Bank, PPP and EIDL matters · National preparation support

PPP Application Records: Build a Version and Responsibility Map

Track PPP application versions, source figures, certifications and who performed each step so counsel can review an accurate chronology.

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

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

Create a version register

Assign each available application a descriptive working label and record its date, entity, program round and source. Keep drafts separate from submitted copies. A downloaded form without a submission confirmation may not prove what the lender received. Preserve email attachments, portal confirmations and later amendments so the legal team can follow the actual sequence.

Trace figures to their sources

For each material figure, identify the payroll report, tax filing, bank record or other source used. Record the period and calculation shown in the contemporaneous file. Do not insert a later corrected number into the historical version. If the source cannot be located, mark the gap and identify who may hold it rather than manufacture a supporting document.

Map preparation, review and certification

Distinguish the person who gathered records, entered information, reviewed the form and submitted or certified it. A single individual may have done several steps, but those steps should not be collapsed into a job title. Record what communications show and what is based on recollection. Counsel determines the significance of each person’s conduct and knowledge.

Make the result usable

Provide a short chronology, a file index and an unresolved-question list. Use consistent entity names and date formats. Keep account numbers and other sensitive identifiers in the secure source file rather than repeating them throughout a narrative. SAG’s role can include organizing the individual account; legal and accounting conclusions require qualified review.

Continue your preparation

Should I replace an old application with corrected numbers?

Preserve the original. Keep any later correction separately, dated and explained. Counsel should direct any communication or submission.

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.

Request a Private Case Review

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.