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Home Source documents Semiannual Report to Congress, April 1, 2020 – September 30, 2020 — U.S. Small Business Administration Office of Inspector General

Semiannual Report to Congress, April 1, 2020 – September 30, 2020 — U.S. Small Business Administration Office of Inspector General

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Semiannual Report to Congress
    April 1, 2020 – September 30, 2020




             U.S. Small Business Administration
               U.S. Small Business Administration
                    Office of Inspector General
                       Office of Inspector General
                                                                     U.S. Small Business Administration
                                                                            Office of Inspector General
                                                                               Washington, D.C. 20416


                 MESSAGE FROM THE INSPECTOR GENERAL
October 30, 2020


I am honored to submit our Semiannual Report to Congress for the second half of fiscal year 2020.
Every 6 months, we report to Congress on our independent oversight of the U.S. Small Business
Administration (SBA), as required by law.
This semiannual period has been like no other in the history of SBA or the
Office of Inspector General (OIG). The focus of our work has been to
oversee the agency’s management of the enormous resources Congress
provided to help keep small businesses alive during the pandemic since
mid-March when the nation’s economy came to a virtual halt because of
the public health crisis caused by the spread of Coronavirus Disease 2019
(COVID-19).
OIG continues to focus on the most critical risks facing SBA, directing our
resources at the most serious management and performance challenges.
There is no doubt that pandemic oversight is at the top of the list.
                                                                                Hannibal “Mike” Ware
                                                                                Inspector General
Our Work this Period
In response to the COVID-19 pandemic, Congress authorized SBA to lend more than $1 trillion to
small business entities through the Paycheck Protection and Economic Injury Disaster Loan programs.
Sadly, the enormous sums authorized by Congress to support small businesses through the
                              pandemic were also viewed as opportunities by fraudsters.
 Pandemic                     By the end of this reporting period, OIG had received more than
                              100,000 complaints of fraud via the Hotline. We have launched
 Response                     hundreds of investigations in response.
                              During this reporting period, OIG issued 10 reports with 24
 Oversight                    recommendations to improve SBA operations and reduce fraud and
                              unnecessary losses in agency programs. The 10 reports include 3 White
                              Papers, a Flash Report, and a Management Alert on pandemic-related
                              issues and fraud.
In addition, OIG investigations resulted in 47 indictments and 8 convictions. Overall, OIG’s
investigations and audits achieved monetary recoveries and savings of $124,513,846. OIG also sent
three present responsibility referrals to SBA. (Present responsibility means the business ethics,
integrity, honesty, and competence of vendors.)




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OIG Staff Dedication and Success
I would be remiss if I did not take this opportunity to
compliment and sincerely thank OIG’s outstanding
employees for their tireless efforts to maintain momentum
on all our projects while exclusively teleworking.
Despite difficult conditions and the need to quickly (and
frequently) adapt to rapid change over the past months, our
auditors, investigators, and support staff have redoubled
their efforts to meet OIG’s mandated mission of promoting
economy, efficiency, effectiveness, and integrity in SBA
programs and operations.
Every member of OIG is committed to protecting the
precious resources of American taxpayers. I look forward to
the impactful work OIG employees will produce in the
coming semiannual period. I am confident that I may speak
for them when I say we all look forward to continuing work
with SBA’s management to address the issues and
challenges facing the agency.




Hannibal “Mike” Ware
SBA Inspector General
                      U.S. Small Business Administration | Office of Inspector General


Organizational Overview
U.S. Small Business Administration
The mission of the U.S. Small Business Administration (SBA) under the Small Business Act, as
amended, is to maintain and strengthen the nation’s economy by enabling the establishment
and vitality of small businesses and assisting in the economic recovery of communities after
disasters.
The agency’s strategic plan for fiscal years (FYs) 2018–22 has four key goals:
           1. Support small business revenue and job growth.
           2. Build healthy entrepreneurial ecosystems and create business friendly
              environments.
           3. Restore small businesses and communities after disasters.
           4. Strengthen SBA’s ability to serve small businesses.

SBA is organized around the functional assistance areas of financial, contracting,
entrepreneurial development, and disaster assistance. The agency also represents small
businesses through an independent advocate and an ombudsman.
SBA’s headquarters is in Washington, D.C. The agency has staff in 10 regional offices, 68
district offices and corresponding branch offices, and 4 disaster field offices. There also are 6
government contracting area offices. SBA also maintains a vast network of resource partners in
all 50 states, the District of Columbia, Puerto Rico, American Samoa, the U.S. Virgin Islands,
and Guam.

Office of Inspector General
OIG has three divisions and several supporting program offices:
   1. The Audits Division audits and reviews SBA programs and operations to ensure they
      are economical, efficient, and effective. Our key areas of emphasis are SBA’s loan
      programs, disaster assistance, business and entrepreneurial development and
      government contracting programs, as well as mandatory and other statutory audit
      requirements involving information security and financial reporting. Other work
      focuses on high-risk activities and management issues facing SBA.

   2. The Investigations Division investigates allegations of illegal and improper activities
      involving SBA’s programs, operations, and personnel. OIG criminal investigators carry
      out a full range of traditional law enforcement functions. The OIG Hotline receives
      allegations of waste, fraud, abuse, or serious mismanagement in SBA or its programs.
      Hotline staff members review complaints and may coordinate reviews of allegations
      within OIG, SBA program offices, or other government agencies.

       The security operations staff conducts required OIG employee background
       investigations and screens OIG employees and contractors according to Homeland
       Security Presidential Directive-12 background investigations requirements.


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   3. The Management and Operations Division provides business support (e.g., budget
      and financial management, human resources, information technology, administrative,
      and communication) for OIG functions and activities.
The Office of Counsel provides legal and ethics advice to all OIG components; represents
OIG in litigation arising out of or affecting OIG operations; presents training; assists with
prosecuting criminal, civil, and administrative enforcement matters; processes subpoenas;
responds to Freedom of Information and Privacy Act requests; and reviews and comments on
proposed policies, regulations, legislation, and procedures.
OIG’s headquarters is in Washington, D.C. Our field staff, primarily investigative agents, are
located in12 offices in the four regions around the country.




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                   Table of Contents
Message from the Inspector General .............................................................................................................................. i

Our Work this Period ......................................................................................................................................................... i

OIG Staff Dedication and Success................................................................................................................................... ii

Organizational Overview .................................................................................................................................................iii

     U.S. Small Business Administration............................................................................................................................iii

Pandemic Response Oversight ....................................................................................................................................... 1

Audits, Inspections, and Evaluations............................................................................................................................... 1

Investigations .................................................................................................................................................................... 4

Small Business Access to Capital .................................................................................................................................... 7

Audits, Inspections, and Evaluations............................................................................................................................... 7

Investigations .................................................................................................................................................................... 8

Disaster Assistance Program ......................................................................................................................................... 10

Audits, Inspections, and Evaluations............................................................................................................................. 10

Investigations .................................................................................................................................................................. 11

Procurement Assistance ................................................................................................................................................. 12

Audits, Inspections, and Evaluations............................................................................................................................. 12

Investigations .................................................................................................................................................................. 13

Agency Management ..................................................................................................................................................... 16

Other Significant OIG Activities ..................................................................................................................................... 18

    OIG Hotline................................................................................................................................................................. 19

Appendix A. Reporting Period Statistical Highlights ................................................................................................... 20

Appendix B. Full Year Statistical Highlights, FY 2020 ................................................................................................. 22

Appendix C. Reports, Recommendations, and Management Decisions .................................................................. 24

Appendix D. Investigations Reporting Statistics .......................................................................................................... 36

Appendix E. Legal Actions Summary ............................................................................................................................ 37

Appendix F. Cosponsored and Other Activities .......................................................................................................... 43

Appendix G. External Peer Reviews .............................................................................................................................. 44

Appendix H. Office of Inspector General Reporting Requirements .......................................................................... 45




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Summary of OIG Oversight Work
Pandemic Response Oversight
SBA’s Disaster Assistance Program is the federal government’s primary program for helping
small businesses, small agricultural cooperatives, and most private, nonprofit organizations after
disasters. SBA offers up to $2 million in economic injury disaster loans to help those eligible to
meet financial obligations and operating expenses.
To support businesses affected by the Coronavirus
Disease 2019 (COVID-19) pandemic, Congress
tasked SBA with lending more than $373 billion in
COVID-19 economic injury disaster funds (EIDLs)
and $20 billion in COVID-19 emergency advance
grants.
The Coronavirus Aid, Relief, and Economic Security (CARES) Act also provided $349 billion for
the creation the Paycheck Protection Program (PPP) under Section 7(a) of the Small Business
Act. Congress added an additional $310 billion to the PPP in April 24, 2020, through the
Paycheck Protection Program and Health Care Enhancement Act .
SBA’s role in the nation’s pandemic response has resulted in the greatest oversight challenge
any OIG in history has ever faced. Our office published a robust oversight plan and immediately
initiated the first reviews focusing on implementation and eligibility of the lending and
entrepreneurial development programs.
SBA’s need to speedily provide relief to small business entities led to reduced controls on
pandemic-related loans and substantially increased risk. It was immediately clear that pandemic
relief efforts had drawn the attention of unscrupulous business owners and greedy criminals.
Within weeks, complaints from lenders and allegations of widespread fraudulent activity
overwhelmed OIG’s Hotline, and we launched hundreds of investigations and initiated audits to
root out the fraud and abuse endangering these critical resources. The following sections
summarize our pandemic oversight work this period.

Audits, Inspections, and Evaluations
During the semiannual period, OIG completed the following work to oversee the resources
allocated for pandemic response:

White Paper: Risk Awareness and Lessons Learned from Prior Audits of Economic Stimulus
Loans
            In this White Paper, we listed a roundup of lessons learned and risks identified in
            previous audits and reviews that SBA should consider to ensure program integrity
            and reduce the risk of financial loss for COVID-19-related loans, which fall under the
            7(a) program.




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SBA has improved controls related to existing loan programs, but we noted several risk areas
that could present challenges in issuing and administering requirements under the COVID-19
loan programs. We detailed key considerations for SBA to ensure
program integrity and the timeliness of loans to eligible small
businesses and to reduce the risk of financial loss.
Our review of previous audits and reviews of economic stimulus loan
programs identified areas of risk in SBA’s 7(a) loan program. We
found SBA did not require program participants to submit
documentation, which resulted in inappropriate or unsupported loan
approvals. We determined that SBA should establish proper controls, such as clear and
consistent guidance and training for new stimulus programs before disbursing funds. The
controls should also ensure that program requirements are updated. (Report 20-11) Access the
White Paper here: https://www.sba.gov/sites/default/files/2020-04/SBA_OIG_WhitePaper_20-
11_508.pdf.

Second White Paper: Risk Awareness and Lessons Learned from Audits and Inspections of
Economic Injury Disaster Loans
            In this White Paper, we listed a roundup of lessons learned and risks identified in
            previous audits and inspections the agency should consider in managing and
            mitigating the risk of loss for COVID-19-related disaster loans. The expected
            increase in loan volumes and amounts and expedited processing timeframes will
            place additional stress on existing controls.
OIG regularly conducts audits and inspections to evaluate management controls and to assess
program integrity, efficiency, and effectiveness of the Disaster Assistance Loan Program. We
compiled findings from those audits and evaluations that identified significant issues and
relevant risks. Previous audits and inspections identified that SBA:
   •   Issued economic injury disaster loans and noneconomic injury disaster loans without fully
       vetting the borrowers’ credit or their ability to repay the loans.
   •   Issued economic injury disaster loans and noneconomic injury disaster loans to
       businesses that did not suffer an economic loss or to businesses outside the timeframe
       of the disaster.
   •   Encountered challenges with having experienced or well-trained staff to provide
       accurate and appropriate assistance to borrowers during large-scale disasters.
To ensure program integrity and reduce the risk of financial loss, SBA should ensure that loans
are provided to eligible applicants timely, that borrowers meet all eligibility requirements, and
that it has experienced or well-trained personnel to provide appropriate assistance and handle
the increased loan volume and expedited processing timeframes. (Report 20-12) Access the
White Paper here: https://www.sba.gov/sites/default/files/2020-04/SBA_OIG_WhitePaper_20-
12_508_0.pdf.




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White Paper: Risk Awareness and Lessons Learned from Prior Audits of Entrepreneurial
Development Programs
             This White Paper identified risks from previous audits and other reviews that SBA
             should consider as it implements mandates to administer federal funds to Small
             Business Development Centers, Women’s Business Centers, and resource partner
             associations related to the COVID-19 pandemic. The increase in federal funds to
             these centers and resource partner associations and expedited timeframes places
additional stress on existing controls.
OIG audits and reviews management controls to assess program integrity, efficiency, and
effectiveness of Small Business Development and Women’s Business Center programs, as well
as previous awards to resource partners for disaster technical assistance. We compiled findings
from those audits and reviews that identified significant issues and relevant risks. (Report 20-13)
Access the White Paper here: https://www.sba.gov/sites/default/files/2020-
04/SBA_OIG_Report_20-13_508.pdf.

Flash Report Small Business Administration's Implementation of the Paycheck
Protection Program Requirements
               On April 24, we began our first review of SBA’s implementation of the Paycheck
               Protection Program. However, when we received requests for information from a
               group of Senators, we produced a Flash Report to detail our preliminary findings.
            We analyzed key provisions of Section 1102 of CARES Act, SBA’s Interim Final
Rules, and public guidance intended to further inform stakeholders of SBA’s implementation of
the PPP. We found that SBA’s Interim Final Rules for implementing the PPP and SBA’s
Frequently Asked Questions mostly aligned with the Act.
We identified the following areas, however, that did not fully align with the Act’s provisions:
           •     Prioritizing underserved and rural markets
           •     Loan proceeds eligible for forgiveness
           •     Guidance on loan deferments
           •     Registration of loans
We offered some suggestions for SBA to consider to better align PPP requirements with the
provisions of the CARES Act. (Report 20-14) Access the Flash Report here:
https://www.sba.gov/sites/default/files/2020-05/SBA_OIG_Report_20-14_508.pdf.

