Bank, PPP and EIDL matters · National preparation support
Documenting Corrective Work in Bank and PPP Fraud Matters
Show what changed, when it changed and how it was implemented through verifiable records coordinated with defense counsel.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
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Identify the specific problem addressed
A general claim that controls improved is difficult to inspect. Describe the process that changed, the date and the person responsible. Preserve earlier policies as well as revisions. Counsel should review how the issue is characterized, especially where facts remain disputed. Do not rewrite historical records to make current procedures appear to have existed earlier.
Separate policy from implementation
A new approval rule is not the same as evidence that staff followed it. Organize training records, completed reviews and dated examples of implementation where appropriate. Identify the period covered and limitations of the evidence. A consultant’s preparation file is not an audit opinion or certification that future problems cannot occur.
Document personal work with equal care
Treatment, education, employment and service should have accurate dates and supporting records. Distinguish enrollment from completion and intentions from sustained activity. Obtain appropriate permissions for sensitive material and coordinate with counsel before use. The strongest preparation makes the actual work visible without inflating its scope or predicting how a judge will weigh it.
Connect evidence to realistic plans
Explain how current practices support lawful employment, household responsibilities and future obligations. Keep proposed arrangements separate from confirmed ones. SAG can help assemble the chronology and source index, with counsel controlling legal submissions. No volume of corrective-work documentation guarantees a sentence, charging decision or other result.
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Is a written policy enough to establish implemented change?
A policy shows what was written. Keep separate evidence of training, use and follow-through, and describe its limits accurately.
Sources and a defined preparation assignment
Official context: U.S. Sentencing Commission: 2026 Guidelines Manual. Sources checked November 6, 2026. Program resources and historical oversight reports do not decide an individual case. Counsel evaluates the applicable law, dates and facts.
Work directly with Joseph to define the scope, authorized recipients and review dates. Agreed deliverables can include a personal and professional chronology, indexed supporting records, factual questions for counsel and a practical preparation schedule. SAG does not manage legal responses or provide forensic accounting. An engagement does not automatically establish privilege.
SAG serves clients nationwide from New Jersey, with travel arranged for cases. SAG is not a law firm. No charging decision, sentence, placement or release date is guaranteed.
For defense counsel: Discuss Support for Your Client. Share your role, stage and next deadline, not sensitive financial records or privileged advice, in the initial inquiry.