Bank, PPP and EIDL matters · National preparation support
PPP and EIDL Use of Funds: Organize the Transaction Record
Build a traceable record of disbursements, transfers and expenditures for counsel without treating every account movement as a final use.
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 program and source account
Keep PPP and EIDL receipts separate in the working inventory. Record the borrower entity, disbursement date, amount and source statement. Counsel evaluates the applicable program rules and relevant time period. A general description such as business expenses does not replace the underlying records or establish that a particular expenditure met program requirements.
Follow transfers to the underlying event
A transfer may move funds between accounts before a later payment. Record each step without counting the same funds repeatedly as separate expenditures. Keep the original statements, invoices and payment confirmations available. If funds were commingled, identify that fact and ask a qualified financial reviewer to determine the appropriate tracing approach.
Distinguish description from conclusion
A bank memo is a source description, not necessarily a complete explanation of purpose. Identify supporting invoices, contracts or payroll records where available. Keep undocumented recollections labeled as such. Do not reconstruct invoices or change memo fields to improve the appearance of the record. Counsel determines what explanations and supporting materials are appropriate.
Connect transactions to actual responsibility
Identify who authorized, initiated and recorded relevant payments, using available records. Access to an account does not explain every transaction, and a title does not replace a candid account of personal actions. SAG can organize the individual chronology and source index; forensic tracing and legal conclusions remain with qualified professionals.
Continue your preparation
Can SAG provide a forensic tracing opinion?
No. SAG can organize the personal chronology and source index. Qualified financial specialists and counsel evaluate tracing and legal significance.
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.
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.