Serious Concerns of Potential Fraud in the Economic Injury Disaster Loan Program
Pertaining to the Response to COVID-19
               On July 28, 2020, Inspector General Ware issued a Management Alert to inform
               widespread potential fraud in the Economic Injury Disaster Loan and advance grant
               programs that required immediate attention and action.
           OIG had been inundated with contacts to investigative field offices and the
complaint Hotline reporting more than 5,000 instances of suspected fraud from financial




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institutions. Nearly 3,800 of those reported instances of
suspected fraud came from only six financial institutions.     Management
Nine financial institutions reported a combined total of
$187.3 million in suspected fraudulent transactions.           Alert
OIG suggested swift management action to engage
financial institutions immediately to identify disbursements that may have been obtained
fraudulently, recover disbursed funds, and prevent additional taxpayer losses. (Report 20-14)
Access the report here: https://www.sba.gov/sites/default/files/2020-07/SBA_OIG_Report_20-
16_508.1.pdf.

Investigations
Houston Entrepreneur Charged with Spending COVID-19 Relief Funds on Improper
Expenses Including Lamborghini and Strip Club
            A Houston man was taken into custody on allegations he fraudulently obtained
            more than $1.6 million in PPP loans. The complaint alleged the individual was
            involved in a scheme to submit fraudulent PPP loan applications to federally insured
            banks and other lenders.
The man allegedly used the loan proceeds not for payroll expenses, but for lavish personal
purchases, such as loan money on a Lamborghini Urus, a Rolex watch, and real estate
transactions. He also allegedly spent thousands at strip clubs and other Houston night clubs.
The complaint further alleged he also used a portion of the loan money to buy a 2020 Ford F-
350 pickup truck.
Find more information here: https://www.justice.gov/usao-sdtx/pr/houston-entrepreneur-
charged-spending-covid-relief-funds-improper-expenses-including.

Nine Charged with $24 Million in Fraudulent Small Business Administration Paycheck
Protection Program Loans
             The owner of a Florida talent management company and four others were charged
             in complaints for their alleged participation in a scheme to file fraudulent loan
             applications seeking more than $24 million in PPP loans. Many of those loan
             applications were approved and funded by financial institutions, paying out at least
             $17.4 million.
“The defendants allegedly participated in an extensive nationwide scheme to file at least 90
fraudulent applications for millions of dollars in PPP loans in exchange for illegal kickbacks of
portions of the loan proceeds,” said an Acting Assistant Attorney General of the Justice
Department’s Criminal Division. Find more information here:
https://www.justice.gov/opa/pr/nine-charged-24-million-covid-relief-fraud-scheme.




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NFL Player Charged in South Florida Federal Court for Alleged Role in $24 Million
COVID-19 Fraud Scheme
            Federal prosecutors charged an NFL player for his alleged participation in a
            scheme to file fraudulent loan applications seeking more than $24 million in
            forgivable PPP loans.
            The complaint alleged the NFL player conspired with others to fraudulently secure
            millions of dollars loans. Early in the scheme, an individual allegedly got a
fraudulent PPP loan for his talent management company using falsified documents.
After submitting that application, the individual then began to work with other co-conspirators,
including the NFL player, on a scheme to submit numerous fraudulent PPP loan applications for
loan applicants and take kickbacks in return for getting the forgivable loans for them.
The scheme involved the preparation of at least 90 fraudulent applications worth more than $24
million dollars. Many of those loan applications were approved and funded by financial
institutions, paying out at least $17.4 million. Access more information here:
https://www.justice.gov/usao-sdfl/pr/nfl-player-charged-south-florida-federal-court-alleged-role-
24-million-covid-relief.

Two Men Charged in Miami Federal Court for Exploiting Exploit Covid-19 Relief
Programs
            Federal prosecutors charged two Florida residents with bank fraud conspiracy for
            allegedly using synthetic identities to commit crimes, including defrauding banks
            and stealing more than $3 million from Covid-19 relief programs.
             Synthetic identities combine stolen real identity information, such as social security
             numbers, with fraudulent identity information, such as fake names and dates of
birth. Criminals create synthetic identities and use them to open fraudulent bank and credit card
accounts and make fraudulent purchases.
From about April through July of 2020, members of the conspiracy allegedly used the already-
established synthetic identities and associated shell companies to fraudulently apply for PPP
help. According to the complaint, the defendants fraudulently sought and received more than
$3 million dollars in PPP relief. This money was paid to companies registered to the synthetic
identities. Access more information here: https://www.justice.gov/usao-sdfl/pr/two-men-who-
allegedly-used-synthetic-identities-existing-shell-companies-and-prior-0.

Florida Man and Two Massachusetts Men Charged in Scheme to Defraud PPP and EIDL
Programs
            A Florida man and two Massachusetts men were charged and arrested in the
            Southern District of Florida for their alleged participation in a fraud and money
            laundering-ring established in 2019 to carry out fraudulent email schemes. The men
            later used the scheme to fraudulently secure about $2 million from Covid-19 relief
            programs.




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The criminal complaint charges one of the Massachusetts men and the Florida man with counts
of bank fraud, and money laundering. Both were arrested. The other Massachusetts man was
also charged with false statements and aggravated identity theft and is still at large.
The investigation disclosed that in June and July 2020, these men used inactive, as well as newly
created shell companies to submit false and fraudulent loan applications under two government
relief programs to receive almost $2 million in government funding.
OIG conducted the investigation jointly with the Federal Bureau of Investigation, Miami Division;
Treasury Inspector General for Tax Administration; Cyber Crimes Division, Washington, D.C.;
the United States Secret Service, Miami; and the Federal Deposit Insurance Corp. Office of
Inspector General, Miami, in conjunction with the U.S. Attorney’s Office.

Virginia Man Indicted for Defrauding COVID-19 EIDL Program.
            A Virginia man was indicted in the Eastern District of Virginia on multiple counts of
            wire fraud, false statements to a financial institution, engaging in monetary
            transactions in property derived from specified unlawful activity, and theft of
            government property.
             The indictment was based on evidence that he fraudulently obtained a Covid-19
EIDL. The application contained false statements about his business, income, and criminal
history, qualifying the man for a $197,000 EIDL loan.
The Virginia man also applied for a second EIDL using false information about a second
business. This loan was not funded. Additionally, he applied for a PPP that was not funded.
OIG conducted the investigation jointly with the U.S. Postal Inspection Service, the Federal
Bureau of Investigation, and the Internal Revenue Service-Criminal Investigation, under the
direction of the U.S. Attorney’s Office, Eastern District of Virginia, Newport News Division.




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Small Business Access to Capital
SBA provides small businesses with capital and financial assistance through several key
programs. SBA has a financial assistance portfolio of guaranteed and direct loans that totaled
about $623 billion as of June 30, 2020.Over the years, OIG has worked closely with the agency
to identify potential points of risk and improve SBA’s oversight and controls to ensure eligible
participants most in need of assistance benefit from these programs.
For example, the agency’s largest lending program, the Section 7(a) Loan Program, is SBA’s
principal vehicle for providing small businesses with access to credit that cannot be obtained
elsewhere. Proceeds from a 7(a) loan may be used to establish a new business or to assist in
acquiring, operating, or expanding an existing business. This program relies on numerous
outside parties (such as borrowers, loan agents, and lenders) to complete loan transactions.
SBA has centralized many loan approval and servicing functions and reduced the number of
staff performing these functions, placing more responsibility on and giving greater
independence to lenders. Past OIG reviews have reported on these trends, and OIG continues
to identify weaknesses in SBA’s lender and loan agent oversight processes.
Criminals use a wide array of techniques to fraudulently get—or induce others to obtain—SBA-
guaranteed loans. The techniques include submitting fraudulent documents, making fictitious
asset claims, manipulating listed property values, using loan proceeds contrary to the terms of
the loans, and failing to disclose debts or previous criminal records. Consequently, there is a
greater chance of financial loss to the agency and its lenders. OIG dedicates a significant
portion of its resources to identifying wrongdoers and, whenever possible, recovering taxpayer
funds.

Audits, Inspections, and Evaluations
Office of Inspector General High Risk 7(a) Loan Review Program
            This Management Advisory presented the evaluation results of one 7(a) loan as part
            of our High-Risk 7(a) Loan Review Program. We set out to determine if the high‐
            dollar/early‐defaulted 7(a) loans were originated and closed in accordance with
            SBA rules, regulations, policies, and procedures and whether material deficiencies
            existed that warranted recovery of guaranteed payments to lenders.
Our review of one high-dollar/early defaulted 7(a) loan showed the lender did not provide
sufficient evidence to support that it had closed the loan in accordance with SBA’s
requirements. The lender did not have adequate documentation to substantiate reasonable
assurance that it met requirements for equity injection.
As a result, the lenders’ material noncompliance with SBA requirements while closing the loan
resulted in a potential loss to SBA of approximately $2.1 million. We recommended that SBA
require the lender to bring the loan into compliance or seek recovery of approximately $2.1
million. SBA management agreed with the recommendation and said if the problems were not
corrected, SBA would recover the funds from the lender. Access Report (20-18) here:
https://www.sba.gov/sites/default/files/2020-08/SBA%20OIG%20Report%2020-18.pdf.




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Investigations
Former Maryland Bank President Pled Guilty in Bank Fraud Scheme
             A Maryland woman, who was a former President of Maryland Bank, pled guilty in
             federal court on multiple counts of conspiracy, bribery, and false statements. The
             woman had been previously indicted on similar charges.
            The investigation disclosed that from 2012 to 2013, the woman conspired with an
            agent of a real estate development company to defraud the Maryland bank and
another bank by purchasing a home through false pretenses, representations, and promises.
The woman agreed to help the agent secure a $650,000 line of credit from the Maryland Bank in
exchange for the agent agreeing to serve as the straw purchaser of a property sought by the
woman.
OIG jointly conducted the investigation with the Federal Housing Finance Agency, Office of
Inspector General; the Federal Deposit Insurance Corporation, Office of Inspector General; and
the Special Inspector General for the Troubled Asset Relief Program, under the direction of the
U.S. Attorney’s Office, U.S. District of Maryland.

North Carolina Man Indicted in SBA Bank Fraud Scheme
            A North Carolina man was indicted on multiple counts of aggravated identity theft,
            bank fraud, wire fraud, concealment of money laundering, and false statements to a
            bank in connection with his application for two SBA 7(a) loans totaling $845,200.
             The indictment was based on evidence that man fraudulently obtained two SBA-
             guaranteed 7(a) loans totaling $845,200 by making various false statements and
submitting fraudulent documents, including fraudulent applications and fake supporting
documentation. As part of his fraudulent schemes, he also stole the identity of at least one
individual and used various falsified documents in the victim’s name, including a falsified United
States passport.
The North Carolina man used the fraudulently obtained funds for personal expenses such as
trips to casinos, rent and car payments, and purchases at restaurants and bars throughout North
Carolina, Florida, and Las Vegas.
OIG conducted the joint investigation with the FBI, under the direction of the U.S. Attorney’s
Office, Western District of North Carolina, Charlotte Division.

Georgia Reality Television Personality Indicted for Ponzi Scheme
            A Georgia reality television personality was indicted on multiple counts of wire
            fraud, bank fraud, false statements, and money laundering in the Northern District
            of Georgia in an elaborate Ponzi scheme. The indictment alleged that from
            approximately August 2014 through May 2020, the TV personality posed as the
            owner of a profitable trucking business.
The trucking business never generated enough revenue to cover its expenses. However, the
personality persuaded approximately 20 individuals to invest more than $5 million in his
trucking business.


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The man promised he would use the investors’ money to purchase and operate trucks. Instead,
he used the investors’ money to pay his personal debts and expenses and fund an extravagant
lifestyle for himself. During the wire fraud scheme, he transferred more than $5 million to a
casino to cover his personal gambling and entertainment expenses.
The TV personality also signed and applied for an SBA-guaranteed PPP loan in the name of his
trucking business, stating that the business had 107 employees and an average monthly payroll
of $1,490,200. Seeking a loan in the amount of $3,725,500, he certified the loan proceeds
would be used to “retain workers and maintain payroll or make mortgage interest payments,
lease payments, and utility payments, as specified under the Paycheck Protection Program
Rule.”
Instead, he used the money for unauthorized personal expenses such as paying past-due child
support, paying restitution in a previous fraud case, cash withdrawals, custom jewelry, the
purchase of a Rolls-Royce car, payments to associates assisting in the Ponzi scheme, and
payments to help an associate start a new business.
The personality allegedly structured these financial transactions to conceal and disguise the
nature, location, source, ownership, and control of the proceeds. When the PPP lender became
suspicious of information provided in support of the SBA PPP loan application, the personality
submitted false bank statements for the trucking business although the account had been
closed.
OIG conducted the joint investigation with the Federal Bureau of Investigation and U.S.
Attorney’s Office, Northern District of Georgia.

