Bank, PPP and EIDL matters · National preparation support
Bank and PPP Fraud Restitution: Prepare a Traceable Financial File
Organize proposed obligations, recoveries and financial records for restitution review in a bank or PPP fraud matter.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
Request a Private Case Review · (646) 588-8182
Identify the proposed recipients and amounts
Begin with the actual demand, agreement or proposed order. List each recipient, amount, supporting schedule and status. Distinguish a lender, an agency and another claimant when the records identify different parties. Counsel determines entitlement and legal obligations. A working summary should not convert a disputed request into an established debt or omit an existing order.
Document recoveries without assumptions
Create a dated ledger of repayments, returned funds and other documented recoveries. Preserve confirmation of receipt where available. A frozen account, seized asset or proposed sale is not the same as a completed distribution. Ask counsel how any recovery relates to the proposed obligation; do not promise that every asset will reduce restitution dollar for dollar.
Prepare an accurate financial picture
Organize current income, assets, liabilities and necessary household expenses with source records. Distinguish individual ownership from business property and joint interests. Do not hide an asset because access is restricted or count projected earnings as confirmed income. Counsel can identify which disclosures and supporting materials are required and how they should be handled.
Make the hearing file reviewable
Use a source index, version history and short list of calculation questions. Joseph’s Bloomberg Law analysis on fraud payback hearings connects directly to this preparation problem: can a reviewer trace the proposed figures to reliable evidence? SAG can organize the agreed file with counsel, but cannot determine the obligation or guarantee a financial outcome.
Continue your preparation
- PPP Fraud Loss Records
- Forfeiture versus restitution
- Restitution hearing preparation
- PSR financial disclosure
Does an asset seizure mean restitution has been paid?
Do not assume that. Preserve the seizure and any later distribution records, and ask counsel how they affect the obligation.
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.