Indictment — United States v. Britney Sade McCoy, Middle District of Louisiana (Document 1)

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An indictment for wire fraud, false statements in loan and credit application and notice of forfeiture against Britney Sade McCoy, Case No. 3:25-cr-00071-SDD-SDJ, in the U.S. District Court for the Middle District of Louisiana, filed June 18, 2025 as Document 1. It charges wire fraud under 18 U.S.C. § 1343 and false statements under 18 U.S.C. § 1014. The indictment alleges that McCoy, then a City of Baton Rouge purchasing analyst, submitted PPP applications on or about April 30, 2021 and May 28, 2021 claiming a tutoring business with gross income of $54,683, each yielding approximately $11,392, and then filed forgiveness applications reporting the funds were spent on payroll. It states the SBA forgave each loan in the amount of approximately $11,424 and that McCoy obtained at least approximately $22,784 in PPP funds.

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Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page1of12

UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF LOUISIANA

INDICTMENT FOR WIRE FRAUD, FALSE STATEMENTS IN LOAN AND
CREDIT APPLICATION, AND NOTICE OF FORFEITURE

UNITED STATES OF AMERICA : CRIMINAL NO. 25- {\-Spp -SP.3
versus > 18U,S.C. § 1343
: 18U.S.C. § 1014
BRITNEY SADE MCCOY > 18U.S.C.§2
a/k/a “Brit’Ney Sadé McCoy” : 18U,S.C. § 981
a/k/a “Brit’Ney McCoy” : 18U.S.C. § 982
a/k/a “Wop” > 21 U.S.C. § 853
a/k/a “only lwop23” : 28US.C. § 2461

a/k/a “Buwop Tropicana”

THE GRAND JURY CHARGES:

At all times relevant to this Indictment:

Small Business Administration

1. The United States Small Business Administration (“SBA”) was an executive-
branch agency of the United States that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.

2. As part of this effort, the SBA facilitated loans through banks, credit unions,
and other lenders. These loans had government-backed guarantees.

The Paycheck Protection Program

3, The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”)
was a federal law enacted in or around March 2020 and designed to provide emergency

financial assistance to the millions of Americans who were suffering from the economic effects
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caused by the COVID-19 pandemic. On or about March 13, 2020, the President declared a
national emergency under section 501 of the Robert T. Stafford Disaster Relief and Emergency
Assistance Act, 42 U.S.C. §§ 5121 et seq. (the “Stafford Act”).

4, One source of relief provided by the CARES Act was the authorization of up to
$349 billion in forgivable loans to small businesses for job retention and certain other
expenses, through a program referred to as the Paycheck Protection Program (“PPP”).

5. In order to obtain a PPP loan, a qualifying business was required to submit a
PPP loan application, signed by an individual authorized to represent the business (the
“authorized representative”). The PPP loan application required the business (through its
authorized representative) to acknowledge the program rules and make certain affirmative
certifications in order to be eligible to obtain the PPP loan. In the PPP loan application, the
small business (through its authorized representative) was required to state, among other
things, its: (a) average monthly payroll expenses; and (b) number of employees. These figures
were used to calculate the amount of money the small business was eligible to receive under
the PPP. In addition, businesses applying for a PPP loan were required to provide
documentation (generally, a business tax return) to substantiate their payroll expenses.

6. Individuals who operated a business under a “sole proprietorship” business
structure were also eligible for a PPP loan. To qualify for such a PPP loan, individuals had to
report and document their income and expenses from the sole proprietorship, as typically
reported to the Internal Revenue Service (“IRS”) on a “Form 1040, Schedule C” for a given
tax year. As with other PPP loans, this information and supporting documentation were used

to calculate the amount of money the individual was entitled to receive under the PPP. The
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 3 of 12

maximum loan amount for a sole proprietorship with no employees was approximately
$20,833.

7. PPP loan applications were processed by a participating lender (the “lender’’).
If the lender approved a PPP loan application, the lender funded the PPP loan using its own
monies, which were 100% guaranteed by the SBA. Data from the application, including
information about the borrower, the total amount of the loan, and the listed number of
employees, was transmitted by the lender to the SBA in the course of processing the loan.

8. Certain PPP lenders provided loan applicants with access to an online PPP portal
and offered eligible participants funding through their own customized platforms. Other banks
partnered directly with non-bank lenders and financial technology companies to identify,
assist, and fund eligible PPP applicants.

