PPP Investigation & Fraud Defense Services

The Paycheck Protection Program ended on May 31, 2021, but the program is still front of mind for regulatory authorities. Vallit can help with PPP SBA reviews and appeals, PPP fraud investigations, and PPP forgiveness corrections.

Specializing in PPP

A niche area question requires niche area expertise. Vallit can provide the timely expertise necessary to handle any PPP matter, including corresponding with lenders, the SBA or DOJ, and clients.

When the CARES Act was passed in March 2020, members of the Vallit team quickly worked to become PPP subject matter experts. One team member in particular, Erica Price, was selected for her firm’s COVID-19 Task Force. While initially being a resource for internal and external PPP questions, her responsibilities quickly expanded to overseeing PPP consulting services, including PPP forgiveness assistance, ERC calculation, and PPP interplay. Vallit Advisors has experienced team members who have been involved with the program since inception and have remained current on PPP developments.

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Why Choose Vallit Advisors

Vallit Advisors takes a unique approach to PPP investigations and fraud defense. Our team not only has experience in public accounting and a background in audit, but is credentialed with CPA and CFE designations. This background has enabled us to provide valuable forgiveness assistance services and calculate hundreds of thousands of ERC dollars due.

Beyond consulting for our clients, Vallit team members frequently present and author thought leadership on many topics in the forensic accounting and valuation industries. In particular, Vallit’s lead for PPP services, Erica Price, has on multiple occasions authored and presented on the PPP as a subject matter expert.

Who We Can Work With

We have the resources and knowledge base to address and solve your PPP matter. Vallit can partner with:

  • CPAs that have clients with PPP concerns,
  • Attorneys in need of a PPP expert witness,
  • PPP borrowers dealing with an SBA review or DOJ investigation, and
  • PPP lenders looking to recommend professional PPP assistance to their borrowers.  

PPP Investigation & Fraud Defense Services

For a PPP loan of any size, SBA may undertake a review at any time, before or after SBA remits a forgiveness payment to the lender, in SBA’s discretion." (SBA’s PPP Loans Frequently Asked Questions, Question 39)

In August 2022, the "PPP and Bank Fraud Enforcement Harmonization Act of 2022” was passed, extending the statute of limitations for PPP fraud charges to 10 years. This significantly increased the amount of time Borrowers can be subject to investigation by regulatory authorities, regardless of forgiveness status.

Now that most loans have been forgiven, the SBA has been able to shift its resources from loan approval and forgiveness, to loan review. But enforcement efforts aren't just coming from the SBA. In September 2022, the Department of Justice established three Strike Force teams to assist the already established COVID-19 Fraud Task Force in a prosecutor-led approach on combatting COVID-19 fraud. 

“There are years and years and years of work ahead of us,” said Kevin Chambers, the Justice Department’s chief pandemic prosecutor. “I’m confident that we’ll be using every last day of those 10 years.” 

It’s been quite some time since most professionals have had to assist with PPP forgiveness or answer PPP questions. The program, which was established in March 2020, underwent continuous changes as first the loan application process, and later the loan forgiveness process, were rolled out. The program was then modified further and expanded by the Economic Aid Act and the America Rescue Plan Act of 2021. Between April 2020 and September 2021, the SBA issued over 30 Interim Final Rules and 43 pages of Frequently Asked Questions on the program. Staying up to date on program changes was a full-time job. Vallit has the expertise to know not only the most current regulations, but also what set of rules were applicable at the time a specific loan application or forgiveness application was approved.

Offering both proactive and reactive services, we can step in and assist at any phase. Proactive services can provide a sense of relief and identify potential problems on your own time, before regulatory agencies get involved. Reactive services, (offered after a PPP issue has been identified by the lender or a regulatory authority) can ensure the matter is handled correctly, by someone who understands your client’s specific situation and knows how to speak PPP.

The PPP program rules are complicated, and sometimes a miscommunication or misunderstanding can result in incorrect eligibility or forgiveness decisions. 

Even if phrases like "This decision is final." and "There is no other recourse." are getting thrown around, we can still bring clarity and understanding to the situation, and in instances where a correction is called for, we can fight to make that happen.

Mark Norris Cutout

"Vallit is excited to add PPP Investigation and Fraud Defense services to its repertoire of forensic and expert services. The SBA and Department of Justice are focusing on reviewing previously forgiven loans for fraud now that their enforcement period has been extended to 10 years. Erica and her team strengthen our mission of protecting businesses and their assets by becoming the ally business owners and their advisors need when a challenge arises in this complex service area."

Mark Norris