Criminal Information — United States v. Tracy Denise Jones, Northern District of Georgia (Document 1)

Summary

A criminal information filed by the United States Attorney against Tracy Denise Jones, Case 1:25-cr-00559-JPB, in the U.S. District Court for the Northern District of Georgia, filed in open court December 19, 2025 as Document 1. Count One charges conspiracy to commit theft of government funds, alleging that Jones, Senior Vice President over the Housing Choice Voucher Program at the Housing Authority of the City of Atlanta, used false forms and the fake name Tracy P. Collins to receive Section 8 payments for a Fayetteville house she owned. It states Jones collected approximately $36,387 of housing assistance payments from November 12, 2019, to February 3, 2023 through an account of New Beginning Restoration Project, Inc. Count Two charges wire fraud from about April 1, 2020 to May 31, 2021 over Paycheck Protection Program loan applications containing false information.

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“Criminal Information — United States v. Tracy Denise Jones, Northern District of Georgia (Document 1).” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/information-no-1-25-cr-00559-dkt-1-n-d-ga-bf1a8d03ea/, SHA-256 3248b3f813830ec96abfb502f6e8a78c4274df7b04072f541a5568df00af2684.

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Case 1:25-cr-00559-JPB Document 1 Filed 12/19/25 Page 1 of 19
FILED IN OPEN COURT
U.S.D.C. -Atlanta

DEC 19 2025
K~VIN P. WEIMER, Clerk
y• QM Deputy Clerk

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF GEORGIA
ATLANTA DIVISION

UNITED ST A TES OF AMERICA

V. Criminal Information

TRACY DENISE JONES No. l:25-CR-559

THE UNITED STATES ATTORNEY CHARGES THAT:

Count One
(Conspiracy to Commit Theft of Government Funds)

1. Beginning on a date unknown, but at least from in or about December 2018,

until at least on or about February 3, 2023, in the Northern District of Georgia,

the defendant, TRACY DENISE JONES, knowingly and willfully combined,

conspired, confederated, agreed, and had a tacit understanding with M.D. and

other persons known and unknown to commit an offense against the United

States; to wit, to commit Theft of Government Funds, that is, to knowingly and

willfully embezzle, steal, purloin, and convert to her own use and the use of

another, money of the United States having a value exceeding the sum of $1,000,

namely, funds provided by the U.S. Department of Housing and Urban

Development in the form of housing assistance payments, which funds JONES

was not entitled to receive, in violation of Title 18, United States Code, Section

641.
Case 1:25-cr-00559-JPB Document 1 Filed 12/19/25 Page 2 of 19

Background

2. At all times relevant to this Information:

3. Since on or about April 3, 2017, JONES has served as Senior Vice President

over the Housing Choice Voucher Program at the Housing Authority of the City

of Atlanta, Georgia(" Atlanta Housing" or" AH").

4. AH is the largest housing authority in Georgia and one of the largest in the

nation, providing housing resources for nearly 27,000 low-income households

comprised of approximately 43,000 individuals within the City of Atlanta.

Among other assistance programs, AH administers a Housing Choice Voucher

Program, also known as "Section 8," that provides rental subsidy payments to

landlords who rent properties in Atlanta, Georgia to low-income individuals.

AH programs are funded by the U.S. Department of Housing and Urban

Development ("HUD"). AH has rules restricting AH staff from personally

profiting from the Section 8 program or receiving Section 8 payments for their

own properties. Additionally, Section 8 landlords are typically prohibited from

leasing to their own family members. Section 8 funds are limited, and there is

often a long waiting list of low-income families and individuals who are hoping

to be accepted into the program to have access to rental assistance.

5. The Georgia Department of Community Affairs ("DCA") also administers a

Section 8 Housing Choice Voucher Program. DCA administers the program in

149 of Georgia's 159 counties, but not in the area serviced by AH. DCA's

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program is also funded by HUD. DCA received more than $10,000 of federal

funding in each of years 2018 to 2023.

