBA (RCW
9A.56.030). These actions are grounds for suspension from
participation in federal government programs.
Emphasis added.  Suspension Letter – Ex. C - Dkt 3, Ex A - Dkt 6.  Furthermore, not only had Sangha
been suspended, Twinco had as well.
Sangha was convicted of Attempted Theft In the Second Degree on June 22, 2018. Judgement
and Sentence, Non-Felony, Ex. D - Dkt 3, Ex B - Dkt 6.
On July 19, 2022, SBA issued a Notice of Termination of Suspension. AR 331, Exhibit J Dkt
3.  The termination applied to Sangha, Twinco, Inc., Sangha Top Hat LLC, and Jus Liquor LLC.
The SBA sets forth the suspension framework:
Executive Order 12549, the basis for the subject certifications in Form
2483, was issued with the intent to “curb fraud, waste, and abuse in
Federal programs, increase agency accountability and ensure
consistency among agency regulations concerning debarment and
suspension of participants in Federal programs[.]” Exec. Order No.
12549, 51 FR 6370 (Feb. 18, 1986).
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Loans and loan guarantees are considered covered transactions and the
principals and participants in those transactions are subject to the
prohibitions therein. 2 C.F.R. § 180.970. Pursuant to 2 C.F.R. Part
2700.10, SBA has adopted the guidance in Part 180 as regulation. The
purpose of the non-procurement debarment and suspension system is to
protect the public interest and ensure the integrity of the federal
government by conducting business only with responsible persons. 2
C.F.R. § 180.125.
The SBA highlights the fact that in the Paycheck Protection Program Borrower Application
Form includes the self-certification question No. 1 that stated:
Is the Applicant or any owner of the Applicant presently suspended,
debarred, proposed for debarment, declared ineligible, voluntarily
excluded from participation in this transaction by any Federal
department or agency, or presently involved in any bankruptcy?
In its application for the PPP Loan, Appellant responded “No” to question No. 1. (AR 153). In
addition, by submitting the PPP loan application, Twinco certified, consistent with EO 12549, that the
owner of Appellant was not debarred, suspended, declared ineligible or voluntary excluded from
participation in a transaction by any Federal agency.
The SBA argues that the Notice of Suspension did not provide an expiration date.  Nor was
there a basis for inferring an expiration date from the mere criminal judgment.
Furthermore, SBA asserts that, even if SBA should have ended the suspension earlier, it did
not do so, and the answer to the Question 1 was false.  That alone is fatal to forgiveness.
The SBA points out there is no basis for understanding that the criminal proceedings did not
conclude until the satisfaction of judgment was filed on July 13, 2022, even though a conviction was
entered June 22, 2018, well after the date of the loan application.
At the time of the loan application (April 2, 2020), approximately two years and two months
had passed since the Notice of Suspension had been issued (February 16, 2018). Appellant provided
no documents that would support suspension having been terminated prior to the date of the loan
application.  The satisfaction of the criminal judgment was not filed until July 13, 2022, and SBA did
not issue a notice of termination of the suspension until July 29, 2022.
Finally, because Sangha was suspended and a 51% owner of Twinco, Twinco was ineligible
for the PPP loan.
Twinco filed a rebuttal and asserted it was essentially unlawful to have an “indefinite
suspension.”  It further claims that an SBA “3-year rule” for suspension duration is not authorized by
issuance of a regulation.  The three-year language cited by the SBA is contained in the last page of the
instructions, but not on the application itself. Additionally, the instructions do not state any
consequence for a suspension occurring in the prior three years. While claiming a certification is being
made, there is no language stating that a prior suspension in the preceding three years makes an
applicant ineligible.
Twinco cites “2 CFR §180.760(a) provides that a temporary suspension ‘may continue until
the conclusion of those proceedings,’” and argues that the proceedings ended on the sentencing date,
not the Satisfaction of Judgment entered in 2022.
Finally, Twinco argues that the term of the suspension is governed by 2 CFR §180.760, which
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answers the question “How long will my suspension last?” The rule is clear that a temporary
suspension “may continue until the conclusion of those proceedings.” 2 CFR §180.760(a) (emphasis
added). The only reasonable interpretation of this rule is that suspensions end upon the conclusion of
the proceedings on which they are based.  Twinco highlights “until” to support the end date.  It further
claims that placing the burden of lifting a suspension on Twinco is arbitrary and capricious.
