Bank, PPP and EIDL matters · National preparation support
Individual Roles in Bank and PPP Fraud Matters
Create a precise chronology of duties, access, decisions and knowledge in a multi-person bank or PPP case for counsel’s review.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Use actions rather than labels
Owner, employee, accountant and manager are starting points, not complete descriptions. Record what you personally prepared, reviewed, approved, submitted or learned. Include dates and supporting sources. Do not use a broad label either to claim responsibility for everything or to avoid explaining actions you actually performed.
Map changes over time
A person’s authority may change during the relevant period. Note hiring, promotion, departure, ownership changes and system-access changes. Separate formal authority from actual activity, with evidence for each. A later job description should not replace the contemporaneous record. If the date is uncertain, state the uncertainty and identify potential sources.
Distinguish your knowledge from the company record
A document may have existed without you seeing it at the time. Conversely, an informal conversation may be relevant even if no formal document was created. Clearly label firsthand recollection, contemporaneous evidence and later information. Counsel evaluates credibility and legal significance; preparation should not turn uncertainty into a confident assertion.
Connect responsibility to the broader personal record
Where appropriate to the stage, connect the chronology to documented accountability, corrective work and practical plans. Avoid blaming others through unsupported assertions or using generalized praise to bypass difficult facts. SAG can organize the evidence and questions so counsel can assess a candid, specific account.
Continue your preparation
Does a limited title establish a limited legal role?
Not by itself. Counsel evaluates actual conduct and applicable law. Prepare the factual chronology rather than relying on the title.
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.