9. Once approved, the business (through its authorized representative) received the
PPP loan proceeds via an electronic funds transfer from the third-party lender to a financial
account under the control of the business. PPP loan proceeds were required to be used by the
business on certain permissible expenses, including payroll costs, mortgage interest, rent, and
utilities. Under the applicable PPP rules and guidance, the interest and principal on the PPP
loan was eligible for forgiveness if the business was eligible for the PPP loan it received, spent
the loan proceeds on these permissible expense items within a designated period of time, and
used a certain portion of the loan proceeds for payroll expenses. The proceeds of a PPP loan
were not permitted to be used by the borrowers to purchase consumer goods, automobiles,
personal residences, clothing, or jewelry, or to pay personal federal income taxes or for

ordinary day-to-day living expenses unrelated to the specified authorized expenses.
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The Defendant, Relevant Individuals, and Relevant Entities

10. Defendant BRITNEY SADE MCCOY, also known as “Brit’Ney Sadé
McCoy,” also known as “Brit’Ney McCoy,” also known as “Wop,” also known as
“onlylwop23,” also known as “Buwop Tropicana” (hereinafter, “MCCOY”), was a resident
of Baton Rouge, Louisiana, within the Middle District of Louisiana. MCCOY was employed
by the City of Baton Rouge as a Purchasing Analyst from in or around May 2019 to in or
around September 2021. On or about November 29, 2021, MCCOY was hired as a State
Procurement Analyst at the State of Louisiana’s Division of Administration, Office of State
Procurement.

11. Associate 1 was a resident of Baton Rouge, Louisiana, within the Middle
District of Louisiana.

12. Credit Union 1 was a federally insured financial institution headquartered in
Baton Rouge, Louisiana. MCCOY held an account, ending in 7558, at Credit Union 1, over
which she had control.

13. Company 1 was a non-bank lender and limited liability company headquartered
in Hollywood, Florida. Company | participated in the SBA’s PPP as a lender and, as such,
was authorized to lend funds to eligible borrowers under the terms of the PPP.

14. Company 2 was a technology company headquartered in San Francisco,
California. Company 2 provided services to SBA-approved lenders and non-lenders in
connection with digitally transferring documents for borrowers’ electronic signatures.

15. Company 3 was a non-bank lender headquartered in Lake Mary, Florida.
Company 3 participated in the SBA’s PPP as a lender and, as such, was authorized to lend

funds to eligible borrowers under the terms of the PPP.
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16. Company 4 was a federally insured financial institution headquartered in
Laguna Hills, California. Company 4 participated in the SBA’s PPP as a lender and, as such,
was authorized to lend funds to eligible borrowers under the terms of the PPP.

17. | Company 5 was a technology company headquartered in Springdale, Arkansas.
Company 5 partnered with lenders, financial institutions, and companies, including
Company 4, to process PPP applications. Company 5’s servers were located outside of the
Middle District of Louisiana.

COUNT 1
Wire Fraud
(18 U.S.C. §§ 1343 and 2)
18. Paragraphs 1 through 17 of this Indictment are re-alleged and incorporated by

reference as though fully set forth herein.

The Scheme to Defraud

19. Beginning in or around April 2021, and continuing through at least in or around
September 2021, in the Middle District of Louisiana, and elsewhere, MCCOY devised and
intended to devise a scheme and artifice to defraud the United States, through the SBA, lenders,
and companies, and to obtain money and property by means of materially false and fraudulent
pretenses, promises, and representations, by: (1) creating false and fraudulent PPP
applications, PPP loan forgiveness applications, forms, and supporting documents (the
“fraudulent loan applications”); (2) submitting and causing to be submitted the fraudulent loan
applications to lenders, the SBA, and others in order to obtain funds and loan forgiveness
through the PPP; and (3) receiving and obtaining PPP funds and loan forgiveness based on the

fraudulent loan applications submitted.
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Purpose of the Scheme

20. It was a purpose of the scheme and artifice for MCCOY and her accomplices
to unlawfully and unjustly enrich themselves by: (a) submitting and causing the submission,
via interstate wire communications, of false and fraudulent applications for PPP loans and loan
forgiveness; (b) diverting fraud proceeds for their personal use, the use and benefit of others,
and to further the fraud; and (c) concealing and causing the concealment of the false and
fraudulent applications and related documents.