California Man Charged for Making False Statements to Secure SBA Loans
            In 2019, a California man made several material omissions and false statements to
            secure two loans to his business for a total of approximately $5 million from an SBA
            preferred lender. SBA guaranteed 75 percent of the loans from the lender to the
            business under the SBA’s Section 7(a) program.
             In 2020, the man applied for and received approximately $1.7 million through the
PPP from another lender. In the application, he falsely certified he paid employee salaries and
payroll taxes. In fact, he had not been paying payroll taxes for employees as required since mid-
2019. In May 2020, a criminal complaint was issued and in June the man was arrested for
making false statements and omissions to obtain SBA loans.




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Disaster Assistance Program
Disaster assistance has been part of the agency since its inception in 1953. Through its Office of
Disaster Assistance, SBA provides long-term, low-interest financial assistance to businesses of all
sizes, private nonprofit organizations, homeowners, and renters following a disaster. Each year,
SBA approves hundreds of millions of dollars in disaster assistance loans.
The Disaster Loan Program is the only form of SBA assistance not limited to small businesses.
The program’s disaster loans are the primary form of federal assistance for repairing and
rebuilding nonfarm, private sector disaster losses.
The program includes four categories of loans for disaster-related losses:
           •   Home disaster loans
           •   Business disaster loans
           •   Economic injury disaster loans
           •   Military reservist economic injury loans

Audits, Inspections, and Evaluations
Audit of SBA’s Compliance with the Debt Collection Improvement Act, as Amended
            This report presented the results of our audit to determine if SBA was in compliance
            with the Debt Collection Improvement Act of 1996, as amended, for delinquent
            disaster loans as of April 30, 2019. Under the law as amended in 2014, if a disaster
            loan is delinquent for 120 days, the SBA is required to refer the debtors to the U.S.
            Department of the Treasury Offset Program for administrative offset. The Act also
requires SBA to transfer all disaster loans that are 180-days delinquent to Treasury for collection
action unless they are exempt.
We found SBA was not fully in compliance with the Debt Collection Improvement Act, because
the agency had not sent more than 250 past-due loans totaling more than $30.5 million and 180
days or more delinquent to Treasury Cross-Servicing for collection. None of the 250 loans that
SBA was maintaining without sending to Treasury Cross-Servicing were exempt from collection
action.
In addition, several delinquent loans were incorrectly classified as exempt from transfer to
Treasury for collection. In our sample of 20 loans, eight (40 percent) totaling $1.2 million, were
incorrectly classified as exempt.
We recommended and SBA agreed to 10 actions to strengthen its controls and improve
compliance with the Debt Collection Improvement Act. Management’s implemented and
planned actions will resolve all our recommendations, including conducting loan reviews,
revising, and establishing policies and procedures, and conducting training to ensure
compliance with the Debt Collection Improvement Act. (Report 20-20) Access the report here:
https://www.sba.gov/sites/default/files/2020-09/SBA%20OIG%20Report%2020-20.1.pdf.




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                        U.S. Small Business Administration | Office of Inspector General


Investigations
Customs and Border Protection Agent Sentenced for Hurricane Harvey Fraud Disaster
Fraud
            An employee of the US Department of Homeland Security, Customs and Border
            Protection, pled guilty in federal court to engaging in monetary transactions in
            property derived from specified unlawful activity. The Texas man was sentenced to
            3 years of probation, and his federal employment terminated.
              He had received $53,000 for alleged damage caused by Hurricane Harvey to a
residential rental property in Houston. The man failed to send in receipts and refused an onsite
inspection of the damaged property. The investigation revealed that the property received no
hurricane damage and that he had used the funds to pay off credit cards and send an
international wire to a friend in Kenya.
We conducted this investigation jointly with the Department of Homeland Security OIG.




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U.S. Small Business Administration | Office of Inspector General


Procurement Assistance
Each year, the federal government spends hundreds of billions of dollars in federal contracts to
purchase goods and services. SBA has worked to maximize opportunities for small business
firms to receive these contract awards. In FY 20, the federal government aimed for 23 percent of
these award dollars to go to small businesses, as mandated in the Small Business Act.
SBA has specific programs that focus on strengthening particular types of small businesses,
including firms owned and controlled by service-disabled veteran-owned small businesses and
women-owned small businesses, as well as small businesses that are disadvantaged or located
in historically underused business zones (HUBZones).
The HUBZone Program helps small businesses stimulate their economically challenged local
economies. Similarly, to help small, disadvantaged businesses gain access to federal and private
procurement markets, SBA’s Section 8(a) Business Development Program offers a broad range
of business development support, such as mentoring, procurement assistance, business
counseling, training, financial assistance, surety bonding, and other management and technical
assistance.
SBA also aids existing and prospective small businesses through a variety of counseling and
training services offered by partner organizations. Among these partners are small business
development centers, the SCORE Association, and women’s business centers.
SBA also designed the Boots to Business Program to provide transitioning service members
interested in exploring business ownership or other self-employment opportunities with
technical assistance and access to information on available resources and on start-up capital.
These programs require effective and efficient management, outreach, and service delivery.

Audits, Inspections, and Evaluations
SBA's Corrective Actions to Reduce 8(a) Firms Eligibility Risks
            This report presented the results of our inspection of SBA’s corrective actions for
            two recommendations made in previous Office of Inspector General audit reports
            on the 8(a) Business Development Program. Our most recent audits of SBA’s 8(a)
            program have identified internal control weaknesses that allowed ineligible firms to
            be certified and participate in the program.
This follow-up inspection focused on two significant weaknesses OIG identified during previous
reviews of SBA’s 8(a) program eligibility and continuing eligibility processes.
In SBA OIG Audit Report 16-13, SBA’s 8(a) Business Development Program Eligibility, we
reported that SBA did not properly document that 8(a) firms admitted in the program met all
eligibility criteria because managers overturned lower-level reviewers’ recommendations for
denial without fully documenting how the identified eligibility concerns had been resolved.
In addition, in SBA OIG Audit Report 18-22, Improvements Needed in SBA’s Oversight of 8(a)
Continuing Eligibility Processes, we reported that SBA did not perform required continuing
eligibility reviews when it received specific and credible complaints about firm eligibility and did
not log all complaints referred by the OIG Hotline.



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                        U.S. Small Business Administration | Office of Inspector General

We inspected SBA’s corrective actions for two recommendations made to address these
weaknesses and verified the corrective actions SBA implemented effectively ensured that
program officials justified their recommendations to admit firms applying to the 8(a) program
and program officials tracked complaints received about firms’ participating in the 8(a) program.
(Report 20-19) Access the report at: https://www.sba.gov/sites/default/files/2020-
09/Final%20Report%20-%208%28a%29%20BD%20Program%20follow%20up-508.pdf


Investigations
Oklahoma Man to Pay More than $1.3 Million in Restitution
            An Oklahoma man was sentenced in federal court to 48 months in prison and
            ordered to pay $1,355,068 in restitution for his role in a conspiracy to commit
            bribery and theft by an agent of an Indian tribal government receiving federal
            funds. This investigation was based on allegations received from the Federal
            Bureau of Investigations about an Oklahoma tribally owned Section 8(a) company.
The company was formed by a former tribal town chief. Even though the tribal town was a 51
percent owner of the 8(a) company, the town had no oversight and was not even sure what
services the 8(a) company performed.
Although the tribal town had requested financial documents from the 8(a) company for several
years, the 8(a) company declined to provide documents, claiming they were classified because
of the nature of the contracts the 8(a) company serviced. In addition, other tribal town elected
officials alleged that the former chief had formed the 8(a) company for his personal gain.
The investigation determined that the Oklahoma man helped establish the 8(a) company and
other business entities established under the tribal town. He and a woman serving as the
controller and chief financial officer for these tribal town-owned businesses diverted funds to the
man for personal expenses unrelated to tribal town business. Between 2012 and 2019, the
unauthorized withdrawals from the business entities were more than $1.2 million.
Finally, a second man, the chairman of the Economic Development Authority of the tribal town,
engaged in wrongdoing. The authority identified, planned, initiated, and developed economic
strategies and activities on behalf of the town. The chairman pled guilty to accepting $61,900 in
payments from the Oklahoma man who intended to influence or reward the chairman in
deciding ongoing or future business transactions for the town. The chairman was sentenced to
12 months in prison and ordered to pay a $10,000 fine.

Five Ohio Individuals Sentenced in Bribery Scheme
            Five people in Ohio were sentenced in schemes to defraud SBA, the U.S. Navy, Air
            Force, Department of Defense, and the Department of Veterans Affairs by paying
            bribes and fraudulently obtaining at least $15 million in government set-aside
            contracts.
            One individual owned several businesses that had been part of the SBA’s 8(a)
Business Development Program. One business had graduated from the program in late 2009
and was no longer eligible for the 8(a) set-aside contracts.



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U.S. Small Business Administration | Office of Inspector General

The primary subject recruited 8(a) and veteran-owned small businesses to bid on contracts and
pass them through to other ineligible businesses in exchange for a fee. On at least two
occasions, the primary subject also purchased 49 percent of the 8(a) or the veteran-owned small
business.
In addition, a civilian engineering technician for the United States Navy accepted a series of
bribes and kickbacks, including cash, meals, a hunting trip, a fence, and a vehicle, in return for
using his official position with the Navy to the defendants their businesses. These benefits
included assistance in finding and securing government contracts and approval of invoices for
payments to pass-through companies used by the defendants.
One man was sentenced to 36 months’ probation and a $15,900 fine, two individuals were
sentenced to 24 months’ probation and ordered to pay $10,200 and $5,300. Two additional
individuals were sentenced to 12-month probation and ordered to pay $5,000 fines.
OIG conducted this investigation jointly with the NASA Office of Inspector General, Department
of Defense Criminal Investigative Service, Department of Veterans Affairs Office of Inspector
General, and the Naval Criminal Investigative Service.

Georgia Man Pled Guilty for Participation in 8(a) Program Kickback and Bribery Scheme
            A Georgia man who owned a defense contracting company entered a guilty plea in
            the Southern District of Georgia on a charge of conspiracy. By entering the plea, he
            admitted to participating in a kickback and bribery scheme involving government
            contracts at Fort Gordon, Georgia, to build and modernize its communications
            network. The scheme involved active duty and retired military personnel. The man
agreed to forfeit $1,131,861.66.
OIG conducted the investigation jointly with U.S. Army Criminal Investigation Division
Command and the Defense Criminal Investigative Service. Prosecution is being handled by the
U.S. Attorney's Office, Southern District of Georgia, Augusta Division, Augusta, Georgia.

Virginia Business and a Group of Seven Individuals Indicted for Defrauding SBA Service-
Disabled Veteran-Owned Small Business Program
            A Virginia-based business and seven participating individuals were indicted in the
            Eastern District of Virginia and charged with multiple counts of conspiracy to
            defraud and commit offenses against the United States, wire fraud, mail fraud, entry
            of goods falsely classified, entry of goods by false statements, smuggling goods,
            and criminal forfeiture.
The indictment alleged that from at least 2011 through 2018, the group repeatedly and
fraudulently violated federal contracting requirements by engaging in fraud related to the
Service-Disabled Veteran-Owned Small Business set-aside program and sourcing merchandise
from China and concealing such supplying of merchandise to the United States and its
agencies.
The company received three set-aside contracts by using an unindicted figurehead owner to
appear to comply with the contracting requirements governing such contracts. The company




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                        U.S. Small Business Administration | Office of Inspector General

was awarded various federal government contracts that required it to comply with the Buy
American Act, the Berry Amendment, and the Trade Agreements Act.
Even though the group was subject to such requirements, they repeatedly tried to bring in
merchandise manufactured in China and falsely represented to various government contracting
agencies that the merchandise was made in the United States.
OIG conducted the case jointly with the Defense Criminal Investigative Service, the Naval
Criminal Investigative Service, U.S. Immigration and Customs Enforcement, and the U.S.
Department of State, Office of Inspector General. The U.S. Attorney’s Office for the Eastern
District of Virginia, Newport News Division, is handling the prosecution.

Washington Man Created Alias to Fraudulently Obtain Government Contracts
            The investigation revealed the man used various aliases to procure government
            contracts. The individual was debarred from government contracting from 2014 to
            2017. During that time, he formed various small businesses with associates to bid
            on and be awarded set-aside contracts.
            Companies he financially controlled during the period of debarment were awarded
69 federal contracts valued at more than $1 million. Many of the contracts were set-aside for
small businesses. Once awarded contracts, he devised a scheme to defraud other government
contractors by subcontracting the work and not making payment to those subcontractors.
In another scheme to defraud government contractors, he presented himself as a federal
contracting official, created fictitious contracting documents, and passed said documents to
victim businesses to perform work under the false understanding they had been awarded a
prime contract with the U.S. government. Once the contracts were complete, those victim
businesses were unable to obtain payment.
OIG conducted the investigation in conjunction with the Defense Criminal Investigative Service;
U.S. Army Criminal Investigation Command, Major Procurement Fraud Unit; General Service
Administration, Office of Inspector General; U.S. Department of Health and Human Services,
Office of Inspector General; U.S. Department of Justice, Office of Inspector General; Internal
Revenue Service Criminal Investigation Division; U.S. Department of State, Office of Inspector
General; Department of Homeland Security, Office of Inspector General; Department of
Commerce, Office of Inspector General.




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U.S. Small Business Administration | Office of Inspector General


Agency Management
OIG is responsible for ensuring that agency management appropriately safeguards SBA from
fraud, waste, and abuse, and that SBA activities directly further agency goals. As part of these
efforts, OIG works with the offices of the Chief Financial Officer, the Chief Information Officer,
and the Chief Operating Officer to review financial reporting and performance management,
human resources, procurements and grants, space and facilities, and maintenance of SBA’s
information systems and related security controls.

