Bank, PPP and EIDL matters · National preparation support

EIDL Fraud Investigation: Loan History, Uses and Individual Roles

Prepare a source-backed EIDL chronology covering application records, disbursements, account activity and individual responsibilities for counsel.

By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026

Request a Private Case Review · (646) 588-8182

Keep EIDL and PPP files distinct

SBA maintains separate resources for its COVID-era programs. Do not apply a PPP forgiveness assumption to an EIDL file. Identify the exact program and loan documents involved, including any advance, modification or increase. Record the entity, application date and amount requested separately from amounts approved and actually disbursed. Counsel evaluates the governing requirements and legal significance.

Build a transaction timeline

Start with source statements showing receipt of funds, then identify the records needed to understand subsequent activity. A transfer between accounts is not the same event as a final expenditure. Record the destination, date and supporting document without guessing the purpose from a short bank description. Preserve original statements and clearly label any working spreadsheet as a reconstruction.

Separate servicing history from allegations

Keep billing statements, repayment records, returned funds and agency correspondence in their own dated sequence. A servicing status does not by itself explain whether an allegation is supported or what an investigation will do next. Ask counsel which issues require financial or legal analysis. Preserve unresolved discrepancies rather than forcing a loan balance to match a different proposed loss figure.

Prepare for changing practical needs

Business operations, employment and household finances may change during a matter. Document current income and obligations, confirmed restrictions and authorized plans. SAG can help organize professional history, individual responsibilities and practical preparation in coordination with counsel. Decisions about communications with agencies, disposition of funds and legal responses belong with the legal team.

Continue your preparation

Is an EIDL repayment record the same as a restitution calculation?

No. Keep the servicing history and any proposed legal calculation separately. Counsel determines whether and how a payment affects an obligation.

Sources and a defined preparation assignment

Official context: SBA COVID-era program resources. 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.

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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.