Bank, PPP and EIDL matters · National preparation support
PPP Forgiveness and Fraud Investigation: Separate the Questions
Distinguish a forgiveness decision from later review questions. Organize the underlying application, supporting records and agency correspondence.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
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Identify what was actually decided
Keep the forgiveness application, submitted attachments, lender communications and final determination together. Record the date, amount and any qualifications in the decision. Do not describe a pending request as granted or assume that a dashboard status explains every issue. SBA OIG has discussed reviews for fraud and eligibility after forgiveness in its published oversight work.
Compare the application histories
The original loan application and the forgiveness request may cover different questions and periods. Create a version list showing who prepared, reviewed and submitted each document. Preserve the source records used at the time. If later accounting corrections differ from an earlier submission, identify both versions and the reason documented for the change without rewriting the earlier record.
Keep program review and criminal questions separate
A request for additional documentation does not itself establish a criminal charge. Conversely, do not treat forgiveness as a legal conclusion about every potential allegation. Counsel evaluates the significance of the actual correspondence and applicable law. The preparation task is to make the sequence and supporting records clear enough for that evaluation.
Document your role at each step
Identify what information you supplied, what you reviewed, what you certified and what you learned later. Outside assistance should be described accurately, with engagement records and communications where available. Neither using a preparer nor signing a form supplies a complete account of the facts. SAG can help organize the personal chronology for counsel’s review.
Continue your preparation
Does loan forgiveness guarantee that no later review will occur?
No. Preserve the determination and underlying records. Ask counsel to evaluate any later request or allegation on its own terms.
Sources and a defined preparation assignment
Official context: SBA OIG: PPP loan review processes (2022 oversight report). 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.