6. M.D. is an individual who has two children with JONES' son. As early as

November 2017 and through at least February 2023, M.D. and JONES' two

grandchildren lived at a rental residence in Fayetteville, Georgia owned by

JONES (the "Fayetteville house"). At times, JONES' son also lived with M.D. and

the two children. The Fayetteville house is within the territory covered by DCA.

7. JONES lived and maintained her primary residence in a separate house in

Atlanta, Georgia.

Manner and Means

8. The manner and means by which the conspiracy to commit theft of

government funds was sought to be accomplished included the following:

9. JONES and M.D. participated in a multi-step scheme in which they

submitted falsified forms to AH and DCA so that JONES would receive Section 8

payments for the Fayetteville house while M.D. and JONES's grandchildren

lived there.

10. First, beginning in 2018, the conspirators presented false documentation to

gain M.D.'s acceptance into the AH Section 8 program, representing that M.D.

was a resident of Atlanta even though M.D. actually resided in the Fayetteville

residence and therefore was not eligible for AH programs. As a result of the false

documents, M.D. was accepted into the AH program on about February 15, 2019.

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11. Second, because AH could not issue Section 8 payments for housing in

Fayetteville, on March 15, 2019, the conspirators presented false documentation

to AH in which M.D. claimed to be a victim of domestic violence and needed to

relocate to another area for the safety of herself and her children. As a result,

M.D.' s Section 8 eligibility was transferred to DCA.

12. Third, from July to October 2019, JONES and M.D. applied to have DCA

approve a lease for M.D. to live in the Fayetteville house and for DCA to issue

Section 8 payments of $705 per month to JONES. To disguise JONES' identity as

the true owner of the house, she temporarily transferred the property to a

business entity she had set up, New Beginning Restoration Project, Inc. a/k/ a

New Beginnings Restoration Project Inc. ("NBRP"), and used the fake name

Tracy P. Collins as the purported owner of NBRP. JONES also repeatedly falsely

certified that "[t]he owner (including a principal or other interested party) is not

the . . . grandparent ... of any member of the assisted family" even though

JONES was the grandparent of M.D.'s two children who resided with M.D. in the

house.

13. As a result of the fraudulent scheme, JONES collected approximately

$36,387 of housing assistance payments from November 12, 2019, to February 3,

2023, which were deposited into an NBRP bank account controlled by JONES.

14. Fourth, to cover up the fraud, JONES submitted an affidavit to an AH

internal investigation in which she falsely claimed that she did not own or

control the Fayetteville house or NBRP from 2018-2022. JONES also caused at

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least one other individual to provide false documents and statements to the AH

internal investigation and in response to a federal grand jury subpoena.

Overt Acts

15. In furtherance of the conspiracy to commit federal program theft, JONES,

M.D., and others committed at least the following overt acts in the Northern

District of Georgia.

16. On or about December 18, 2018, in the course of applying for the AH

housing assistance program, M.D. submitted a letter to AH stating that she was

an Atlanta resident and attached a Lease Agreement purporting to show that she

was a tenant and resident of an apartment in Atlanta, Georgia. That lease was

fraudulent and M.D. never lived at that location. In reality, M.D. lived at the

Fayetteville house. As a result, on February 15, 2019, M.D. was accepted into the

AH housing assistance program.

17. On or about March 15, 2019, JONES and M.D. submitted to AH a domestic

violence form in which M.D. falsely claimed that she lived in Atlanta, falsely

claimed she was being abused by a boyfriend, and stated, "I, [M.D.] am currently

in an abuse situation. There is physical and verbal abuse against myself and my

children. I want to relocate to another area for the safety of myself and my

children." As a result of the false statements on the form, M.D. was allowed to

transfer her housing assistance benefits out of Atlanta.

18. On or about July 23, 2019, JONES signed a Housing Choice Voucher

Landlord Certification of Responsibility agreement, using the fake name Tracy P.
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Collins, stating that Collins was the owner of the Fayetteville house and NBRP.