Manner and Means of the Scheme

21. The manner and means by which MCCOY and her accomplices sought to

accomplish the objects and purpose of the scheme and artifice included, among others:
The Associate 1 PPP Application

22. Onor about April 20, 2021, a false and fraudulent application was electronically
submitted on behalf of Associate 1 to Company 3, located outside the State of Louisiana,
seeking approximately $11,141 (the “Associate 1 PPP Application”). The Associate 1 PPP
Application falsely claimed that Associate 1 was a sole proprietor, Associate 1’s purported
business was established on January 1, 2016, it had one employee, and its gross income for
2019 was $53,480. In support of the Associate 1 PPP Application, Associate 1 submitted and
caused to be submitted a fake bank statement and a fake IRS Form 1040, Schedule C, for 2019.

23. Inreliance on the false representations made in the Associate 1 PPP Application
and supporting documents, Company 3 deposited approximately $11,141 in PPP funds into
Associate 1’s bank account. Upon receipt of the PPP funds, Associate 1 transferred thousands

of dollars of the criminal proceeds to individuals, including approximately $2,000 to MCCOY.
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 7 of 12

The Britney McCoy First PPP Application

24. On or about April 30, 2021, MCCOY, while employed by the City of Baton
Rouge, electronically submitted and caused to be submitted a false and fraudulent PPP
application in her name to Company 3, located outside the State of Louisiana, seeking
approximately $11,392 in PPP funds (the “Britney McCoy First PPP Application”). MCCOY
signed the Britney McCoy First PPP Application and falsely certified that the application,
supporting documents, and all information provided therein were true and accurate in all
material respects.

25. Inthe Britney McCoy First PPP Application, MCCOY claimed that she was a
sole proprietor, her purported business was established on January 1, 2016, it had one
employee, and its gross income for 2019 was $54,683. MCCOY electronically submitted and
caused to be submitted an IRS Form 1040, Schedule C, for 2019 (the “2019 IRS Form 1040”)
as a supporting document. The 2019 IRS Form 1040 falsely represented that MCCOY made
approximately $54,683 in gross income and gross profit, and her principal business or
profession was “Exam Preparation and Tutoring” in 2019.

26. In reliance on the false representations made in the Britney McCoy First PPP
Application and supporting documents, Company 3 deposited approximately $11,392 in PPP
funds into MCCOY’s account, ending in 7558, at Credit Union 1. MCCOY spent the PPP
proceeds on impermissible personal expenses, including items from Saks Fifth Avenue and
Zales.

27. Onor about August 12, 2021, a fraudulent PPP loan forgiveness application was
electronically signed by MCCOY using Company 2’s technology and then electronically

submitted to the SBA, seeking to have the entire $11,392 loan forgiven (the “Britney McCoy
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 8 of 12

First Draw PPP Loan Forgiveness Application”). In the Britney McCoy First Draw PPP
Forgiveness Application, MCCOY falsely stated and reported that she spent $11,392 of the
PPP loan proceeds on payroll costs. MCCOY signed the Britney McCoy First Draw PPP
Forgiveness Application and falsely certified that the information provided therein was true
and correct in all material respects. The SBA authorized complete loan forgiveness of the PPP
loan in the amount of approximately $11,424 (including the principal and interest), and the
SBA remitted the forgiveness payment to Company 3 on or about August 17, 2021.
The Britney McCoy Second PPP Application

28. On or about May 28, 2021, MCCOY, while employed by the City of Baton
Rouge, electronically submitted and caused to be submitted another false and fraudulent PPP
application in her name to Company 1 through Company 5’s servers, located outside the State
of Louisiana, seeking approximately $11,392 in PPP funds (the “Britney McCoy Second PPP
Application”). MCCOY signed the Britney McCoy Second PPP Application and falsely
certified that the application, supporting documents, and all information provided therein were
true and accurate in all material respects. In support of the Britney McCoy Second PPP
Application, MCCOY made the same false representations reported in the Britney McCoy
First PPP Application. In support of the Britney McCoy Second PPP Application, MCCOY
electronically submitted and caused to be submitted the same IRS Form 1040 for 2019, as
detailed in paragraph 25.

29. Inreliance on the false representations made in the Britney McCoy Second PPP
Application and supporting documents, Company 4 deposited approximately $11,392 in PPP
funds into MCCOY’s account, ending in 7558, at Credit Union 1. In or around June 2021,

Company | sold and transferred MCCOY’s loan to Company 4. MCCOY spent the PPP
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 9 of 12

proceeds on impermissible personal travel and other expenses, including items from Louis
Vuitton and Saks Fifth Avenue.

