Indictment — United States v. Tiffanie Foster, Western District of Missouri (Document 1)

Summary

A grand jury Indictment in United States v. Tiffanie Foster, Case No. 4:25-00201-01-CR-W-BP, in the United States District Court for the Western District of Missouri, Western Division, filed June 27, 2025. Counts One and Two charge wire fraud under 18 U.S.C. §1343. The indictment alleges that Foster applied to Itria Ventures, LLC for a PPP loan for Exotic Indiscretions, LLC with a 2019 Schedule C listing gross receipts of $152,675, while the Schedule C filed with her 2019 taxes listed $1,350, and that the full $20,833 loan was deposited on March 26, 2021. It also alleges that Foster claimed Michigan unemployment benefits, including PUA, while residing in Missouri and working full-time for the Social Security Administration, receiving $34,960.00. The second count concerns a $460.00 unemployment payment on or about September 14, 2021.

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“Indictment — United States v. Tiffanie Foster, Western District of Missouri (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/indictment-no-4-25-cr-00201-dkt-1-w-d-mo-ea081d967a/, SHA-256 6d84fcf6aee7487fff853913413452c7aa556fa8bc5929358cbd3031747384c2.

Full text

IN THE UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF MISSOURI
WESTERN DIVISION

UNITED STATES OF AMERICA, Case No. 4:25-00201-01-CR-W-BP

Plaintiff, COUNTS ONE and TWO:
[Wire Fraud]
v. 18 U.S.C. §1343
NMT 20 Years’ Imprisonment
TIFFANIE FOSTER, NMT $250,000 Fine
[DOB: 8/3/1976] NMT 3 Years’ Supervised Release
Class C Felony
Defendant.
$100 Mandatory Special Assessment per count

INDICTMENT

THE GRAND JURY CHARGES THAT:

Introduction

I. THE PAYCHECK PROTECTION PROGRAM AND PANDEMIC
UNEMPLOYMENT ASSISTANCE

1. On March 27, 2020, the President signed into law the Coronavirus Aid, Relief, and

Economic Security Act (“CARES Act”), an economic stimulus bill that, among other things,

provided emergency assistance to small business owners and nonprofit organizations in all U.S.

states, Washington D.C., and territories affected by the COVID-19 pandemic. 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”). Additional PPP funding was authorized in legislation

enacted on or about December 27, 2020, and March 11, 2021.

2. The PPP program, which is operated by the Small Business Administration

(“SBA”), provided small businesses with funding to meet specific business obligations, including

payroll and rent. The PPP permitted participating third-party lenders to approve and disburse SBA-

Case 4:25-cr-00201-BP Document 1 Filed 06/27/25 Page 1 of 5
backed PPP loans to cover payroll, fixed debts, utilities, rent/mortgage, accounts payable and other

bills incurred by qualifying businesses during, and resulting from, the COVID-19 pandemic. PPP

loans are fully guaranteed by the SBA. Further, SBA will forgive any loan up to 100 percent if the

borrower establishes it utilized 60 percent of the loan on payroll costs in the 24-week period post-

disbursement, with the remaining 40 percent going toward covered mortgage interest payments,

covered rent payments, covered utilities, covered operations expenditures, covered property

damage costs, covered supplier costs, and covered worker protection expenditures. Whatever

portion is not forgiven is serviced as a loan.

3. The SBA promulgated regulations concerning eligibility for a PPP loan. Individuals

who operated a business under a “sole proprietorship” business structure were 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 on a

“Form 1040, Schedule C,” for a given tax year. As with other PPP loans, this information and

supporting documentation was used to calculate the amount of money the individual was entitled

to receive under the PPP. The maximum loan amount for a sole proprietor with no employees was

$20,833.00.

4. A PPP loan application was processed by the third-party participating lender with

whom the application was filed. If a PPP loan application was approved, the participating lender

would fund the PPP loan; to encourage PPP loans to be issued, the loan was guaranteed by the

SBA. Data from the application, including information from the borrower, the total amount of the

loan, and the listed number of employees, was transmitted by the lender to the SBA while

processing the loan.