The agreement included a statement that "[t]he owner (including a principal or

other interested party) is not the ... grandparent ... of any member of the

assisted family" even though JONES was the grandparent of M.D.' s two children

who resided with M.D. in the house.

19. On or about July 24, 2019, JONES submitted to DCA a Form W-9 Request

for Taxpayer Identification Number and Certification, on behalf of NBRP,

signing the fake name Tracy P. Collins.

20. On or about July 24, 2019, JONES and M.D. signed and submitted to DCA

a Request for Tenancy Approval. JONES signed the form using the fake name

Tracy P. Collins as Owner/Owner representative of the property and NBRP. The

form included an Owner Certification stating, "The owner (including a principal

or other interested party) is not the ... grandparent ... of any member of the

family," even though JONES was the grandparent of M.D.'s two children who

resided with M.D. in the house

21. On or about July 27, 2019, JONES submitted to DCA a form directing DCA

to deposit rental assistance payments into an NBRP bank account controlled by

her.

22. On or about July 29, 2019, JONES submitted a letter to DCA, signing the

fake name T.P. Collins, falsely stating that Collins was the "new owner of the

home in which [M.D.] resides."

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23. On or about October 3, 2019, JONES and M.D. signed and submitted to

DCA a Lease for Residential Property that listed NBRP as landlord of the

Fayetteville house and M.D. as the tenant. JONES signed as landlord using the

fake name Tracy D. Collins.

24. On or about October 25, 2019, JONES signed and submitted to DCA a

HUD Housing Assistance Payments Contract, as property owner, using the fake

name Tracy Collins, requesting housing assistance payments of $705 per month,

with M.D. as the tenant. The contract included an Owner Certification stating,

"The owner (including a principal or other interested party) is not the ...

grandparent ... of any member of the family," even though JONES was the

grandparent of M.D.'s two children who resided with M.D. in the house

25. On or about April 25, 2023, JONES signed and notarized an affidavit and

submitted it to attorneys conducting an internal investigation for AH, falsely

stating, among other things, "I did not own or control the [Fayetteville] residence

during any time that [M.D.] and her children occupied the residence pursuant to

a HAP voucher. I had previously deeded the property to New Beginnings

Restoration Project, Inc. and in May of 2018 the corporation assigned and ceded

control of New Beginnings to [C.T.]. I did not and have not received any HAP

funds or benefits either directly or indirectly at any time."

All in violation of Title 18, United States Code, Section 371.

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Count Two
(Wire Fraud)

26. The factual allegation of paragraph 2 through 25 of this Information are

realleged and incorporated as if fully set forth herein.

27. Beginning on or about April 1, 2020, until on or about May 31, 2021, in the

Northern District of Georgia, the defendant, TRACY DENISE JONES, aided by

others known and unknown, knowingly devised and intended to devise a

scheme and artifice to defraud the Small Business Administration and a lender

operating under the Paycheck Protection Program, and to obtain money and

property by means of materially false and fraudulent pretenses, representations,

and promises, and by omission of material facts, and, with intent to defraud,

caused to be transmitted by means of a wire communication in interstate and

foreign commerce certain writings, signs, signals, and sounds, namely, loan

applications and related documents containing false information.

The Small Business Administration

28. The United States Small Business Administration ("SBA") is an executive

branch agency of the United States government that provides support to

entrepreneurs and small businesses. The mission of the SBA is 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.

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29. As part of this effort, the SBA enables and provides for loans through

banks, credit unions, and other lenders. These loans have government-backed

guarantees.

The Paycheck Protection Program

30. The Coronavirus Aid, Relief, and Economic Security ("CARES") Act was a

federal law enacted in or about March 2020 and was designed to provide

emergency financial assistance to the millions of Americans who were suffering

from the economic effects caused by the COVID-19 pandemic.

31. One source of relief that the CARES Act provided for was the

authorization of up to $349 billion in forgivable loans to small businesses for

payroll, mortgage interest, rent/lease, and utilities, through a program referred

to as the Paycheck Protection Program ("PPP") . In April 2020, Congress

authorized up to $310 billion in additional PPP funding.