3. Discussion
A. Applicable Law and Policy
1) Standard of Review
Twinco has the burden of proving all elements of the appeal. Specifically, Twinco must prove
that the SBA Final Loan Review Decision is based upon a clear error of fact or law. 13 C.F.R. §
134.1210.
2) Scope of OHA and ALJ Decisions
As an independent office of the SBA, OHA has limited authority and jurisdiction to review
decisions made by the SBA. Acting within the bounds of that authority and jurisdiction,
Administrative Law Judges or Administrative Judges do not have the authority to invalidate a
regulation or interpretation issued by the SBA Administrator. See Matter of Cognitive Professional
Services, Inc., Case No. BDPE-545 at *3 (March 10, 2015) (“[OHA] is not the proper forum for a
challenge to the validity of a regulation”); Family Choice Financial, Docket No. PPP-8323747201, at
12 (ALJs are “exercising the Administrator’s delegated authority and it would be surprising if that
delegation included the authority to invalidate an SBA regulation”); Auth. of Educ. Dep’t Admin. L.
Judges in Conducting Hearings, 14 U.S. Op. Off. Legal Counsel 1, 2–3 (1990), 1990 WL 750326, at
*1–2 (“ALJs are bound by all policy directives and rules promulgated by their agency, including the
agency’s interpretations of those policies and rules”).1
Given that limited authority, regulations issued by the SBA Administrator are binding on
OHA, and OHA is not the forum for challenges to the SBA’s regulations or interpretation of
Congressional acts. Any such challenges are more properly made, if at all, in federal court. Id.
3) The CARES Act and PPP Loans
As noted above, in March 2020, in response to the COVID-19 pandemic and the resulting
economic conditions, Congress passed the Coronavirus Aid, Relief and Economic Security Act
(CARES Act), Pub. L 116-136, 134 Stat. 281 (2020). Section 1102 of the Act established the Paycheck
Protection Program, which was “intended to help businesses cover expenses and make payroll for their
workers to keep them employed during the pandemic” by loaning money to eligible small businesses
through verified lenders. If those loans met certain conditions, they would be forgiven through funding
from the SBA. Congress placed the PPP under Section 7(a) of the Small Business Act, making the
SBA the agency entrusted to administer the Program. See CARES Act section 1102(a) (adding
Paragraph (36) to 15 U.S.C.§ 636(a)).
Under the CARES Act, the SBA was granted Emergency Rulemaking Authority under Section
1114, requiring that:
Not later than 15 days after the date of enactment of this Act the
Administrator shall issue regulations to carry out this title and the
amendments made by this title without regard to the notice requirements

1 Available at https://www.justice.gov/file/20131/download (last accessed June 2, 2022).
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under section 553(b) of title 5, United States Code.
(Emphasis added). Subsection (b) of section 553 requires that “General notice of proposed rulemaking
shall be published in the Federal Register . . .) (emphasis added).  Section 1114 of the CARES Act
waived the requirement for SBA’s rules and regulations pertaining to the Cares Act to be published
first in the Federal Register before they could become effective. Thus, the First Interim Final Rule at
85 FR 20811 was effective without publication in the Federal Register and was issued for the
immediate implementation of the PPP through publication on SBA’s and Treasury’s websites on April
2, 2020.  Consequently, publication of the rule in the Federal Register was not required.
4) PPP Loan Eligibility
The PPP is directed at small businesses and its principal function is to provide potentially
forgivable loans to them. See 15 USC § 636(a)(36)(D)(I). The PPP loans are made under the same
terms, conditions, and processes as other SBA loans, although the scope of allowable borrowers was
expanded for PPP loans to generally include sole proprietorships, independent contractors, non-profit
organizations, and other specified businesses, if they were operating “small” business of not more
than 500 employees. 15 USC § 636(a)(36)(B) and 15 USC § 636(a) (36)(D).
Not all such businesses, however, are eligible for PPP loans. The statute also provides that
“the [SBA] Administrator may guarantee covered loans under the same terms, conditions, and
processes as a loan made under this subsection.” 15 USC § 636(a)(36)(B). Ineligible types of
businesses are identified in 13 CFR § 120.110. These ineligible businesses include, for example, non-
profit businesses; passive businesses owned by developers and landlords that do not actively use or
occupy the assets acquired or improved with the loan proceeds (except Eligible Passive Companies
under § 120.1112); financial businesses primarily engaged in the business of lending, such as banks,
finance companies, and factors; life insurance companies; pyramid sale distribution plans; businesses
deriving more than one-third of gross annual revenue from legal gambling activities; businesses
engaged in any illegal activity; businesses with an Associate who is incarcerated, on probation, on
parole, or has been indicted for a felony or a crime of moral turpitude; businesses that have previously
defaulted on a Federal loan or Federally assisted financing; businesses owned or controlled by an
applicant or any of its Associates which previously owned, operated, or controlled a business which
defaulted on a Federal loan. 13 CFR §120.110.
