Review all loans that had a bank account number changed from that shown on the original application to determine if the changes were legitimate or fraudulent. If not legitimate, work to recover the funds, deobligate any undisbursed funds, and refer to the OIG.
Strengthen controls for verifying an entity’s start date to ensure applicants meet eligibility requirements.
Establish or strengthen controls to ensure loan deposits are made to legitimate bank accounts for eligible borrowers only.
Review duplicate loans to IP addresses, email addresses, business addresses, and bank accounts to determine if there are undisbursed funds that should be suspended until the duplicate loans are assessed for eligibility.
Cancel all ineligible loans that are not disbursed, recover funds from all loans disbursed to ineligible applicants, and flag those loans for the improper payments estimation process.
Strengthen or establish controls to ensure multiple loans are provided only to eligible applicants and prevent the erroneous duplication of loans.
Strengthen data integrity to make it possible to determine if the inaccurate information allowed loans to be made to ineligible entities and to strengthen SBA’s ability to service loans appropriately.
Review the applicants with approved loans to determine if there are undisbursed funds remaining that should be suspended until the business start date is verified and the applicant is deemed eligible based on the CARES Act eligibility requirements. If the applicant is deemed ineligible, recover any disbursed funds, deobligate any undisbursed funds, and flag the application as ineligible.
Review the advance grants to determine if the application was legitimate and the business met CARES Act eligibility requirements. If not, recover the funds and flag the application as ineligible.
Revise the FY 2021 Improper Payments Act Checklist to include checking EIN dates for COVID-19 EIDLs and advance grants or program the system to flag erroneously approved loans and advance grants as improper payments; the information should be used during the FY 2021 improper payments estimation process.