32. The PPP allowed qualifying small businesses and other organizations to

receive PPP loans. Businesses must use PPP loan proceeds for payroll costs,

interest on mortgages, rent, and utilities. The PPP allowed the interest and

principal on the PPP loan to be entirely forgiven if the business spent the loan

proceeds on these expense items within a designated period of time and used a

certain percentage of the PPP loan proceeds for payroll expenses.

33. The amount of a PPP loan that a small business may have been entitled to

receive was determined by the number of employees employed by the business

and the business's average monthly payroll costs.
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34. In order to obtain a PPP loan, a qualifying business was required to

submit a PPP loan application, which was signed by an authorized

representative of the business. 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) had 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 had to provide documentation

showing their payroll expenses.

35. The SBA oversaw the PPP. However, individual PPP loans were issued by

private, approved lenders who received and processed PPP applications and

supporting documentation, and then made loans using the lenders' own funds,

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.

36. Cross River Bank, an FDIC-insured bank headquartered in Fort Lee, New

Jersey, was one lender that processed and made PPP loans.

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The EIDL Program

37. The Economic Injury Disaster Loan ("EIDL") program was an SBA

program that provided low-interest financing to small businesses, renters, and

homeowners in regions affected by declared disasters.

38. Another source of relief provided by the CARES Act was the authorization

for the SBA to provide EIDLs of up to $2 million to eligible small businesses

experiencing substantial financial disruption due to the COVID-19 pandemic. In

addition, the CARES Act authorized the SBA to issue advances of up to $10,000

to small businesses within three days of applying for an EIDL. The amount of the

advance was determined by the number of employees the applicant certified

having as employees. The EIDL advances did not have to be repaid.

39. To obtain an EIDL or an EIDL advance for COVID-19 relief, a qualifying

business was required to submit an application to the SBA and provide

information about its operations, such as the number of employees and gross

revenues and cost of goods sold for the 12-month period preceding January 31,

2020. The applicant was also required to certify that all the information in the

application was true and correct to the best of the applicant's knowledge.

40. EIDL applications were submitted directly to the SBA and processed by

the agency with support from a government contractor. The amount of the loan,

if the application was approved, was determined based, in part, on the

information provided by the applicant about employment, revenue, and cost of

goods sold, as described above. Any funds issued under an EIDL or EIDL

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advance were issued directly by the SBA through the United States Treasury.

EIDL funds were required to be used for certain purposes, such as working

capital to make regular payments for operating expenses, which included

payroll, rent/ mortgage, utilities, and other ordinary business expenses, and to

pay business debt incurred at any time (past, present, or future). If the applicant

also obtained a loan under the PPP, the EIDL funds could not be used for the

same purpose as the PPP funds.

41. EIDL applications were received in and processed using computer servers

located in the states of Iowa, Virginia, and Washington. EIDL disbursement

payments were initiated by the SBA using computer servers located in the state

of Colorado, which transmitted the payment information to the Treasury using

computer servers located in the state of Virginia.

42. As part of the scheme, beginning on or about April 1, 2020, defendant

JONES applied for a series of four sets of pandemic relief funds in the names of

two business entities controlled by her.

43. Application #1: On or about April 1, 2020, JONES submitted to the SBA,

via the internet, an application for an EIDL Advance and Loan in the name of

New Beginning Restoration Project Inc. In that application, JONES stated that she

was CEO and 100 % owner of NBRP, had three employees, and received $56,000

of gross revenues in 2019. In reality, NBRP was not conducting business

operations, had no employees, and had no sales in 2019. Additionally, JONES'

statements that she was the sole owner of NBRP conflicted with her other

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statements described above in Count One, specifically, her multiple statements to

DCA that NBRP was owned by "Tracy Collins," and her April 25, 2023, affidavit

stating that NBRP was controlled by C.T. starting in 2018. As a result of this

fraudulent application, on June 10, 2020, JONES received a deposit of $13,000 of

EIDL funds into an NBRP bank account controlled by her and on June 18, 2020,

she received a deposit of $3,000 of EIDL Advance funds into that same bank

account. The NBRP bank account that received the funds is the same account that

received the housing assistance payments described in Count One.