30. Onor about September 10, 2021, a fraudulent PPP loan forgiveness application
was electronically signed by MCCOY using Company 2’s technology and then electronically
submitted to Company 4 and the SBA, seeking to have the entire $11,392 loan forgiven (the
“Britney McCoy Second Draw PPP Loan Forgiveness Application”). In the Britney McCoy
Second Draw PPP Forgiveness Application, MCCOY falsely stated and reported that she
spent $11,392 of the PPP loan proceeds on payroll costs. MCCOY signed the Britney McCoy
Second Draw PPP Forgiveness Application and falsely certified that the information provided
therein was true and correct in all material respects. The SBA authorized complete loan
forgiveness of the PPP loan in the amount of approximately $11,424 (including the principal
and interest), and the SBA remitted the forgiveness payment to Company 4 on or about
September 15, 2021.

Scope of the Scheme

31. In total, based on the false and fraudulent PPP applications detailed above,
MCCOY fraudulently sought and obtained at least approximately $22,784 in PPP funds.
Use of Wires
32. On or about the date set forth below, in the Middle District of Louisiana, and
elsewhere, MCCOY, aiding and abetting and aided and abetted by others, having devised the
scheme described above, for the purpose of executing the scheme, and attempting to do so, did
knowingly transmit and cause to be transmitted, by means of wire communication, certain

writings, signals, pictures, and sounds in interstate commerce, as described below:
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 10 of 12

Count Approximate Description of Wire
Date
MCCOY electronically submitted and caused to be submitted
1 5/28/2091 the Britney McCoy Second Draw PPP Application and

supporting documents from within the Middle District of
Louisiana to Company | located outside the State of Louisiana.

The above is a violation of Title 18, United States Code, Sections 1343 and 2.

COUNT 2

False Statements in Loan and Credit Application

(18 U.S.C. §§ 1014 and 2)

Paragraphs 1 through 32 of this Indictment are re-alleged and incorporated by

reference as though fully set forth herein.

34.

On or about the date set forth below, in the Middle District of Louisiana, and

elsewhere, MCCOY, aiding and abetting and aided and abetted by others, did knowingly make

and cause to be made one or more false statements and reports for the purpose of influencing

the action of Company 4 in connection with an application, commitment, and loan, as

described below.

Count | Approximate Date Description of False Statements
In the Britney McCoy Second Draw PPP Loan Forgiveness
Application, MCCOY falsely stated and reported that she
7 9/10/2021 spent $11,392 of the PPP loan proceeds on payroll costs,

when in fact as MCCOY knew, MCCOY spent the PPP
loan proceeds on impermissible personal expenses,

including items from Louis Vuitton and Saks Fifth Avenue.

Each of the above is a violation of Title 18, United States Code, Sections 1014 and 2.

10
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 11 of 12

NOTICE OF FORFEITURE

35. Paragraphs | through 34 of this Indictment are incorporated by reference herein
as factual allegations.

36. | Uponconviction of the offense alleged in Count One, MCCOY shall forfeit to
the United States pursuant to Title 18, United States Code, Section 981(a)(1)(C), Title 18,
United States Code, Section 982(a)(2), and Title 28, United States Code, Section 2461(c), any
property, real or personal, which constitutes or is derived from proceeds traceable to, or
obtained as a result of, the offense.

37. | Upon conviction of the offense alleged in Count Two, MCCOY shall forfeit to
the United States pursuant to Title 18, United States Code, Section 981(a)(2), any property,
real or personal, which constitutes or is derived from proceeds traceable to the offense.

38. If any of the above-described property, as a result of any act or omission of the
defendant:

a. cannot be located upon the exercise of due diligence;

b. has been transferred or sold to, or deposited with, a third party;

c. has been placed beyond the jurisdiction of the Court;

d. has been substantially diminished in value; or

e. has been commingled with other property which cannot be subdivided
without difficulty,

11
Case 3:25-cr-00071-SDD-SDJ Document1 06/18/25 Page 12 of 12

the United States shall be entitled to forfeiture of substitute property pursuant to Title 21,
United States Code, Section 853(p), as incorporated by Title 28, United States Code, Section

2461(c), and the United States shall be entitled to a forfeiture money judgment.

UNITED STATES OF AMERICA, BY A TRUE BILL
‘ REDACTED
(1 Wp C~ ie PER PRIVACY ACT
ELLISON C. TRAVIS GRAND JURY FOREPERSON

ACTING UNITED STATES ATTORNEY
MIDDLE DISTRICT OF LOUISIANA

KRISTEN L. CRAIG ad DATE “
ASSISTANT UNITED STATES ATTORNEY

12


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