Superseding Criminal Information, United States v. Trenikia Lashae Banks (S.D. Tex., September 18, 2025)
Summary
Superseding Criminal Information, Criminal No. 4:24-CR-302-2-S, filed September 18, 2025, in the Southern District of Texas, Houston Division, against Trenikia Lashae Banks. Count One (Conspiracy) alleges that Banks and others conspired from no later than in or about April 2020 through in or about September 2022 to commit wire fraud through fraudulent Paycheck Protection Program (PPP) loan applications, defrauding the SBA and Cache Valley Bank. It alleges that a first draw PPP application for Impressionable Memories LLC falsely represented 12 employees and that Cache Valley Bank approved a loan of $121,250. It further alleges that on or about March 2, 2021, Banks used loan proceeds to purchase a $48,500 cashier's check payable to "ADMC Ent."
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“Superseding Criminal Information, United States v. Trenikia Lashae Banks (S.D. Tex., September 18, 2025).”
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Case 4:24-cr-00302 Document 71 Filed on 09/18/25 in TXSD Page 1 of 6
United States Courts
Southern District of Texas
&/>ED
September 18, 2025
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS EaƚŚĂŶKĐŚƐŶĞƌ, Clerk ofCourt
HOUSTON DIVISION
UNITED STATES OF AMERICA §
§
vs. § CRIMINAL NO. 4:24-CR-302-2-S
§
(2) TRENIKIA LASHAE BANKS, §
§
Defendant. §
SUPERSEDING CRIMINAL INFORMATION
THE UNITED STATES ATTORNEY CHARGES THAT:
COUNT ONE
(Conspiracy, 18 U.S.C. § 371)
A. INTRODUCTION
At times material to this Information:
1. Defendant TRENIKIA LASHAE BANKS and others known and unknown to the
United States Attorney conspired together, and with intent to defraud, participated in a scheme and
artifice to defraud the Small Business Administration (SBA) and Cache Valley Bank.
2. BANKS was a resident of Houston, Texas, and was affiliated with the following
business entities:
a. The Exclusive Estates LLC was registered as a Domestic Limited Liability
Company with the Texas Secretary of State on or about September 25, 2018. BANKS was listed
as the initial registered agent and one of two governing members. The Exclusive Estates LLC was
in tax forfeiture status between approximately February 28, 2020, and February 19, 2021.
b. Solid LLC was registered as a Domestic Limited Liability Company with
the Texas Secretary of State on or about January 16, 2020. BANKS was listed as the original
registered agent and governing member.
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Case 4:24-cr-00302 Document 71 Filed on 09/18/25 in TXSD Page 2 of 6
c. Impressionable Memories LLC was registered as a Domestic Limited
Liability Company with the Texas Secretary of State on or about May 27, 2021. BANKS was listed
as the initial registered agent and governing member. On or about March 10, 2023, the Texas
Secretary of State entered a tax forfeiture on Impressionable Memories.
3. Cache Valley Bank was a financial institution, the deposits of which were insured
by the Federal Deposit Insurance Corporation.
4. According to the Texas Workforce Commission, there were no wages associated
with The Exclusive Estates LLC, Solid LLC, or Impressionable Memories LLC between at least
January 1, 2019, and December 31, 2022.
B. THE PAYCHECK PROTECTION PROGRAM
5. The United States Small Business Administration (“SBA”) was an executive
branch agency of the United States government that provided support to entrepreneurs and small
businesses. The mission of the SBA was to maintain and strengthen the nation’s economy by
enabling the establishment and viability of small businesses and by assisting in the economic
recovery of communities after disasters.
6. On or about March 27, 2020, the Coronavirus Aid, Relief, and Economic Security
(“CARES”) Act was enacted to provide emergency financial assistance to the millions of
Americans suffering adverse economic effects caused by the COVID-19 pandemic. The CARES
Act established several new temporary programs and provided for expansion of others, including
programs created and/or administered by the SBA.
7. One source of relief provided by the CARES Act was the authorization of
forgivable loans to small businesses for job retention and certain other expenses, through a
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Case 4:24-cr-00302 Document 71 Filed on 09/18/25 in TXSD Page 3 of 6
program referred to as the Paycheck Protection Program (“PPP”). The PPP provided for
government-backed loans designed to incentivize small businesses to keep their workers on the
payroll by providing funds for up to 8 weeks of estimated payroll costs, including benefits.
8. To obtain a PPP loan, a qualifying business was required to submit a PPP loan
application signed by an authorized representative of the business. The PPP loan application
required the business (through its authorized representative) to acknowledge the program rules and
make certain affirmative certifications in order to be eligible to obtain the PPP loan. In the PPP
loan application, the applicant (through its authorized representative) was required to state, among
other things: (a) its average monthly payroll expenses; and (b) its number of employees. These
figures were used to calculate the amount of money the small business was eligible to receive
under the PPP. In addition, the applicant was required to provide documentation showing its
payroll expenses. The applicant was also required to certify that the business was in operation on
February 15, 2020, and had employees or paid independent contractors.