44. Application #2: On or about May 21, 2020, JONES submitted to Cross

River Bank, via the internet, an application for a PPP loan for $11,162 in the name

of New Beginnings Restoration Project Inc. In that application, JONES stated that

she was 100% owner of NBRP, had five employees, and paid an average monthly

payroll of $4,464.80. In support of the application, JONES also submitted a

purported IRS Schedule C for Profit of Loss From Business stating that NBRP

had gross sales of $56,480 in 2019. In reality, NBRP was not conducting business

operations, had no employees, and had no sales in 2019, and the Schedule Chad

not been filed with the IRS. Additionally, JONES' statements that she was the

sole owner of NBRP conflicted with her other statements described above in

Count One, specifically, her multiple statements to DCA that NBRP was owned

by "Tracy Collins," and her April 25, 2023, affidavit stating that NBRP was

controlled by C.T. starting in 2018. As a result of this fraudulent application, on

May 26, 2020, JONES received a deposit of $11,162 into an NBRP bank account

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Case 1:25-cr-00559-JPB Document 1 Filed 12/19/25 Page 14 of 19

controlled by her. The NBRP bank account that received the funds is the same

account that received the housing assistance payments described in Count One.

45. Application #3: On or about July 26, 2020, JONES submitted to the SBA,

via the internet, an application for an EIDL Advance and Loan in the name of

C&T Management and Consulting ("C&T"). In that application, JONES stated

that she was 100% owner of C&T, had four employees, and received $78,000 of

gross revenues in 2019. In reality, JONES reported to the IRS in a Schedule C to

her personal tax return that C&T had only $12,000 of gross receipts (and reported

a net loss of $14,307 for the business, which offset personal income taxes she

owed). SBA ultimately denied her application.

46. Application #4: On or about April 19, 2021, JONES submitted to the SBA,

via the internet, an application for an EIDL Targeted Advance in the name of

New Beginning Restoration Project Inc. In that application, JONES falsely stated

that she had six employees and submitted a purported IRS Schedule C stating

that NBRP had gross sales of $74,269 in 2020. In reality, NBRP at that time was

not conducting business operations, had no employees, and had no sales in 2020,

and the Schedule C had not been filed with the IRS.

47. On or about May 5, 2021, SBA declined JONES' EIDL Targeted Advance

application. In response, on or about May 31, 2021, JONES wrote to the SBA to

appeal the denial, stating, among other things:

· "I currently reside[]" and "I have lived at" an address in Atlanta since August
2019;
· "I rent the [Fayetteville] home;"
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Case 1:25-cr-00559-JPB Document 1 Filed 12/19/25 Page 15 of 19

• "I am truly a honest business owners;"
• "I hear the stories how people abused the PPP loans to establish a lavish lif[ e]
style. That is not me. My business is small and is growing, but I [am] one of
the legitimate and honest business that can use all the help I can;" and
• "I also serve a community of low income families in my business, renting one
of my three homes to a low income family as well as serve other owners of
low income rental properties."

48. SBA did not ultimately approve her request for the EIDL Targeted

Advance.

Execution of the Scheme

49. To execute this scheme to defraud, JONES caused the transmission of

interstate wire communications. Among other executions of the scheme, on or

about April 19, 2021, in the Northern District of Georgia, JONES, aided and

abetted by others known and unknown, for the purpose of executing and

attempting to execute the scheme and artifice to defraud, and to obtain money

and property by means of materially false and fraudulent pretenses,

representations, and promises, and by omission of material facts, did, with intent

to defraud, cause to be transmitted by means of a wire communication in

interstate and foreign commerce certain writings, signs, signals, and sounds,

namely, a fraudulent application for an EIDL Targeted Advance in the name of

New Beginning Restoration Project Inc.

All in violation of Title 18, United States Code, Sections 1343 and 2.