Audits, Inspections, and Evaluations
Independent Auditors’ Report on SBA’s Compliance with Improper Payments Act
           We contracted with independent certified public accounting firm KPMG LLP for a
           performance audit as required by the Improper Payments Elimination and Recovery
           Act of 2010 (IPERA). The objectives of the engagement were to review the payment
           integrity section of SBA’s FY 2019 Agency Financial Report to determine whether
           the agency is in compliance with the Improper Payments Information Act of 2002,
as amended. KPMG also evaluated the agency’s accuracy and completeness of reporting and
performance in reducing and recapturing improper payments.
KPMG conducted the engagement in accordance with consulting services standards
established by the American Institute of Certified Public Accountants, the standards applicable
to performance audits contained in the U.S. Government Accountability Office’s Government
Auditing Standards issued by the Comptroller General of the United States, and guidance as
defined by the Council of the Inspectors General on Integrity and Efficiency’s “Guidance for
Improper Payments Elimination and Recovery Act Compliance Reviews.”
The attached independent auditors’ report presents KPMG’s findings on the agency’s improper
payment reporting required under IPERA. KPMG reported:
       •   SBA complied with the six IPERA reporting requirements.
       •   Improvement was needed over the completeness and accuracy of improper payment
           reporting.
       •   SBA reduced the improper payment rates for most programs.
The report contains four recommendations to improve the effectiveness of improper payment
controls. These recommendations will remain open until OIG receives documentation
demonstrating that these recommendations have been addressed. (Report 20-15) Access the
report here: https://www.sba.gov/sites/default/files/2020-05/SBA_OIG_Report_20-15_508.pdf

Evaluation of Certify.SBA.gov
              This report presents the results of our evaluation of SBA’s most recent information
              technology (IT) initiative intended to improve SBA’s small business contracting
              programs, Certify.SBA.Gov. Our scope included Certify’s development,
              implementation, and oversight from FYs 2015-19. SBA’s Business Technology
              Investment Committee ratified Certify’s objectives and approved an 11-year project
lifecycle cost estimate of $45 million on May 20, 2015.



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                        U.S. Small Business Administration | Office of Inspector General

Certify was envisioned to be the single gateway to all of SBA’s contracting programs and a
vehicle to improve small business participation in federal contracts. The primary goal of Certify
was to streamline the certification process and improve productivity by providing management
views of in-progress applications, automate repetitive tasks, make document review
straightforward, and provide tools for identifying fraud, waste, and abuse.
                               We found that Certify has not accomplished its objectives to
                               significantly improve SBA’s certification processes or facilitate
                               small business participation in federal contracts. Although SBA
                               has spent 5 years and more than $30 million on the development
                               of Certify and it offers some improved functionality, it does not
                               have many of the essential search, analytical, and reporting tools
                               it was supposed to have.
To compensate for Certify’s shortcomings, program analysts must use labor intensive methods
external to the Certify platform, reducing Certify’s expected benefits for both SBA contracting
program analysts and program participants.
We identified a need for improved planning and performance oversight throughout this project.
As a result, Certify did not meet its original goal of improving SBA’s small business certification
process, and the $30 million investment has not yielded its intended results. Moving forward,
SBA plans to migrate to another platform to address Certify’s limitations. However, until SBA
addresses these oversight weaknesses, there is a continued risk of repeating past project
shortcomings.
We made nine recommendations to improve SBA’s system development and contracting
program management in the following areas: requirements, baseline management, risk
management, investment monitoring, and reporting. Although SBA management agreed or
partially agreed with all recommendations, its planned actions only resolved three
recommendations. We will work with SBA management to resolve the remaining six
recommendations through the audit follow-up process. (Report 20-17) Access the report here:
https://www.sba.gov/sites/default/files/2020-07/SBA_OIG_Report_20-17_508.pdf




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U.S. Small Business Administration | Office of Inspector General


Other Significant OIG Activities
OIG Background Investigations Ensure Integrity
During this reporting period, OIG initiated 53 background investigations and issued 5 security
clearances for OIG employees and contractors. OIG adjudicated 10 background investigative
reports.

OIG Promotes Debarment and Other Administrative Enforcement Actions
OIG promotes program integrity by making present responsibility referrals to SBA and other
agencies. Present responsibility means the business ethics, integrity, honesty, and competence
of vendors. These present responsibility referrals often result in suspensions, debarments, and
similar administrative enforcement actions.
These actions protect taxpayer funds from contract vendors who are not a good risk for the
government. During this reporting period, OIG sent three present responsibility referrals to
SBA.
A typical OIG referral contains a summary of allegations, evidence supporting the case, and a
draft notice of suspension or proposed debarment in certain instances. Most OIG administrative
referrals involve SBA’s loan and contract programs. OIG ensures that a suspension and
debarment official reviews all appropriate allegations arising in other contexts, such as the
investigation of False Claims Act cases.

OIG Trains Multiple Agencies on Small Business Procurement Integrity and
Other Oversight Concerns
On May 6, 2020, we presented the sixth annual Small Business Procurement Integrity Seminar
virtually. The event was a continuation of our partnership with the Council of the Inspectors
General on Integrity and Efficiency Training Institute. We trained almost 100 members of the
federal oversight community to identify, develop, and pursue small business contracting fraud.

OIG Reviews of Proposed Agency Regulations, Operating Procedures, and
Other Initiatives Lead to Improved Program Controls
OIG reviews changes SBA proposes to make to its program directives, such as regulations,
internal operating procedures, agency policy notices, and SBA forms completed by the public.
OIG often identifies material weaknesses in the proposals and works with the agency to
promote more effective controls to deter waste, fraud, and abuse. During the reporting period,
OIG reviewed 67 proposed revisions of these program directives and submitted comments
designed to improve 27 of these initiatives.

2004 Legislation Requires SBA Regulations and OIG Approval of SBDC
Surveys
In December 2004, Congress amended Section 21(a)(7) of the Small Business Act (15 U.S.C.
648(a)(7)) to restrict disclosing information regarding individuals or small businesses that have



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                         U.S. Small Business Administration | Office of Inspector General

received assistance from a Small Business Development Center and limit the agency’s use of
such information. The provision also required SBA to issue regulations about disclosures of the
information for use in conducting financial audits or SBDC client surveys. In 2009, SBA officials
told OIG the agency would issue regulations as required by the statute. In April 2014, SBA sent
the proposed regulations for publication in the Federal Register for public comment.
In addition, Section 21(a)(7) of the Small Business Act states that until these Small Business
Development Center information disclosure regulations are issued, the Inspector General must
approve any related client survey, as well as the use of any survey information, and must also
include this approval in OIG’s Semiannual Report to Congress. SBA did not submit any surveys
OIG review during the reporting period.

OIG Hotline
OIG’s Hotline reviews allegations of waste, fraud, abuse, or serious mismanagement within SBA
or its programs from employees, contractors, and the public. During this reporting period, the
Hotline received 104,913 complaints, 100 times more than the total of 742 complaints received
in 2019.
                                Complaints come to OIG via online submission on the SBA OIG
                                website, telephone, e-mail, and posted mail. Hotline staff
                                conducts a preliminary review of each allegation and may consult
                                with OIG’s Investigations Division, Audits Division, and Office of
                                Counsel to determine the appropriate course of action.
                               Referrals within OIG may result in corrective actions, audits, or
                               administrative, civil, or criminal investigations. Matters referred to
SBA program offices for further action are monitored by Hotline staff for prompt response,
adequate resolution of the allegations, and documentation of any corrective action taken.
In 2020, OIG was recertified under the Office of Special Counsel 2302(c) Certification Program.
The program requires federal agencies to inform their workforces about the rights and
remedies available to them under the Whistleblower Protection Act, the Whistleblower
Protection and Enhancement Act, and related civil service laws. In accordance with the
certification requirements, the whistleblower coordinator trained all OIG and agency employees
on protections against whistleblower retaliation and other prohibited personnel practices. OIG
was initially certified in 2015.
Comprehensive information on whistleblower protection may be found here:
https://www.sba.gov/oig/whistleblower-rights-and-protection.




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U.S. Small Business Administration | Office of Inspector General


                                              Appendixes
Appendix A. Reporting Period Statistical Highlights
Summary of OIG Dollar Accomplishments in dollars ($)
 Dollar Accomplishments as a Result of Investigations and Related
 Activities
 Potential Investigative Recoveries and Fines                                  46,747,462
 Asset Forfeitures Attributed to OIG Investigations                                     0
 Loans/Contracts Not Approved or Canceled as a Result of                       26,293,440
 Investigations
 Investigations Subtotal                                                       73,040,902
 Dollar Accomplishments as a Result of Audit Activities
 Disallowed Costs Agreed to by Management                                      51,472,944
 Recommendations that Funds Be Put to Better Use Agreed to by
 Management
 Audit Subtotal                                                                51,472,944
 Total OIG Dollar Accomplishments                                            $124,513,846



Efficiency and Effectiveness Activities Related to Audit, Other Reports, and Follow-up
Activities
 Reports Issued                                                                       10
 Recommendations Issued                                                               24
 Dollar Value of Costs Questioned                                                     $0
 Dollar Value of Recommendations that Funds Be Put to Better Use                      $0
 Recommendations with Management Decisions                                            33
 Recommendations without a Management Decision                                        13
 Collections as a Result of Questioned Costs                                    $347,673



Indictments, Convictions, and Case Actions
 Indictments from OIG Cases                                                          47
 Convictions from OIG Cases                                                           8
 Cases Opened                                                                       257
 Cases Closed                                                                        62



SBA Personnel Actions Taken as a Result of Investigation
 Dismissals                                                                              1
 Resignations and Retirements                                                            0
 Suspensions                                                                             0
 Reprimands                                                                              1




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Program Actions Taken During the Reporting Period as a Result of OIG Action
Present Responsibility Referrals to the Agency                                                    3
Pending at the Agency as of September 30, 2020                                                   39
Suspensions Issued by the Agency                                                                 50
Proposed Debarments Issued by the Agency                                                          0
Final Debarments Issued by the Agency                                                             5
Proposed Debarments Declined by the Agency                                                        0
Administrative Agreements Entered by the Agency in Lieu of Debarment                              0
Present Responsibility Actions by Other Agencies                                                  0



Agency Legislative and Regulatory Proposals Reviewed
Legislation, Regulations, Standard Operating Procedures, and Other Issuances Reviewed            67
Comments Provided by OIG to Improve Legislation, Regulations, Standard Operating
Procedures, and Other Issuances                                                                  27




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U.S. Small Business Administration | Office of Inspector General


Appendix B. Full-Year Statistical Highlights, FY 2020
Summary of OIG Dollar Accomplishments
 Dollar Accomplishments as a Result of Investigations and
 Related Activities
 Potential Investigative Recoveries and Fines                               $51,389,743
 Asset Forfeitures Attributed to OIG Investigations                             $69,000
 Loans and Contracts Not Approved or Canceled as a Result
 of Investigations                                                          $26,293,440
 Investigations Subtotal                                                    $77,752,183
 Dollar Accomplishments as a Result of Audit Activities
 Disallowed Costs Agreed to by Management                                   $64,796,672
 Recommendations that Funds Be Put to Better Use Agreed
 to by Management                                                                    $0
 Audit Subtotal                                                             $64,796,672
 Total OIG Dollar Accomplishments                                          $142,548,855



Efficiency and Effectiveness Activities Related to Audit, Other Reports,
and Follow-up Activities
 Reports Issued                                                                      20
 Recommendations Issued                                                              91
 Dollar Value of Costs Questioned                                           $64,804,274
 Dollar Value of Recommendations that Funds Be Put to Better Use                     $0
 Recommendations with Management Decisions                                           88
 Recommendations without Management Decisions                                        13
 Collections as a Result of Questioned Costs                                  $393,172



Indictments, Convictions, and Case Actions
 Indictments from OIG Cases                                                          63
 Convictions from OIG Cases                                                          32
 Cases Opened                                                                       295
 Cases Closed                                                                       118



SBA Personnel Actions Taken as a Result of Investigations
 Dismissals                                                                           1
 Resignations and Retirements                                                         1
 Suspensions                                                                          0
 Reprimands                                                                           1




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Program Actions Taken During the Fiscal Year as a Result of OIG Action
 Present Responsibility Referrals to the Agency                                                          47
 Pending at the Agency as of September 30, 2020                                                          36
 Suspensions Issued by the Agency                                                                        24
 Proposed Debarments Issued by the Agency                                                                24
 Final Debarments Issued by the Agency                                                                   27
 Present Responsibility Matters Declined by the Agency                                                    4
 Administrative Agreements Entered by the Agency in Lieu of Debarment                                     1
 Present Responsibility Actions by Other Agencies                                                        15
*OIG does not count matters where SBA has ceded lead agency as declinations



Agency Legislative and Regulatory Proposals Reviewed
 Legislation, Regulations, Standard Operating Procedures, and
 Other Issuances Reviewed                                                                               140
 Comment Memoranda Provided by OIG to Improve Legislation,
 Regulations, Standard Operating Procedures, and Other Issuances                                         28




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U.S. Small Business Administration | Office of Inspector General


Appendix C. Reports, Recommendations, and Management Decisions
Reports Issued

Agency Management
 Title                                                       Report        Issue Date        Questioned    Funds for
                                                             Number                          Costs         Better Use
 Independent Auditors’ Report on SBA’s Compliance with         20-15        5/12/2020                 $0            $0
 Improper Payments Elimination and Recovery Act of 2010
 Evaluation of Certify.SBA.Gov                                 20-17        7/30/2020                $0            $0
 Program Subtotal                                                  2                —                $0            $0



