The Harvard Club of Boston Agrees to Pay $2.4 Million to Resolve Allegations of PPP Loan Fraud

Summary

A press release of USAO - Massachusetts, published January 15, 2026, announces that The Harvard Club of Boston, a private club not formally affiliated with Harvard University, has agreed to pay approximately $2.4 million to resolve allegations that it violated the False Claims Act by obtaining a Paycheck Protection Program (PPP) loan for which it was not eligible. As detailed in the settlement agreement, the club admits that on May 4, 2021, it applied for and certified eligibility for a first draw PPP loan, and later sought and received forgiveness of the full amount. The release says the qui tam case is captioned United States ex rel. Foster. v. Harvard Club of Boston, No. 25-cv-11530 (D. Mass. 2025), with Mr. Foster to receive approximately $247,219.

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BOSTON – The Harvard Club of Boston, a private club that is not formally affiliated with Harvard University, has agreed to pay approximately $2.4 million to resolve allegations that it violated the False Claims Act by obtaining a Paycheck Protection Program (PPP) loan for which it was not eligible.
Congress enacted the Coronavirus Aid, Relief, and the Economic Security Act (CARES Act) on March 29, 2020, to provide emergency financial assistance to the millions of Americans who were suffering the economic effects of the COVID-19 pandemic. The CARES Act authorized forgivable loans to small businesses for job retention and certain approved expenses through the PPP. The Small Business Administration (SBA) has longstanding guidance identifying businesses that are ineligible for loan programs including “private clubs and businesses which limit the number of memberships for reasons other than capacity” and “restrict patronage for any reason other than capacity.” SBA’s guidance also made clear that this restriction applied specifically to eligibility for PPP loans.
As detailed in the settlement agreement, The Harvard Club of Boston admits that, on May 4, 2021, it applied for and certified its eligibility for a first draw PPP loan. The Harvard Club of Boston later sought and received forgiveness from SBA of the full amount of its loan. At the time of its application, The Harvard Club of Boston operated as a private membership club that restricted membership to applicants who fit certain eligibility criteria, and therefore, it was ineligible for loans under the PPP program.
The settlement credits The Harvard Club of Boston for cooperation under the Department of Justice’s Guidelines for Taking Voluntary Disclosure, Cooperation and Remediation into Account in False Claims Act Matters.
The claims resolved in today’s settlement include claims that were brought under the qui tam or whistleblower provisions of the False Claims Act.  Under those provisions, a private party can file an action on behalf of the United States and receive a portion of any recovery. As part of today’s resolution, Mr. Foster will receive approximately $247,219. The qui tam case is captioned United States ex rel. Foster. v. Harvard Club of Boston, No. 25-cv-11530 (D. Mass. 2025).
U.S. Attorney Leah B. Foley and Wendell Davis, General Counsel for the Small Businesses Administration made the announcement today. Assistant U.S. Attorney Lindsey Ross of the Affirmative Civil Enforcement Unit handled the case.
harvard_club_settlement_agreement_fully_executed.pdf

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