Bank, PPP and EIDL matters · National preparation support

PPP Investigation Preparation for Business Owners

Document ownership, delegation, operational history and personal responsibilities in a PPP matter without relying on job titles alone.

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

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

Build an ownership timeline

Identify the legal entities, ownership interests and dates of acquisition, transfer or closure. Keep formation documents and relevant agreements available. A current ownership chart may not describe the business when an application was prepared. Mark periods when authority or operations changed and identify the contemporaneous records supporting those changes.

Describe delegation precisely

Record what you asked employees or outside providers to do, what information you supplied and what you reviewed. Delegation should not be described as a complete absence of involvement when records show otherwise. Conversely, do not substitute the owner title for a detailed account of every task. Counsel needs the actual sequence and supporting communications.

Separate business disruption from individual decisions

Pandemic-era operating conditions may provide context, but they do not by themselves establish what a person knew or did. Document closures, staffing changes and financial pressures with dated sources where relevant. Avoid broad claims about all businesses or all borrowers. Explain the particular circumstances without using hardship to erase responsibility for actual conduct.

Plan for the business and household

Identify authorized operational responsibilities, employees who depend on the business and realistic continuity arrangements. Keep confirmed agreements separate from proposals. SAG can help organize professional history and practical plans while counsel addresses legal and investigative decisions. Do not disclose employee data or sensitive financial documents through a general inquiry form.

Continue your preparation

Is being the owner a complete description of my role?

No. Prepare a dated account of actual duties, decisions, delegation and knowledge, supported by the available records.

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.