9. A business’s PPP loan application was received and processed, in the first instance,
by a participating lender. If a PPP loan application was approved, the participating lender funded
the PPP loan using its own monies, which were 100% guaranteed by the SBA.
10. PPP loan proceeds were required to be used by the business on certain permissible
expenses: payroll costs, interest on mortgages, rent, and utilities. The PPP allowed the interest and
principal on the PPP loan to be entirely forgiven if the business spent the loan proceeds on these
expense items within a designated period of time after receiving the proceeds and used a certain
amount of the PPP loan proceeds on payroll expenses.
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C. THE CONSPIRACY
11. Beginning no later than in or about April 2020, and continuing through in or about
September 2022, within the Southern District of Texas and elsewhere, Defendant,
TRENIKIA LASHAE BANKS,
did knowingly combine, conspire, confederate, and agree with co-conspirators known and
unknown to commit the following offense against the United States:
to knowingly devise and intend to devise, a scheme and artifice to defraud,
and to obtain money and property by means of materially false and
fraudulent pretenses, representations, and promises, and for the purpose of
executing such scheme and artifice, did knowingly transmit and cause to be
transmitted, by means of wire communication in interstate and foreign
commerce, certain writings, signs, signals, pictures, and sounds, in violation
of Title 18, United States Code, Section 1343 (wire fraud).
D. MANNER AND MEANS OF THE CONSPIRACY
12. In furtherance of this conspiracy and to effect the objects thereof, the Defendant
and other co-conspirators used the following manner and means, among others:
a. Co-conspirators would submit and cause to be submitted fraudulent PPP
loan applications to induce lenders to approve loans to businesses that did not qualify to receive
loans, or to induce lenders to approve loans in amounts above what the businesses were entitled to
receive.
b. Some fraudulent PPP loan applications submitted by co-conspirators were
for businesses with existing operations, employees, and payroll. On the applications, co-
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Case 4:24-cr-00302 Document 71 Filed on 09/18/25 in TXSD Page 5 of 6
conspirators would inflate the number of employees and monthly payroll of the businesses, to
increase the loan amounts that the businesses would receive.
c. Some fraudulent PPP loan applications submitted by co-conspirators were
for businesses with no existing operations, employees, and payroll. On the applications, co-
conspirators would falsely represent that the businesses had employees and monthly payroll.
d. Co-conspirators would submit and cause to be submitted fraudulent
documents to substantiate their false statements to lenders regarding operations, number of
employees, and monthly payroll of businesses seeking PPP and EIDL loans. These documents
would include, but are not limited to, fake IRS tax forms.
e. Co-conspirators used PPP loan funds in part to pay for unauthorized and
non-business expenses, including but not limited to house payments, car payments, and kickback
payments.
E. OVERT ACTS
13. On or about January 21, 2021, Person C texted BANKS an image file depicting a
first draw PPP application for Impressionable Memories LLC. Person C texted: “121k is what on
app so u know and u have 12 employees.” BANKS responded with the email address:
“Applications@CVB.com.”
14. On or about January 21, 2021, Cache Valley Bank received a first draw PPP
application for Impressionable Memories LLC. The application falsely represented that
Impressionable Memories LLC had 12 employees and an average monthly payroll of tens of
thousands of dollars. Submitted in support of the application was a fraudulent business tax return
for Impressionable Memories LLC purportedly signed by tax preparer Person A.
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Case 4:24-cr-00302 Document 71 Filed on 09/18/25 in TXSD Page 6 of 6
15. Cache Valley Bank approved a first draw PPP loan to Impressionable Memories
LLC in the amount of $121,250. Person C electronically signed the Promissory Note in the name
of “Trenikia L. Banks” on or about February 25, 2021.
16. On or about February 26, 2021, Person C texted BANKS an image file depicting a
portion of the Promissory Note for the first draw PPP loan to Impressionable Memories LLC.
17. BANKS asked: “What’s that promise to pay tho?” Person C responded: “Don’t
worry bout that u don’t have to pay back if paperwork is put in to be forgiven but if u don’t then
it’s a 1 percent loan. I have papers to put in once that time comes up a year from now.”
18. Cache Valley Bank disbursed the first draw PPP loan funds for Impressionable
Memories LLC into Capital One Bank Account x0546 (BANKS dba Impressionable Memories)
on or about March 1, 2021. On or about March 2, 2021, BANKS used the loan proceeds to purchase
a $48,500 cashier’s check made payable to “ADMC Ent.” On or about March 2, 2021, the $48,500
cashier’s check from BANKS was deposited into Allegiance Bank Account x1389 (ADMC), a
bank account belonging to Person C.
All in violation of Title 18, United States Code, Section 371.
NICHOLAS J. GANJEI
United States Attorney
By: _______________________________
Stephanie Bauman
Shirin Hakimzadeh
Assistant United States Attorney
713-567-9000
6
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