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V-Finder uses only public data. That misses 151 of 239 publicly charged PPP loans (121 of them under $150k). For each type of miss, this page lists the non-public data that would close the gap, who already holds it, and the plain-English flag V-Finder could show if that data were plugged in.
60 missed charged loans (58 under $150k)
Data that would help: IRS tax return transcripts (Form 1040 Schedule C) for the year the borrower claimed
Who holds it: IRS (shared only with the borrower’s consent)
New flag: “Self-employed income on the application doesn’t match the tax return” or “No Schedule C on file for the year claimed.”
28 missed charged loans (18 under $150k)
Data that would help: Quarterly wage records: IRS Form 941 transcripts, state unemployment-insurance (UI) wage reports, and the National Directory of New Hires quarterly wage file
Who holds it: IRS; state workforce agencies; HHS Office of Child Support Services (runs the NDNH)
New flag: “Payroll claimed is 4× the wages reported to the state” or “No employees on file for this employer ID.”
Sources: PRAC: Phase III Fraud Controls · ACF: National Directory of New Hires
21 missed charged loans (17 under $150k)
Data that would help: Secretary of State business registrations (formation date, status, registered agent) and the date the IRS issued the employer ID
Who holds it: Each state’s Secretary of State; IRS
New flag: “Business registered after Feb 15, 2020” or “Not registered in its state.”
Sources: PRAC example: 5 of 11 businesses created after Feb 15, 2020
13 missed charged loans (4 under $150k)
Data that would help: Application intake logs: IP address, device, phone, email and bank account for each application
Who holds it: PPP lenders and loan processors; SBA; SBA OIG (subpoenaed some lender intake data); PRAC’s Pandemic Analytics Center of Excellence (PACE)
New flag: “Shares a phone, bank account or IP address with 12 other loans, 3 of them already flagged.”
Sources: SBA OIG Report 23-09 (link analysis) · PRAC: About PACE
11 missed charged loans (9 under $150k)
Data that would help: Identity checks: SSA Death Master File and other Do Not Pay sources, and SSN/name/date-of-birth verification
Who holds it: Treasury Do Not Pay; Social Security Administration (eCBSV)
New flag: “Owner’s SSN belongs to a deceased person” or “SSN doesn’t match the owner’s name and birth date.”
Sources: SBA OIG Report 21-06 (Do Not Pay match) · PRAC lessons learned (June 2022) · SSA eCBSV
4 missed charged loans (3 under $150k)
Data that would help: Borrower-level EIDL loan records and state unemployment claims
Who holds it: SBA (EIDL); state workforce agencies (UI claims, also in the NDNH UI file)
New flag: “Same owner also received an EIDL loan or collected unemployment while claiming payroll.”
Sources: PRAC: About PACE
4 missed charged loans (3 under $150k)
Data that would help: IRS transcripts to compare with the Form 941, W-2 or 1099 the borrower uploaded
Who holds it: IRS (borrower consent)
New flag: “The uploaded Form 941 is not on file with the IRS.”
Sources: PRAC: Phase III Fraud Controls
4 missed charged loans (4 under $150k)
Data that would help: Lender underwriting files (loan officer, preparer and processor IDs) and suspicious activity reports (SARs) filed by banks
Who holds it: Lenders; SBA; FinCEN (SARs)
New flag: “The same loan officer or preparer handled 40 loans, 6 of them already flagged” or “Lender filed a SAR on this loan.”
Sources: FinCEN PPP FAQs (Jan 2024) · GAO-21-472T
Background: PRAC’s Pandemic Analytics Center of Excellence uses 59 datasets (over 1.6 billion records) for this kind of matching (About PACE). See also Caught Cases and the method page.