Credit/Capital Programs
 Title                                                       Report        Issue Date Questioned            Funds for
                                                             Number                   Costs                 Better Use
 White Paper: Risk Awareness and Lessons Learned from           20-11        4/3/2020           $0                 $0
 Prior Audits of Economic Stimulus Loans
 Flash Report: Small Business Administration’s                  20-14        5/8/2020                 $0           $0
 Implementation of the Paycheck Protection Program
 Requirements
 Office of Inspector General High Risk 7(a) Loan Review         20-18       8/25/2020                 $0           $0
 Program
 Audit of SBA’s Compliance with the Debt Collection             20-20       9/30/2020                 $0           $0
 Improvement Act, as Amended
 Program Subtotal                                                  4                    —             $0           $0



Disaster Assistance
  Title                                                      Report         Issue Date       Questioned    Funds for
                                                             Number                          Costs         Better Use
  White Paper: Risk Awareness and Lessons Learned from          20-12        4/3/2020                 $0
  Audits and Inspections of Economic Injury Disaster Loans
  Serious Problems and Deficiencies in Internal Controls         20-16      7/28/2020                 $0           $0
  Over Economic Injury Disaster Loan Program Pertaining
  to the Response to COVID-19
  Program Subtotal                                                     2                —             $0           $0



Contracting and Counseling Programs
 Title                                                       Report         Issue Date       Questioned     Funds for
                                                             Number                          Costs          Better Use
 White Paper: Risk Awareness and Lessons Learned from           20-13        4/23/2020                $0            $0
 Prior Audits Entrepreneurial Development Programs
 SBA’s Corrective Actions to Reduce 8(a) Firm Eligibility       20-19        9/15/2020                $0           $0
 Risks
 Program Subtotal                                                   2                    —            $0           $0




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Reports with Questioned Costs
                                                       Reports     Recommendations*            Questioned       Unsupported
                                                                                               Costs**          Costs***
     A.     No management decision made by                     1                         2      $51,472,944       $51,472,944
            March 31, 2020
     B.     Issued during this reporting period                0                         0               $0                $0
     Subtotal (Universe from which                             1                         2      $51,472,944       $51,472,944
     management decisions could be made in
     this reporting period)
     C.     Management decisions made during                   1                         2      $51,472,944       $51,472,944
            this reporting period
            (i) Disallowed costs                               1                         2      $51,472,944       $51,472,944
            (ii) Costs not disallowed                          0                         0               $0                $0
     D.     No management decision made by                     0                         0               $0                $0
            September 30, 2020
*            Reports may have more than one recommendation.
**           Questioned costs found to be improper.
***          Unsupported costs that may be proper but lack documentation. Unsupported costs are a subset of questioned costs.



Reports with Recommendations that Funds Be Put to Better Use
                                                                       Reports         Recommendations           Recommended
                                                                                                                 Funds for
                                                                                                                 Better Use
A.        No Management Decision Made by March 31, 2020                      —                    —                     —
B.        Issued During this Reporting Period                                —                    —                     —
          Subtotal (Universe from which Management                           —                    —                     —
          Decisions Could Be Made in this Reporting Period)
C.        Management Decisions Made During this Reporting                    —                    —                     —
          Period
          (I) Recommendations Agreed to by SBA Management                    —                    —                     —
          (Ii) Recommendations Not Agreed to by SBA                          —                    —                     —
          Management
D.        No Management Decision Made by                                     —                    —                     —
          September 30,2020



Reports from Prior Periods with Overdue Management Decisions
Report Report Title                       Issue Date       Recommendation                    Reason for Delay    Timetable for
Number                                                                                                           Resolution
None this period



Reports from Prior Periods with Open Recommendations as of September 30, 2020
     Report       Title                                            Date Issued         Number of Open           Aggregate
     Number                                                                            Recommendations          Potential Cost
                                                                                                                Savings
     15-16        SBA Needs to Improve Its Oversight of                  9/25/2015                         1                  —
                  Loan Agents
     17-19        Audit of SBA’s Microloan Program                      9/28/2017                          2     $137,199,806
     18-03        Independent Auditor’s Report on the                  11/14/2017                          1                —
                  SBA’s FY 2017 Financial Statements




                                                                    Semiannual Report to Congress, Fall 2020 | 25
U.S. Small Business Administration | Office of Inspector General

 Report   Title                                        Date Issued      Number of Open    Aggregate
 Number                                                                 Recommendations   Potential Cost
                                                                                          Savings
 18-07    Accuracy of the FY 2015 7(a) Loan                12/11/2017                 1      $ 1,903,213
          Guaranty Purchase Improper Payments
          Rate
 18-13    Evaluation of SBA 7(a) Loans Made to               3/6/2018                 1               —
          Poultry Farmers
 18-18    Audit of SBA’s Women-Owned Small                  6/20/2018                 1               —
          Business Federal Contracting Program
 18-21    OIG High-Risk 7a Loan Review Program              8/15/2018                 2      $1,351,565
          2018
 18-22    Improvements Needed in SBA’s Oversight             9/7/2018                 5               —
          of 8(a) Continuing Eligibility Processes
 18-23    OIG High-Risk 7(a) Loan Review Program            9/13/2018                 2      $1,303,403
 19-06    SBA’s District Offices’ Customer Service         12/19/2018                 1               —
 19-08    SBA’s HUBZone Certification Process               3/28/2019                 1       $589,000
 19-14    SBA’s 2018 and 2019 Cash Contributions            6/19/2019                 2               —
          and Gifts
 19-15    OIG High-Risk 7(a) Loan Review Program           7/10/20191                        $3,000,297
 19-16    Office of Inspector General High-Risk 7(a)                                  2      $2,059,132
                                                            8/14/2019
          Loan Review Program
 19-17    Evaluation of SBA’s All Small Mentor-                                       4               —
                                                            9/17/2019
          Protégé Program
 19-18    Audit of SBA's Suspension and                                               1      $2,900,000
                                                            9/18/2019
          Debarment Process
 19-19    Office of Inspector General High-Risk 7(a)                                  1      $1,267,223
                                                            9/19/2019
          Loan Review Program
 19-20    Review of Women's Business Center, Inc.                                     1               —
          Compliance with Cooperative Agreement             9/19/2019
          Requirement
 19-23    Audit of SBA’s Desktop Loss Verification                                    1      $2,524,400
                                                            9/26/2019
          Process
 20-03    Audit of SBA's Oversight of High-Risk                                       6     $13,3135,60
                                                           11/12/2019
          Lenders
 20-05    KPMG Management Letter                                                      2               —
          Communicating Matters Relatives to SBA's         12/10/2019
          FY 2019 Financial Statement Audit
 20-06    SBA’S FY 2019 Cash Contributions and                                        1               —
                                                            2/11/2020
          Gifts
 20-07    Audit of the Office of Disaster Assistance                                  1               —
                                                            2/20/2020
          Improper Payment Appeal Process
 20-08    Audit of the SBA's Community Advantage                                      6     $5,1472,944
                                                            3/18/2020
          Pilot Program
 20-09    Audit of SBA’s Cooperative Agreement                                        3               —
          With Arsenal Business and Technology
                                                            3/24/2020
          Partnership’s Veterans Business
          Outreach Center
          Total                                                                      48    $153,519,682




26 | Semiannual Report to Congress, Fall 2020
                          U.S. Small Business Administration | Office of Inspector General

Significant Recommendations from Prior Reporting Periods without Final Action as of
September 30, 2020
Report      Date Issued    Recommendation                                 Date of      Final Action Target
Number                                                                    Management   Date
                                                                          Decision
15-16       9/25/2015      Develop benchmarks for contractor              9/20/2018    1/31/2021
                           performance and require the Fiscal
                           Transfer Agent to implement
                           appropriate application controls and
                           follow-up procedures with lenders to
                           ensure the integrity of the Form 159
                           database.
17-19       9/28/2017      Continue efforts to improve the                1/4/2018     12/31/2020
                           information system to include outcome-
                           based performance measurements and
                           ensure the data captured can be used
                           to effectively monitor the microloan
                           program compliance, performance, and
                           integrity.
17-19       9/28/2017      Update the microloan reporting system          1/4/2018     12/31/2020
                           manual to reflect current technology
                           capabilities.
18-03       11/14/2017     Monitor and perform procedures over            1/10/2018    3/31/2021
                           the service organization’s attestation
                           report regarding user control
                           considerations. This assessment should
                           be performed annually.
18-13       3/6/2018       Review the arrangements between                3/1/2018     12/31/2020
                           integrators and growers under the
                           revised regulations, and establish and
                           implement controls, such as
                           supplemental guidance, to ensure SBA
                           loan specialists and lenders make
                           appropriate affiliation determinations.
18-18       6/20/2018      Implement a Women-Owned Small                  9/28/2018    10/30/2020
                           Business Federal Contracting Program
                           certification process as required by the
                           National Defense Authorization Act for
                           FY 2015.
18-21       8/15/2018      Require the lender to bring the loan into      8/7/2018     10/30/2020
                           compliance or, if not possible, seek
                           recovery of $799,159 on the guaranty
                           paid by SBA.
18-21       8/15/2018      Require the lender to bring the loan into      8/7/2018     10/30/2020
                           compliance or, if not possible, seek
                           recovery of $552,406 on the guaranty
                           paid by SBA.
18-22       9/7/2018       Revise its current process to ensure it        12/19/2019   11/30/2020
                           accurately identifies all high-risk firms to
                           receive continuing eligibility reviews
                           from the Office of Certification and
                           Eligibility.




                                                          Semiannual Report to Congress, Fall 2020 | 27
U.S. Small Business Administration | Office of Inspector General

 Report     Date Issued   Recommendation                                   Date of      Final Action Target
 Number                                                                    Management   Date
                                                                           Decision
 18-22      9/7/2018      Establish and implement clear policies           12/19/2019   11/30/2020
                          and procedures for evaluating 8(a)
                          continuing eligibility, including ensuring
                          that district offices use standardized
                          analysis tools that conform with 8(a)
                          continuing eligibility requirements
                          found in 13 CFR 124, and train
                          employees on these procedures.
 18-22      9/7/2018      Develop and implement a                          12/19/2019   11/30/2020
                          comprehensive oversight plan to ensure
                          completion of continuing eligibility
                          reviews of all 8(a) firms, monitor the
                          quality of continuing eligibility reviews,
                          and eliminate duplication between the
                          Office of Certification and Eligibility and
                          the district offices.
 18-22      9/7/2018      Establish and implement clear policies           12/19/2020   11/30/2020
                          and procedures that include timelines
                          for sending Notices of Intent to
                          Terminate and to Graduate Early firms
                          after eligibility issues are first identified.
 18-22      9/7/2018      Establish and implement clear policies           12/19/2020   11/30/2020
                          and detailed procedures, consistent
                          with 13 CFR 124.112(c), to promptly and
                          effectively review and address
                          complaints about 8(a) continuing
                          eligibility, including communicating the
                          content of the complaint to the district
                          office, and train employees
                          implementing the 8(a) program on the
                          updated procedures.
 18-23      9/13/2018     Require the lender to bring the loan into        9/20/2018    10/30/2020
                          compliance or, if not possible, seek
                          recovery of $448,287 plus interest on
                          the guaranty paid by SBA.
 18-23      9/13/2018     Require the lender to bring the loan into        9/20/2018    10/30/2020
                          compliance or, if not possible, seek
                          recovery of $855,116 plus interest on
                          the guaranty paid by SBA.
 19-06      12/19/2018    Revise SOP 90 75 4, Outreach Activities,         12/19/2018   1/31/2020
                          to clarify the expectation for using SBA
                          Form 20, Outreach Event Survey, and
                          establish a process to collect and
                          analyze customer feedback.
 19-08      3/28/2019     Implement a plan to reduce IT issues             3/29/2019    9/15/2020
                          affecting the HUBZone certification
                          process.




28 | Semiannual Report to Congress, Fall 2020
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued    Recommendation                               Date of      Final Action Target
Number                                                               Management   Date
                                                                     Decision
19-14    6/19/2019      Develop and implement prescriptive           6/26/2020    1/31/2020
                        and rigorous controls to oversee and
                        monitor excess cash held by the fiscal
                        agent for recurring activities such as
                        NSBW on behalf of SBA and in
                        accordance with the requirements of
                        OMB Circular No. A-123. These controls
                        should be incorporated into SOP 90 75
                        4 and include the receipt and recurring
                        review of bank statements for cash held
                        on account.
19-14    6/19/2019      Implement a process to ensure that           6/26/2020    1/31/2020
                        responsibilities stipulated in the NSBW
                        co-sponsorship agreement are aligned
                        with requirements in SOP 90 75 4.
19-15    7/10/2019      Require the lender to bring the loan into    7/11/2019    10/30/2020
                        compliance or, if not possible, seek
                        recovery of $3,000,297 plus interest on
                        the guaranty paid by SBA.
19-16    8/14/2019      Require the lender to bring the loan into    8/15/2019    10/30/2020
                        compliance or, if not possible, seek
                        recovery of $1,367,417 plus interest on
                        the guaranty paid by SBA.
19-16    8/14/2019      Require the lender to bring the loan into    8/15/2019    10/30/2020
                        compliance or, if not possible, seek
                        recovery of $691,715 plus interest on
                        the guaranty paid by SBA.
19-17    9/17/2019      Develop and implement application            9/17/2019    11/30/2020
                        review and annual evaluation
                        procedures to ensure mentors are
                        qualified, including implementing
                        mandatory use of the mentor
                        certification form.
19-17    9/17/2019      Develop and implement procedures to          9/17/2019    11/30/2020
                        ensure quality and consistency in
                        application reviews and annual
                        evaluations, including maintaining
                        adequate documentation to support
                        completion of each step in the
                        application review and annual
                        evaluation processes.
19-17    9/17/2019      Prioritize staff resources to ensure         2/4/2020     3/31/2021
                        application reviews and annual
                        evaluations are conducted in
                        accordance with regulatory and
                        program requirements.
19-17    9/17/2019      Ensure that certify.SBA.gov has the          9/17/2019    3/31/2021
                        functionality needed for program
                        officials to conduct application reviews
                        and annual evaluations.
19-18    9/18/2019      Rescind the SBA loan guaranty for the        11/13/2019   12/31/2020
                        $2.9 million loan and assess the lender’s
                        eligibility for continued participation in
                        the SBA lending program.