5. The CARES Act also created a Pandemic Unemployment Assistance (“PUA”)

Case 4:25-cr-00201-BP Document 1 Filed 06/27/25 Page 2 of 5
program to assist individuals experiencing unemployment or underemployment due to the

pandemic. The PUA provided temporary benefits for self-employed workers, including

independent contractors and gig workers, for up to 39 weeks. Those eligible for PUA benefits

could also receive additional supplemental payments of $600 under the Federal Pandemic

Unemployment Compensation program.

The Scheme

6. On or about February 10, 2021, in the Western District of Missouri, the defendant,

TIFFANIE FOSTER, who lived in Kansas City, Missouri, completed and sent an application and

supporting documents to Itria Ventures, LLC, to apply for a PPP loan under the CARES Act for

her business.

7. The application and supporting documents stated that the defendant was the owner

of a business named Exotic Indiscretions, LLC, and used her own social security number for the

business. FOSTER included a 2019 tax Form 1040 Schedule C with her application which listed

gross receipts or sales of $152,675 and a profit of $6,311. The Form 1040 Schedule C the defendant

filed with her 2019 taxes indicated different amounts including $1,350 in gross receipts or sales

and a net loss of $1,032. FOSTER also submitted a bank statement from January of 2020 indicating

she had a combined total of $11,825.84 in both her business checking and business savings

accounts. Bank records showed her actual combined balance for January 2020 was $0.36

indicating the statement she provided with her application was altered. The full amount of the PPP

loan, $20,833, was deposited via wire transfer from Itria Ventures, LLC into a Mazuma Credit

Union account ending in X2828 on March 26, 2021. Itria Ventures, LLC is in New York, New

York while Mazuma Credit Union is headquartered in Overland Park, Kansas.

Case 4:25-cr-00201-BP Document 1 Filed 06/27/25 Page 3 of 5
8. On July 4, 2020, FOSTER submitted an application for unemployment benefits in

the state of Michigan which included PUA benefits. The application provided her a fraud warning

indicating that it is considered fraud if a false statement is made in the application or information

is concealed to obtain the benefits. FOSTER affirmed her understanding of this fraud warning on

the application. She indicated on the application that she was a resident of Michigan and was

unemployed due to the pandemic, when in fact, she was residing in the Western District of

Missouri and working full-time for the Social Security Administration. FOSTER also indicated on

her application that she had not applied for unemployment benefits in any other state. In fact, she

had applied for unemployment benefits in the state of Missouri on May 11, 2020. FOSTER

received unemployment benefits from March 28, 2020, through September 4, 2021, from

Michigan for a total of $34,960.00. These benefits were deposited from the state of Michigan into

FOSTER’S account via electronic direct deposit with Pathward National Bank which is located in

Sioux Falls, South Dakota.

COUNT ONE

The allegations set forth in paragraphs 1 through 8 are hereby incorporated in full.

9. On or about March 26, 2021, in the Western District of Missouri, the defendant,

TIFFANIE FOSTER, having devised and intended to devise a scheme to obtain money by means

of materially false and fraudulent pretenses, representations, and promises, for the purpose of

executing the scheme described above, caused to be transmitted by means of wire communication

in interstate commerce a deposit of $20,833 from Itria Ventures, LLC into her account.

All in violation of the provisions of Title 18, United States Code, Section 1343.

Case 4:25-cr-00201-BP Document 1 Filed 06/27/25 Page 4 of 5
COUNT TWO

The allegations set forth in paragraphs 1 through 8 are hereby incorporated in full.

10. On or about September 14, 2021, in the Western District of Missouri, the defendant,

TIFFANIE FOSTER, having devised and intended to devise a scheme to obtain money by means

of materially false and fraudulent pretenses, representations, and promises, for the purpose of

executing the scheme described above, caused to be transmitted by means of wire communication

in interstate commerce an unemployment benefit payment of $460.00 from the state of Michigan

into her bank account.

All in violation of the provisions of Title 18, United States Code, Section 1343.

A TRUE BILL.

Dated: June 27, 2025 SIGNATURE ON FILE WITH USAO
Kansas City, Missouri FOREPERSON OF THE GRAND JURY

/s/Amanda K. Hanson
Amanda K. Hanson
Special Assistant United States Attorney

Case 4:25-cr-00201-BP Document 1 Filed 06/27/25 Page 5 of 5

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