Additionally, there are limitations that preclude some individuals from receiving PPP loans
or being a participant in receiving a PPP loan. Thus, for example, persons suspended or “debarred”
under the SBA or Government-wide debarment regulations may not conduct business with SBA. 13
CFR §103.2(b). Individuals are precluded if they recently were convicted of or had a civil judgment
rendered against them for commission of fraud or a criminal offense in connection with a public
transaction or contract, violation of Federal or State antitrust statutes or commission of
embezzlement, theft, forgery, bribery, falsification, or destruction of records, making false
statements, or receiving stolen property. Executive Order 12549, 13 CFR part 145. Also, if a
borrower or 20% or more owner of a borrower is presently involved in a bankruptcy proceeding, the
borrower is ineligible for a PPP loan. SBA Form 2483-SD or SBA Form 2483-SD-C; FAQ issued
April 9, 2021.
On the Paycheck Protection Program application, an applicant must certify that:

2 “An Eligible Passive Company must use loan proceeds only to acquire or lease, and/or improve or renovate, real or
personal property (including eligible refinancing), that it leases to one or more Operating Companies for conducting
the Operating Company's business, or to finance a change of ownership between the existing owners of the Eligible
Passive Company.” 120 CFR 120.111. Emphasis added.
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The information provided in this application and the information
provided in all supporting documents and forms is true and accurate in
all material respects. I understand that knowingly making a false
statement to obtain a guaranteed loan from SBA is punishable under the
law, including under 18 U.S.C. 1001 and 3571 by imprisonment of not
more than five years and/or a fine of up to $250,000; under 15 U.S.C.
645 by imprisonment of not more than two years and/or a fine of not
more than $5,000; and, if submitted to a federally insured institution,
under 18 U.S.C.1014 by imprisonment of not more than thirty years
and/or a fine of not more than $1,000,000.
85 CFR 20814.
Furthermore,
If SBA determines in the course of its review that the borrower was
ineligible for the PPP loan based on the provisions of the CARES Act,
SBA rules or guidance available at the time of the borrower’s loan
application, or the terms of the borrower’s PPP loan application (for
example, because the borrower lacked an adequate basis for the
certifications that it made in its PPP loan application), the loan will
not be eligible for loan forgiveness.
Emphasis added.  85 CFR 33005.
The regulatory provision regarding the length of a suspension states as follows:
§ 180.760 How long may my suspension last?
(a) If legal or debarment proceedings are initiated at the time of, or
during your suspension, the suspension may continue until the
conclusion of those proceedings. However, if proceedings are not
initiated, a suspension may not exceed 12 months.
(b) The suspending official may extend the 12 month limit under
paragraph (a) of this section for an additional 6 months if an office of a
U.S. Assistant Attorney General, U.S. Attorney, or other responsible
prosecuting official requests an extension in writing. In no event may a
suspension exceed 18 months without initiating proceedings under
paragraph (a) of this section.
(c) The suspending official must notify the appropriate officials under
paragraph (b) of this section of an impending termination of a
suspension at least 30 days before the 12 month period expires to allow
the officials an opportunity to request an extension.
Emphasis added.  2 CFR 180.760.
B. Application of Law
The SBA Final Loan Review Decision must be reversed if it contains clear error of fact or law
material to the decision.  The central issue is whether Twinco’s partial owner was subject to a
suspension which rendered it ineligible for a PPP loan and, if so, ineligible for forgiveness of such
loan.
The threshold question is whether Twinco was under suspension at the time of the PPP
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application.  Twinco must show that the SBA made a clear error in this fact.  There is nothing in the
record to show that the suspension issued to Twinco was actively terminated by the SBA until its
action on  July 19, 2022.  Therefore, when Twinco answered “No” in the application form to the
question as to whether it is “presently suspended . . . from participation in this transaction by any
Federal department or agency . . . .” its answer was false only if the suspension expired by operation
of law.
Twinco asserts the more fundamental question is whether the SBA erred in not terminating the
suspension well before July 2022, claiming it had no authority to extend the suspension out as long as
it did.  Twinco has asserted it ended with the entry of a guilty plea in June 2018.  It cites 2 CFR
§180.760(a) as providing that a temporary suspension “may continue until the conclusion of those
proceedings.”