                                                      Semiannual Report to Congress, Fall 2020 | 29
U.S. Small Business Administration | Office of Inspector General

 Report     Date Issued   Recommendation                              Date of      Final Action Target
 Number                                                               Management   Date
                                                                      Decision
 19-20      9/19/2019     Refer the Women's Business Center,          9/19/2019    9/30/2019
                          Inc., and its personnel to the Suspension
                          and Debarment Official for a present
                          responsibility determination.
 19-23      9/26/2019     Implement controls to require loss          9/25/2019    10/2/2020
                          verifiers to provide sufficient
                          documentation to support their post
                          desktop review conclusions regarding
                          the validity of the initial desktop
                          verification and their assessment of the
                          extent of damages and losses and the
                          cost to restore the property to its
                          predisaster condition.
 20-03      11/12/2019    Develop and implement policies and          11/15/2019   12/31/2020
                          procedures to document OCRM's
                          justification for not conducting planned
                          reviews and identifying and prioritizing
                          additional lenders for review.
 20-03      11/12/2019    Develop and implement a                     11/15/2019   12/31/2020
                          comprehensive database to manage its
                          oversight of high-risk lenders to ensure
                          performance of all planned reviews,
                          implementation of risk mitigation
                          actions, and identification of
                          noncompliant lender and systemic
                          material loan deficiencies.
 20-03      11/12/2019    Develop and implement policies and          11/15/2019   12/31/2020
                          procedures to provide clear and specific
                          guidance to analysts regarding the
                          appropriate corrective and enforcement
                          actions for identified lenders and loan
                          deficiencies to ensure analysts
                          recommend appropriate and consistent
                          corrective and enforcement actions.
 20-03      11/12/2019    Conduct periodic overall assessments of     11/15/2019   12/31/2020
                          the high-risk lender review results and
                          recommended risk mitigation actions to
                          ensure analysts recommend appropriate
                          and consistent corrective and
                          enforcement actions.
 20-03      11/12/2019    Develop and implement policies and          11/15/2019   12/31/2020
                          procedures that require OCRM to
                          communicate systemic lender issues
                          and material loan deficiencies to the
                          appropriate SBA loan approval and
                          purchase centers to facilitate proactive
                          portfolio management and to mitigate
                          the risk of improper guaranty purchases
                          in the event of default.




30 | Semiannual Report to Congress, Fall 2020
                       U.S. Small Business Administration | Office of Inspector General

Report   Date Issued    Recommendation                               Date of      Final Action Target
Number                                                               Management   Date
                                                                     Decision
20-03    11/12/2019     Determine whether the lenders                11/15/2019   12/31/2020
                        corrected the deficiencies on the 21
                        loans purchased for a total of $13.3
                        million. If not, require the lenders to
                        bring the loans into compliance or, if not
                        possible, seek recovery of the guaranty
                        paid by SBA from lenders.
20-05    12/10/2019     KPMG recommends Associate                    1/9/2020     1/31/2021
                        Administrator for Capital Access update
                        appropriate Center Desk Manuals to
                        specify relevant staff involved in the
                        charge-off and referral processes to
                        ensure the Next Due Date field in the
                        loan repository system is timely updated
                        when a loan's liable parties change. Any
                        change to policy should be
                        communicated to relevant staff.
20-05    12/10/2019     KPMG recommends the Associate                1/9/2020     1/31/2021
                        Administrator for Capital Access
                        perform a regular review of liable parties
                        with outstanding receivable balances to
                        ensure they are referred in a timely
                        manner.
20-06    2/11/2020      Continue to train program office grant       2/25/2020    9/30/2020
                        personnel responsible for monitoring
                        grant recipient performance to enforce
                        compliance with SBA’s established
                        policies and procedures for grants
                        management and best practices for
                        administering grant awards and
                        monitoring performance.
20-07    2/20/2020      Update improper payment standard             8/4/2020     10/2/2020
                        operating procedures, training guides,
                        and checklists to provide clear and
                        comprehensive guidance and
                        instructions to assist Quality Control
                        Specialists to accurately identify
                        improper payments and help mitigate
                        the risk associated with using
                        inexperienced staff.
20-08    3/18/2020      Evaluate options that facilitate the         6/30/2020    2/7/2021
                        Community Advantage pilot program’s
                        ability to effectively expand access to
                        capital in underserved markets.
20-08    3/18/2020      Evaluate whether it is feasible to align     6/30/2020    3/31/2020
                        the maximum interest rates charged
                        under the CA pilot program with
                        comparable 7(a) program rates,
                        excluding SBA Express.
20-08    3/18/2020      Provide criteria to lenders to assist them   8/5/2020     3/31/2020
                        with assessing the borrowers’ M&TA
                        needs.




                                                      Semiannual Report to Congress, Fall 2020 | 31
U.S. Small Business Administration | Office of Inspector General

 Report      Date Issued   Recommendation                              Date of              Final Action Target
 Number                                                                Management           Date
                                                                       Decision
 20-08       3/18/2020     Establish methods to assess whether         6/30/2020            3/31/2020
                           lenders have the expertise needed to
                           provide M&TA to underserved
                           borrowers and to address any lender
                           deficiencies regarding M&TA.
 20-08       3/18/2020     Require lenders to complete the data        6/30/2020            3/31/2020
                           fields related to the M&TA provided and
                           enhance the annual CA performance
                           analysis by including the evaluation of
                           the performance associated with the
                           various types of M&TA.
 20-08       3/18/2020     Establish a process to periodically         6/30/2020            3/31/2020
                           assess the performance of CA loans
                           approved with SBSS scores under 140,
                           to determine whether the recently
                           implemented SBA approval
                           requirement is adequately mitigating
                           the risk of loss.
 20-09       3/24/2020     Implement procedures to ensure              3/25/2020            11/30/2020
                           program officials enforce financial
                           examination results.



Significant Recommendations from this Reporting Period
 Report     Title              Date          Recommendation
 Number                        Issued

 20-15      Independent        5/12/2020     Update SBA Standard Operating Procedure (SOP) 20 32 1,
            Auditors’ Report                 Estimating and Reporting Improper Payments, using the
            on SBA’s                         framework in the Government Accountability Office Standards for
            Compliance with                  Internal Control in the Federal Government (Green Book) to
            Improper                         design and implement robust internal and quality control
            Payments                         processes to ensure complete and accurate reporting of annual
            Elimination and                  improper payment results, including the sampling methodology
            Recovery Act of                  documentation is consistent with the population, sample, and
            2010 (IPERA)                     payment integrity information in the AFR.

 20-15      Independent        5/12/2020     Provide training to responsible staff in the Offices of Internal
            Auditors’ Report                 Control, Capital Access, and Disaster Assistance regarding
            on SBA’s                         updates to SBA SOP 20 32 1.
            Compliance with
            IPERA

 20-15      Independent        5/12/2020     Ensure that staff in the Office of Internal Control oversee and
            Auditors’ Report                 provide adequate quality control reviews over improper payment
            on SBA’s                         disclosures submitted by SBA program offices.
            Compliance with
            IPERA

 20-15      Independent        5/12/2020     Provide training to program office staff, as needed, on the timely
            Auditors’ Report                 reconciliation of the population of transactions used for
            on SBA’s                         estimating improper payments to the general ledger.
            Compliance with
            IPERA



32 | Semiannual Report to Congress, Fall 2020
                     U.S. Small Business Administration | Office of Inspector General

Report   Title             Date        Recommendation
Number                     Issued

20-17    Evaluation of     7/30/2020   Include the Certify investment in the Agency’s Enterprise Risk List
         Certify.SBA.Gov               as a high-risk endeavor and require continuous risk monitoring,
                                       as specified in the SBA Enterprise Risk Management Framework
                                       Guide.

20-17    Evaluation of     7/30/2020   Establish traceable functional requirements for the Certify
         Certify.SBA.Gov               investment in accordance with the Capital Programming Guide,
                                       supplement to OMB Circular A-11, specifically, in terms of the
                                       Office of Government Contracting and Business Development’s
                                       mission, purpose, capability, schedule and cost objectives.

2017     Evaluation of     7/30/2020   Develop a documented requirements traceability matrix and
         Certify.SBA.Gov               ensure that the Office of Government Contracting and Business
                                       Development has adequate resources to trace requirements
                                       throughout all stages of design, development, and user-
                                       acceptance.

20-17    Evaluation of     7/30/2020   Develop and maintain a performance-measurement baseline
         Certify.SBA.Gov               with budgets and schedules assigned to product-oriented work
                                       breakdown structure elements and established cost and
                                       schedule variance thresholds in accordance with the Capital
                                       Programming Guide, supplement to OMB Circular A-11.

20-17    Evaluation of     7/30/2020   Evaluate work breakdown structure elements for cost, schedule,
         Certify.SBA.Gov               and technical risk. Use the results of such risk analysis to maintain
                                       a risk-adjusted budget and schedule in accordance with the
                                       Capital Programming Guide, supplement to OMB Circular A-11.

20-17    Evaluation of     7/30/2020   Incorporate earned value management and integrated baseline
         Certify.SBA.Gov               reviews into the Certify investment as required by FAR 34. 2 and
                                       conduct documented integrated baseline reviews in accordance
                                       with the 32 criteria identified in National Defense Industrial
                                       Association’s Earned Value Management Systems EIA-748 Intent
                                       Guide, as required by SOP 90 52.

20-17    Evaluation of     7/30/2020   Ensure that all Certify investment cost, schedule, and
         Certify.SBA.Gov               performance baseline data submitted for BTIC review clearly
                                       show the amount of work accomplished and actual costs against
                                       the original investment baseline to provide critical management
                                       visibility on the achievement of, or deviation from, goals.

20-17    Evaluation of     7/30/2020   Update system development methodology to link agile summary
         Certify.SBA.Gov               components with establishing traceable requirements,
                                       monitoring progress through a requirements traceability matrix
                                       and reporting progress using a performance management
                                       system, including an earned value management system for the
                                       development of major IT investments.

20-17    Evaluation of     7/30/2020   Determine whether any customization and enhancement costs
         Certify.SBA.Gov               for internal use software related to Certify investment should be
                                       capitalized in accordance with the financial reporting
                                       requirements in OMB Circular A-136.




                                                  Semiannual Report to Congress, Fall 2020 | 33
U.S. Small Business Administration | Office of Inspector General

 Report     Title               Date        Recommendation
 Number                         Issued
 20-18      Office of           4/25/2020   Require the lender to bring the loan into compliance or, if not
            Inspector General               possible, seek recovery of $2,094,574 on the guaranty paid by
            High Risk 7(a)                  SBA.
            Loan Review
            Program
 20-20      Audit of SBA’s      9/30/2020   Review all loans assigned to the resolution center that are 180
            Compliance with                 days or more delinquent and classified with code 66 (Lien or
            the Debt                        Mortgage/Refer to Treasury Offset Program Only) and 00 (Clear
            Collection                      Existing Status Code) and transfer the loans to Treasury Cross-
            Improvement Act,                Servicing, unless verified as exempt when the temporary
            as Amended                      suspension of debt collection activities because of the pandemic
                                            is lifted.

 20-20      Audit of SBA’s      9/30/2020   Revise SOP 50 52 to clearly communicate that all loans with
            Compliance with                 collateral must be evaluated for foreclosure and placed in
            the Debt                        foreclosure status before they are 180 days delinquent.
            Collection
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s      9/30/2020   Revise SOP 50 52 2 to clearly communicate that all debts 180
            Compliance with                 days delinquent must be transferred to Treasury Cross-Servicing
            the Debt                        unless the debt meets a valid transfer exemption.
            Collection
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s      9/30/2020   Establish requirements to provide annual training on Debt
            Compliance with                 Collection Improvement Act requirements to all staff of the
            the Debt                        resolution center.
            Collection
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s      9/30/2020   Ensure that information used to monitor compliance with the
            Compliance with                 Debt Collection Improvement Act includes all loans assigned to
            the Debt                        the resolution center as identified in the Capital Access Financial
            Collection                      System.
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s      9/30/2020   Review all loans currently assigned to the Center and designated
            Compliance with     0           exempt from Treasury Offset Program and verify that each of the
            the Debt                        obligors is exempt from referral to Treasury Offset Program, and
            Collection                      if not, refer the obligors to Treasury Offset Program, as required.
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s      9/30/2020   Review all loans currently assigned to the Center and designated
            Compliance with                 as exempt from Treasury Cross-Servicing that are 180 days or
            the Debt                        more delinquent and verify that each of the obligors is exempt
            Collection                      from transfer to Treasury Cross-Servicing, and if not, transfer the
            Improvement Act,                debt to Treasury Cross-Servicing, as required when the
            as Amended                      temporary suspension of debt collection activities due to COVID-
                                            19 is lifted.