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Count Three
(Credit Application Fraud)

50. The factual allegations of paragraph 2 through 25 of this Information are

realleged and incorporated as if fully set forth herein.

51. On or about June 8, 2022, in the Northern District of Georgia, the

defendant, TRACY DENISE JONES, aided by others known and unknown,

knowingly made false statements and reports, and willfully overvalued

property, in an application, advance, commitment, and loan, and any change and

extension thereof, for the purpose of influencing the actions of the Federal

Housing Administration, a mortgage lending business, and a person and entity

that makes in whole and in part a federally related mortgage loan; to wit, JONES

made false statements in a Uniform Residential Loan Application to American

Financing Corporation to obtain a mortgage insured by the Federal Housing

Administration.

52. Specifically, on or about June 8, 2022, JONES refinanced her existing

mortgage on the Fayetteville house w ith a remaining balance of $134,430.92 to

obtain a new Federal Housing Administration-insured mortgage of $291,780. In

the Uniform Residential Loan Application, JONES made the following false

entries:

· "Intended Occupancy: Primary Residence"
· "Occupancy: Primary Residence"
· "Will you occupy the property as your primary residence? YES"
· "[H]ave you had an ownership interest in another property in the last three
years? NO"
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• "The information I have provided in this application is true, accurate, and
complete as of the date I signed this application."
• "Any intentional or negligent misrepresentation of information may result in
the imposition of ... criminal penalties on me including, but not limited to,
fine or imprisonment or both under the provisions of Federal law."

53. When JONES made the above false entries on the mortgage application,

she knew that she was not personally occupying the Fayetteville house; that she

maintained her actual primary residence at a separate house in Atlanta; that she

was actively renting the Fayetteville house to M.D.; that JONES was receiving

DCA Section 8 housing assistance payments for M.D. living in the Fayetteville

house; that JONES had no intention of occupying the Fayetteville house as her

primary residence; and that JONES had an ownership interest in other

properties, including her actual primary residence in Atlanta.

54. As a result of the false application, the mortgage was approved and

issued.

All in violation of Title 18, United States Code, Sections 1014 and 2.

Forfeiture

55. Upon conviction of the offense alleged in Count One of this Indictment,

the defendant, TRACY DENISE JONES, shall forfeit to the United States of

America, pursuant to Title 18, United States Code, Section 981(a)(l)(C) and Title

28, United States Code, Section 2461(c), any property, real or personal, which

constitutes or is derived from proceeds traceable to the violation, including, but

not limited to, the following:

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MONEY JUDGMENT: A sum of money in United States currency,

representing the amount of proceeds obtained as a result of the offense

alleged in Count One of this Indictment.

56. Upon conviction of one or more of the offenses alleged in Counts Two

through Three of this Indictment, the defendant, TRACY DENISE JONES, shall

forfeit to the United States of America, pursuant to pursuant to Title 18, United

States Code, Section 982(a)(2)(A), any property constituting, or derived from,

proceeds obtained, directly or indirectly, as a result of the violations, including,

but not limited to, the following:

MONEY JUDGMENT: A sum of money in United States currency,

representing the amount of proceeds obtained as a result of the offense

alleged in Counts Two through Three of this Indictment.

57. If, as a result of any act or omission of the defendant, any property subject

to forfeiture,

(a) cannot be located upon the exercise of due diligence;

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

(d) has been substantially diminished in value; or

(e) has been commingled with other property which cannot be divided

without difficulty,

the United States intends, pursuant to Title 21, United States Code, Section

853(p), as incorporated by Title 28, United States Code, Section 2461(c) and Title

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18, United States Code, Section 982(b)(l), to seek forfeiture of any other property

of the defendant up to the value of the forfeitable property.

THEODORE S. HERTZBERG

4;;;en
GARRETT L. BRADFORD
Assistant United States Attorney
Georgia Bar No. 074374

600 U.S. Courthouse
75 Ted Turner Drive SW
Atlanta, GA 30303
404-581-6000; Fax: 404-581-6181

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