The suspension and debarment structure envisions that a government agency, upon learning of
a party’s misdeeds, may initiate a suspension to immediately stop such party from further business
with the federal government.  2 CFR §180.760(a) addresses the question as to “How long may my
suspension last?”  The “suspension may continue until the conclusion of” “legal or debarment
proceedings.”
If one assumes that the proceeding against Sangha ended in dropping the charges or a not guilty
verdict, then if that were the only basis for the suspension (i. e., no debarment or other charges
pending), then the suspension would end on that date, unless extended pursuant to 2 CFR 180.760(b)
for another 6 months “if an office of a U.S. Assistant Attorney General, U.S. Attorney, or other
responsible prosecuting official requests an extension in writing.”  However, even under that
extension, the suspension would not exceed 18 months without initiating proceedings (further
prosecution or debarment).
In this case, the criminal case concluded in June 2018 with a conviction.  The SBA took no
affirmative action to end the suspension, however, more importantly, it did not extend the suspension
for an additional 6 months under 2 CFR 180.760(b) by obtaining a prosecuting official request for an
extension or initiating any other “legal or debarment proceedings.”
Further enlightenment as to the suspension structure is the fact that in absence of initiating a
proceeding, “a suspension may not exceed 12 months.”  2 CFR 180.760(b).
The statute thus makes clear that the February 2018 suspension could not extend beyond 12
months unless the SBA either (1) initiated debarment proceedings or (2) obtained a 6-month extension
from a prosecuting official.  Neither of these occurred.  Nor did the SBA initiate a new suspension for
other reasons.
However, while Twinco’s owner was not under suspension at the time of the application, he
was within 3 years of the PPP application and that status made Twinco ineligible for a PPP loan.
Twinco asserts there is no regulatory authority for the 3-year rule.  This is SBA’s policy and
interpretation of its applicable law and regulations.  Administrative Law Judges or Administrative
Judges do not have the authority to invalidate a regulation or interpretation issued by the SBA
Administrator. See Matter of Cognitive Professional Services, Inc., Case No. BDPE-545 at *3 (March
10, 2015).
The following statement is contained in the PPP application:
Debarment and Suspension Executive Order 12549; (2 CFR Part 180
and Part 2700) – By submitting this loan application, you certify that
neither the Applicant or any owner of the Applicant have within the
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past three years been: (a) debarred, suspended, declared ineligible or
voluntarily excluded from participation in a transaction by any
Federal Agency; (b) formally proposed for debarment, with a final
determination still pending; (c) indicted, convicted, or had a civil
judgment rendered against you for any of the offenses listed in the
regulations or (d) delinquent on any amounts owed to the U.S.
Government or its instrumentalities as of the date of execution of this
certification.
Emphasis added.
Based on the foregoing, I conclude that the SBA did not make a clear error of fact or law in
concluding that Twinco’s owner was under suspension within 3 years of filing its PPP application and
thus was ineligible for a PPP loan and its forgiveness.
C. Conclusion
Twinco must prove that the SBA Final Loan Review Decision is based upon a clear error of
fact or law. 13 C.F.R. § 134.1210.  It has not done so.
After reviewing the record and for the reasons set forth above, I DENY Twinco, Inc.’s appeal,
and AFFIRM the determination of the Small Business Administration in the Final Loan Review
Decision (FLRD).
Neither initial nor final decisions rendered by SBA’s Office of Hearings and Appeals (OHA)
under this subpart are precedential. 13 C.F.R. § 134.1212. This is an initial agency decision.
However, unless a request for reconsideration is filed pursuant to 13 C.F.R. section
134.1211(c)(1), or unless the SBA Administrator elects to review this decision per 13 C.F.R. section
134.1211(d), this decision shall become the final agency decision of SBA 30 calendar days after its
service. 13 C.F.R. § 134.1211. In accordance with the regulations, a party may file a request for
reconsideration within 10 calendar days after service of this decision under 13 C.F.R. section
134.1211(c)(1). See PPP procedural rule. The requesting party may serve its petition via email to
OHAPPPinquiries@sba.gov. It is each party’s responsibility to review applicable rules and
procedures. 13 C.F.R. 134.1211 (c)(1). A request for reconsideration must clearly show an error of
fact or law material to the initial decision. 13 C.F.R. § 134.1211(c)(1).

                                     _______________________
H. Scott Williams
Administrative Judge
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