34 | Semiannual Report to Congress, Fall 2020
                        U.S. Small Business Administration | Office of Inspector General

 Report     Title              Date        Recommendation
 Number                        Issued

 20-20      Audit of SBA’s     9/30/2020   Establish policies and procedures to require routine follow-up on
            Compliance with                delinquent loans to ensure full compliance with the Debt
            the Debt                       Collection Improvement Act.
            Collection
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s     9/30/2020   Reiterate the requirements for workout agreements to
            Compliance with                responsible personnel to ensure compliance with the Debt
            the Debt                       Collection Improvement Act.
            Collection
            Improvement Act,
            as Amended

 20-20      Audit of SBA’s     9/30/2020   Perform a cost benefit analysis to determine if SBA should begin
            Compliance with                assessing fees to offset the cost of processing and handling
            the Debt                       delinquent disaster loans.
            Collection
            Improvement Act,
            as Amended



Significant Management Decisions – OIG Disagreement
There were no significant management decisions OIG disagreed with during this reporting
period.



Significant Revised Management Decisions
There were no significant revised management decisions during this reporting period.



Federal Financial Management Improvement Act
OIG’s Independent Public Accountant, KPMG, found in the FY 2020 financial statement audit
that there were no instances in which SBA’s financial management systems did not substantially
comply with the Federal Financial Management Improvement Act of 1996.



Instances of Interference
There were no attempts by SBA officials to interfere with OIG independence during the
reporting period.




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U.S. Small Business Administration | Office of Inspector General


Appendix D. Investigations Reporting Statistics
Investigative Reports Issued
Report Type                                                                                   Number of Reports
Report of Investigation                                                                                     29
Preliminary Case Closing Reports of Investigation                                                             8
Total                                                                                                       37



Persons Referred for Prosecution
Referred To                                                                                   Number of Persons
Department of Justice                                                                                       200
State Attorney                                                                                                0
Local Attorney                                                                                                0
Total                                                                                                      200*
*Number includes persons and entities referred for prosecution.

Pandemic-Related Investigative Statistics
 SBA OIG                    Investigations    Indict/Complaint             Arrests                  Convictions
 PPP/EIDL*                             41                   74                 62                            4
 Investment Fraud                       1                    1                  1                            1
 Total                                 42                   75                 63                            5

*PPP stands for Paycheck Protection Program. EIDL stands for economic injury disaster loan.



Whistleblower Retaliation Cases
There were no OIG investigations involving whistleblower retaliation during the reporting
period.



Investigations Involving a Senior Government Employee Where Misconduct Was
Substantiated
There were no OIG investigations involving a senior government employee where misconduct
was substantiated during the reporting period.



Investigations Involving a Senior Government Employee That Is Closed and Not
Disclosed to the Public
There were no OIG investigations that are closed and not disclosed to the public involving a
senior government employee during this reporting period.




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                        U.S. Small Business Administration | Office of Inspector General


Appendix E. Legal Actions Summary
April 1, 2020 – September 30, 2020
State   Program   Jointly          Alleged Violation(s) Prosecuted                Legal Action
                  with
AL      DL        DHS/HSI,         Individual conspired to submit a fraudulent    Federal seizure warrant
                  TIGTA            Economic Injury Disaster Loan (EIDL).          issued resulting in
                                                                                  $300,974 recovery.
AR      BL        FBI, TIGTA       Individual fraudulently obtained two SBA        Individual arrested.
                                   guaranteed loans intended for COVID-19
                                   relief through the Paycheck Protection
                                   Program (PPP).
CA      BL        FBI, FDIC/OIG    Individual fraudulently obtained three SBA     Individual arrested.
                                   guaranteed loans intended for COVID-19
                                   relief through the PPP.
CA      DL        FBI              Individual fraudulently obtained two SBA       Individual arrested.
                                   guaranteed loans intended for COVID-19
                                   relief through the PPP.
CA      BL        FHFA/OIG,        Individual obtained more than $8 million in    Individual indicted.
                  FDIC/            PPP loans from various lenders.
                  OIG,
                  TIGTA, IRS/CI,
                  FBI
CA      BL        DHS/HSI,         Individual fraudulently obtained two SBA       Individual charged by
                  TIGTA, USPIS,    guaranteed loans intended for COVID-19         criminal complaint.
                  State of         relief through the PPP.
                  CA/EDD
CO      DL        USSS             Individual used stolen identity to obtain      SBA realized an
                                   EIDL loan in the amount of $14,500.            administrative recovery of
                                                                                  $14,500
CO      DL        USSS             Individual used stolen identity to obtain      SBA realized an
                                   EIDL loan in the amount of $147,436.66.        administrative recovery of
                                                                                  $147,436.66.
DC      BL        FBI, IRS/CI      Individual fraudulently obtained seven SBA     Individual charged by
                                   guaranteed loans intended for COVID-19         criminal complaint. In
                                   relief through the PPP and EIDL programs.      addition, SBA realized an
                                                                                  administrative recovery of
                                                                                  approximately $450,000.
FL      DL        FBI, TIGTA,      Three individuals conspired to fraudulently    Individuals charged by
                  FDIC/OIG,        obtain SBA guaranteed loans intended for       criminal complaint.
                                   COVID-19 relief through the PPP and EIDL
                                   programs.
FL      BL        USSS             Individual assisted persons in obtaining       SBA realized an
                                   PPP loans for which they were not qualified.   administrative recovery of
                                   SBA OIG recovered funds from five              $1,998,368.
                                   individuals who participated in the scheme.
FL      DL                         Individual used stolen identity to obtain      SBA realized an
                                   EIDL loan in the amount of $46,100.            administrative recovery of
                                                                                  $46,100.




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U.S. Small Business Administration | Office of Inspector General

 FL     BL         TIGTA, USPIS   Individual fraudulently obtained two SBA       Individual charged by
                                  guaranteed loans intended for COVID-19         criminal complaint.
                                  relief through the PPP.
 GA     DL                        Individual fraudulently obtained SBA           SBA realized an
                                  guaranteed loans intended for COVID-19         administrative recovery of
                                  relief through the EIDL program.               $172,100.

 GA     BL         FBI            Two individuals falsified applications for     Two individuals indicted.
                                  and SBA PPP loan by providing false
                                  supporting documentation.
 GA     DL                        Multiple individuals used stolen identities    SBA realized an
                                  to obtain EIDL loans.                          administrative recovery of
                                                                                 $1,021,225.
 GA     DL         USSS           Individual used stolen identity to obtain      SBA realized an
                                  EIDL loan in the amount of $59,295.            administrative recovery of
                                                                                 $59,295.
 GA     GC         DCIS,          Individual disclosed sensitive federal         Individual sentenced to
                   Army/CID       procurement information to a company           20 months confinement,
                                  competing for government contracts.            three years supervised
                                                                                 release and ordered to
                                                                                 pay $15,000 fine.
 GA     OT                        Individual falsified receipts to remain        SBA realized an
                                  eligible for SBA grants to which they were     administrative recovery of
                                  not entitled.                                  $420,000.

 ID     GC         DCIS,          Individuals made false statements to qualify   Individuals entered into a
                   Army/CID,      to receive Historically Underutilized          settlement agreement in
                   AFOSI,         Business Zone (HUBZone) contracts.             the amount of $500,000
                   DHS/OIG,
                   GSA/OIG
 LA     DL                        Individual misused SBA disaster loan funds     Individual pled guilty.
                                  received for a property damaged by
                                  flooding.

 MA     BL                        Individual obtained two SBA guaranteed         Individual sentenced to
                                  loans by providing false information on the    30 months
                                  loan application.                              imprisonment,5 years
                                                                                 supervised release and
                                                                                 ordered to pay a $300
                                                                                 assessment.
 MA     BL         FBI, IRS/CI,   Individual submitted falsified                 Individual indicted.
                   FRB/OIG,       documentation in support of multiple
                   FDIC-OIG       applications for PPP loans.
 MD     BL         FHFA/OIG,      Individuals conspired to defraud two banks     Individual pled guilty.
                   FDIC/OIG,      to purchase a home through false
                   SIGTARP        representations.
 ME     DL                        Individual fraudulently obtained SBA           SBA realized an
                                  guaranteed loans intended for COVID-19         administrative recovery of
                                  relief through the EIDL program.               $126,200.

 MI     BL                        Individual misused proceeds of SBA PPP         Individual charged by
                                  loan. The individual received the funds        criminal complaint.
                                  then withdrew the funds to purchase four
                                  vehicles.




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                U.S. Small Business Administration | Office of Inspector General

MO   BL   FBI, FDIC/OIG,   Individual falsified information on his SBA     Individual indicted and
          IRS/CI           loan application.                               arrested.
NC   BL   FBI              Individual fraudulently obtained two SBA        Individual indicted.
                           7(a) loans by submitting fraudulent
                           applications and fake supporting
                           documentation.
NJ   BL                    Individual charging fees to assist applicants   Cease and desist notice
                           obtain SBA PPP loans, in violation of SBA       issued.
                           policy.
NY   BL   FBI              Individual made misrepresentations to           SBA realized an
                           obtain a PPP loan.                              administrative recovery of
                                                                           $211,325.
NY   GC   Army/CID,        Individuals created a sham company to bid       Company entered into
          DCIS,            on and receive government contracts.            settlement agreement in
          DOT/OIG,                                                         the amount of $4,350,000.
          GSA/OIG
NY   BL   FBI, IRS/CI      Individual made misrepresentations to           SBA realized an
                           obtain EIDL and PPP loans.                      administrative recovery of
                                                                           $813,250 and an
                                                                           individual was charged by
                                                                           complaint.
NY   BL   FBI              Individual fraudulently obtained two SBA        Individual indicted.
                           guaranteed loans intended for COVID-19
                           relief through the PPP.
OH   BL   IRS/CI           Individual fraudulently obtained two SBA        Individual charged by
                           guaranteed loan sand one EIDL loan              criminal complaint.
                           intended for COVID-19 relief.
OH   BL                    Two individuals devised and participated in     Two individuals charged
                           a money laundering scheme to obtain 18          by criminal complaint.
                           PPP loans totaling millions of dollars.
OH   GC   DCIS,            Individuals engaged in a conspiracy to          Individual sentenced to
          NASA/OIG,        defraud the government by paying bribes         three years’ probation, a
          NCIS, VA/OIG     and obtaining set-aside contracts to which      fine of $15,000 and a
                           they were not entitled.                         special assessment of
                                                                           $900.
OK   DL                    Individuals fraudulently obtained six SBA       Two individuals charged
                           guaranteed loans intended for COVID-19          by criminal complaint.
                           relief through the PPP.
OK   DL                    Individual made misrepresentations to           Individual indicted.
                           obtain an EIDL loan.
OR   DL                    Individual used stolen identity to obtain       SBA realized an
                           EIDL loan in the amount of $74,100.             administrative recovery of
                                                                           $74,100.
RI   BL   FBI, FDIC/OIG,   Individuals fraudulently obtained two SBA       SBA realized an
          IRS/CI           guaranteed loans intended for COVID-19          administrative recovery of
                           relief through the PPP.                         $279,710.

RI   BL   FDIC/OIG,        Individual charged borrowers’                   SBA realized an
          FRB/OIG          impermissible fees that were not disclosed      administrative recovery of
                           to SBA. In addition, submitted altered          $467,497.
                           documents with SBA loan applications.




                                             Semiannual Report to Congress, Fall 2020 | 39
U.S. Small Business Administration | Office of Inspector General

 RI     BL         FBI, FDIC/OIG,   Individuals fraudulently obtained four SBA    SBA realized an
                   IRS/CI           guaranteed loans intended for COVID-19        administrative recovery of
                                    relief through the PPP.                       $442,881. In addition, two
                                                                                  individuals were charged
                                                                                  by criminal complaint.
 SC     CC         AFOSI,           Individuals conspired to make false           Individual entered into
                   Army/CID,        applications for SBA 8(a) contracts.          civil settlement in the
                   DOE/OIG,                                                       amount of $850,000.
                   USDA/OIG,
                   VA/OIG
 TX     BL         USPIS            Individuals fraudulently obtained two SBA     SBA realized an
                                    guaranteed loans intended for COVID-19        administrative recovery of
                                    relief through the PPP.                       $1,158,143. Individual was
                                                                                  arrested pursuant to a
                                                                                  criminal complaint.
 TX     BL                          Individuals fraudulently obtained two SBA     SBA realized an
                                    guaranteed loans intended for COVID-19        administrative recovery of
                                    relief through the PPP.                       $3,006,200. Individual
                                                                                  charged by criminal
                                                                                  complaint.
 TX     BL         ATF, DHS/HSI,    Individuals fraudulently obtained SBA         SBA realized an
                   TIGTA            guaranteed loan intended for COVID-19         administrative recovery of
                                    relief through the PPP.                       $504,715. Individual
                                                                                  arrested.
 TX     BL         FDIC/OIG,        Individual fraudulently obtained SBA          Individual indicted.
                   FHFA/OIG,        guaranteed loans intended for COVID-19
                   IRS/CI, TIGTA    relief through the PPP. Individual used
                                    funds to purchase luxury automobile, home
                                    mortgage payments and other personal
                                    expenses.
 TX     BL                          Individual submitted nine applications for    Individual arrested
                                    PPP loans. The applications contained false   pursuant to criminal
                                    documents and/or misrepresentations.          complaint. In addition,
                                    Three loans were funded for a total of $4     SBA realized an
                                    million.                                      administrative recovery of
                                                                                  $3,111,698.
 TX     DL         USSS             Individual used stolen identity to obtain     SBA realized an
                                    EIDL loan in the amount of $406,000.          administrative recovery of
                                                                                  $406,000.
 TX     DL         USSS             Individual used stolen identity to obtain     SBA realized an
                                    EIDL loan in the amount of $145,653.          administrative recovery of
                                                                                  $145,653.
 TX     DL         DHS/OIG          Individual obtained SBA disaster loan for     Individual sentenced to 3
                                    damage caused by Hurricane Harvey.            years’ probation and
                                    Investigation determined the property         ordered to pay a $100
                                    received no damage and proceeds were          special assessment.
                                    used to pay off personal credit cards.
 TX     DL                          Individual refused to schedule onsite loss    SBA realized an
                                    verification inspection pursuant to SBA       administrative recovery of
                                    disaster loan terms and conditions.           $22,221.



 TX     DL         DHS/HSI,         Individual fraudulently obtained SBA          SBA realized an
                   FDIC/OIG         guaranteed loan intended for COVID-19         administrative recovery of
                                    relief through the PPP.                       $50,000.



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                U.S. Small Business Administration | Office of Inspector General

TX   DL                    SBA employee applied for three EIDL              SBA realized an
                           loans, two were reviewed and obligated by        administrative recovery of
                           the employee.                                    $130,900. SBA employee
                                                                            terminated.
UT   BL   FBI              Individual failed to disclose criminal history   Individual arrested and
                           on PPP application.                              $28,889 seized and
                                                                            returned to SBA.
UT   GC   AFOSI,           Individuals devised a scheme to obtain           Two individuals charged
          Army/CI, DCIS,   HUBZone set-aside contracts. Individuals         by information.
          FBI              submitted false documentation related to
                           the location of their primary offices.
VA   BL   FBI              Individuals fraudulently obtained SBA            Individuals pled guilty.
                           guaranteed loan intended for COVID-19
                           relief through the PPP.
VA   GC   DCIS, NCIS,      Individuals conspired to obtain SDVOSB           Seven individuals
          INS, DOS/OIG     set-aside contracts to which the companies       indicted.
                           would not otherwise be entitled.

VA   DL   FBI, IRS/CI,     Individual made misrepresentations to            Individual indicted.
          USPIS            obtain an EIDL loan.
WA   GC   Army/CI, DCIS,   Individuals conspired to create fictious         Individual indicted.
          DOC/OIG,         small businesses to obtain small business
          DOJ/OIG,         set-aside contracts to which the companies
          GSA/OIG,         would otherwise be entitled.
          HHS/OIG,
          IRS/CI
WA   DL                    Individual used stolen identity to obtain        SBA realized an
                           EIDL loan in the amount of $159,900.             administrative recovery of
                                                                            $159,900.
WA   DL   IRS/CI           Individual obtained a PPP loan by making         SBA realized an
                           false statements on his application.             administrative recovery of
                                                                            $102,711.
WA   DL   FBI, FDIC/OIG,   Individual fraudulently submitted 26 SBA         Individual charged by
          HHS/OIG,         guaranteed loan applications intended for        criminal complaint. SBA
          IRS/CI, TIGTA    COVID-19 relief through the PPP and EIDL         realized an administrative
                           programs.                                        recovery of $1,183,499.

WA   DL   DHS/OIG          Individual obtained a EIDL loan by making        SBA realized an
                           false statements on his application.             administrative recovery of
                                                                            $149,900. Individual
                                                                            arrested.
WA   DL   FBI, TIGTA       Individual fraudulently obtained five SBA        SBA realized an
                           guaranteed loans intended for COVID-19           administrative recovery of
                           relief through the PPP and EIDL programs.        $10,000. Individual
                                                                            charged by criminal
                                                                            complaint.
WI   BL   FBI              Individual made false statements during a        Individual pled guilty and
                           bankruptcy proceeding related to an SBA          was sentenced to 12
                           guaranteed loan.                                 months and 1 day in
                                                                            prison, 3 years supervised
                                                                            release, and ordered to
                                                                            pay $2,466,550 in
                                                                            restitution.




                                              Semiannual Report to Congress, Fall 2020 | 41
U.S. Small Business Administration | Office of Inspector General

Table Notes:

Legal Actions Summary Program Codes
BL………..Business Loans
DL……….Disaster Loans
GC………Government Contracting and Section 8(a) Business Development
IA………..Internal Affairs
OT………Other


Joint-investigation Agency Acronyms
Defense Criminal Investigative Service (DCIS)
Department of Commerce Office of Inspector General (DOC/OIG)
Department of Energy Office of Inspector General (DOE/OIG)
Department of Health and Human Services Office of Inspector General (HHS/OIG)
Department of Homeland Security Homeland Security Investigations (DHS/HSI)
Department of Homeland Security Immigration and Customs Enforcement (DHS/ICE)
Department of Homeland Security Office of Inspector General (DHS/OIG)
Department of Justice Office of Inspector General (DOJ/OIG)
Department of Justice Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF)
Department of State Office of Inspector General (DOS/OIG)
Department of Transportation Office of Inspector General (DOT/OIG)
Department of Treasury Inspector General for Tax Administration (TIGTA)
Department of Treasury Special Inspector General for the Troubled Asset Relief Program (SIGTARP)
Department of Veterans Affairs Office of Inspector General (VA/OIG)
Federal Bureau of Investigation (FBI)
Federal Deposit Insurance Corporation Office of Inspector General (FDIC/OIG)
Federal Housing Finance Agency Office of Inspector General (FHFA/OIG)
Federal Reserve Board Office of Inspector General (FRB/OIG)
General Services Administration Office of Inspector General (GSA/OIG)
Internal Revenue Service – Criminal Investigation (IRS/CI)
National Aeronautics and Space Administration Office of Inspector General (NASA/OIG)
State of California Employment Development Department (State of CA/EDD)
United States Airforce Office of Special Investigations (AFOSI)
United States Army/Criminal Investigation Division (Army/CID)
United States Department of Agriculture Office of Inspector General (USDA/OIG)
United States Naval Criminal Investigative Service (NCIS)
United States Postal Inspection Service (USPIS)
United States Secret Service (USSS)




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Appendix F. Cosponsored and Other Activities
SBA’s authorization to cosponsor events requires OIG to report to Congress on the
Administrator’s use of that authority semiannually. The following list of activities was provided by
the Office of Strategic Alliances.


Name/Subject of Event        Name of Cosponsor(s)                           Event           Date Fully
                                                                            Location        Executed
                             Utah DO - South Valley Chamber of
                             Commerce, Salt Lake Chamber Women’s
2020 National Small Business                                                World Wide
                             Business Center, Utah Small Business                           9/21/2020
Week Awards Event                                                           Web Virtual
                             Development Center Network, SCORE Utah
                             Chapter
                                                                            Virtual,
                                                                            Casper,
                                                                            Laramie,
Selling to the Government    Wyoming DO - Wyoming Procurement
                                                                            Cheyenne,       9/14/2020
Training Series              Technical Assistance Center
                                                                            Riverton,
                                                                            Jackson, Fort
                                                                            Washakie, WY
                             Nebraska DO - Better Business Bureau,
                             Business Ethics Alliance, Catholic Charities
Entrepreneur’s Education     Archdiocese of Omaha, Greater Omaha
                                                                            Virtual         8/24/2020
Collaborative                Chamber of Commerce, Nebraska Business
                             Development Center, Nebraska Enterprise
                             Fund, SCORE Greater Omaha Chapter 40
Spirit of Small Business     Los Angeles DO - Pacific Coast Business
                                                                            Virtual         8/19/2020
Awards Program               Times
                             Wichita DO - FranNet of Missouri, Kansas,
Small Business Webinars                                                     Virtual         8/14/2020
                             Southern Illinois, and Eastern Iowa
                             HQ/Office of Government Contracting &
SBA Military Spouse                                                         World Wide
                             Business Development - US Chamber of                           7/23/2020
Entrepreneur Summit                                                         Web
                             Commerce Foundation's Hiring Our Heroes
Small Business Basics
                             New York DO - The City of Newburgh             Newburgh, NY 3/18/2020
Workshops
                             HQ/Office of Communications and Public
National Small Business                                                     World Wide
                             Liaison - SCORE Association, Various                           2/28/2020
Week 2020                                                                   Web Virtual
                             Cosponsors




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U.S. Small Business Administration | Office of Inspector General


Appendix G. External Peer Reviews
Section 5(a) of the IG Act requires OIGs to report peer review results in the Semiannual Reports
to Congress. The following information is provided in accordance with these requirements:

Audits Division
Generally accepted government auditing standards (Yellow Book) issued by GAO require that
audit organizations performing audits and attestation engagements in accordance with the
Yellow Book must have an external peer review performed by reviewers independent of the
audit organization being reviewed at least once every 3 years. OIG’s Audits Division was
reviewed by the U.S. Department of State OIG for the period ended March 31, 2018. In
September 2018, SBA OIG received a peer review rating of “pass.”
Similarly, the Council of the Inspectors General on Integrity and Efficiency requires that
organizations that conduct inspections and evaluations under the Quality Standards for
Inspection and Evaluation, or Blue Book, must have an external peer review at least once every 3
years. During FY 20, our Audits Division underwent a first for OIG, a Blue Book peer review
conducted by the Department of Justice OIG. OIG generally met Blue Book standards.
In addition, in FY 20, our Audits Division reviewed the U.S. Department of Housing and Urban
Development OIG against the Blue Book standards. We determined HUD generally met Blue
Book standards.

Investigations Division
Section 6(e)(7) of the IG Act, Attorney General Guidelines for Offices of Inspector General with
Statutory Law Enforcement Authority, and the CIGIE Quality Standards for Investigations require
external peer reviews of OIG investigative functions be conducted every 3 years.
In 2017, the U.S. Federal Deposit Insurance Corporation OIG reviewed our Investigations
Division. The reviewers found the system of internal safeguards and management procedures
for the investigative function of OIG was compliant with the quality standards established by the
Council of the Inspectors General on Integrity and Efficiency and the applicable Attorney
General Guidelines. (OIGs can be assessed as either compliant or noncompliant.) No
recommendations were offered.




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U.S. Small Business Administration | Office of Inspector General


Appendix H. Office of Inspector General Reporting
Requirements
Under the Inspector General Act of 1978, as amended, OIG provides independent, objective
oversight to improve the integrity, accountability, and performance of SBA and its programs
for the benefit of the American people.
Although SBA’s programs are essential to strengthening America’s economy, the agency faces
several challenges in carrying out its mission. Access our annual report of the agency’s top
management and performance challenges here: https://www.sba.gov/sites/default/files/2020-
10/SBA%20OIG%20Report%2021-01.508.pdf.
OIG plays a critical role in addressing these and other challenges by conducting audits to
identify wasteful expenditures and program mismanagement; investigating fraud and other
wrongdoing; and taking other actions to deter and detect waste, fraud, abuse, and
inefficiencies in SBA programs and operations.
OIG’s activities also help to ensure that SBA employees possess a high level of integrity. This is
critical to the proper administration of SBA’s programs because it helps ensure SBA resources
are used by those who need them the most. Copies of OIG reports and other products are
available at https://www.sba.gov/office-of-inspector-general.

Reporting Requirements in the Inspector General Act of 1978, As
Amended

 Section      Reporting Requirement                               Location
 4(a)(2)      Review of legislation and regulations               Other Significant OIG Activities
 5(a)(1)      Significant problems, abuses, and deficiencies      Throughout
              Recommendations with respect to significant         Significant Recommendations from This
 5(a)(2)      problems, abuses, and deficiencies                  Reporting Period
                                                                  Significant Recommendations from Prior
              Prior significant recommendations on which          Reporting Periods Without Final Action as of
 5(a)(3)      corrective action has not been completed            September 30, 2019
 5(a)(4)      Matters referred to prosecutive authorities         Legal Actions Summary
              Instances in which requested information was
 5(a)(5)      refused                                             N/A
 5(a)(6)      List of audit, inspection, and evaluation reports   Reports Issued; Reports with Questioned Costs
 5(a)(7)      Significant reports                                 Throughout
              Audit, inspection, and evaluation statistical
 5(a)(8)      tables                                              Statistical Highlights
              Audit, inspection, and evaluation reports with
              recommendations that funds be put to better         Reports with Recommendations That Funds Be
 5(a)(9)      use                                                 Put to Better Use
              Audit, inspection, and evaluation reports           Reports from Prior Periods with Overdue
              without management decision, without                Management Decisions; Reports from Prior
              comment within 60 days, or with                     Periods with Open Recommendations as of
 5(a)(10)     unimplemented recommendations                       September 30, 2019
 5(a)(11)     Revised management decisions                        Significant Revised Management Decisions
              Management decisions with which the                 Significant Management Decisions with Which
 5(a)(12)     Inspector General disagrees                         OIG Disagrees




                                                         Semiannual Report to Congress, Fall 2019 | 45
U.S. Small Business Administration | Office of Inspector General

 Section         Reporting Requirement                             Location
                 Information described under section 05(b) of
                 the Federal Financial Management                  Federal Financial Management Improvement
 5(a)(13)        Improvement Act of 1996                           Act
 5(a)(14)–(16)   Peer review results                               External Peer Reviews
                 Investigative statistical tables and supporting
 5(a)(17),(18)   metrics                                           Investigations Reporting Statistics
                 Investigations involving a senior government      Investigations Involving a Senior Government
                 employee where allegations of misconduct          Employee Where Misconduct Was
 5(a)(19)        were substantiated                                Substantiated
 5(a)(20)        Whistleblower retaliation                         Whistleblower Retaliation Cases
                 Attempts to interfere with the independence of
 5(a)(21)        OIG                                               Instances of Interference
                 Each closed inspection, evaluation, and audit
                 not disclosed to the public; each closed          Investigations Involving a Senior Government
                 investigation involving a senior government       Employee That Is Closed and Not Disclosed to
 5(a)(22)        employee not disclosed to the public              the Public




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