V-Finder · Gap Closer

Public data only. Scores are statistical indicators, not accusations. V-Finder does not allege that anyone committed a crime; people in Caught Cases are named only because a public DOJ release names them. How scores work · Report an error or request a correction: python0o@mail.grokbot.com

Gap Closer: the data that would catch what we miss

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.

An invitation, not a claim. V-Finder has not received any of this data. Agencies and states that hold it can plug their own data in under their own legal authority. Counts come from the Known gaps review of DOJ releases. Many releases describe more than one scheme, so the counts are approximate and the “up to” numbers overlap. 6 misses are unclear from their release.

Fake Schedule C sole proprietor

60 missed charged loans explained (58 under $150k) · could address up to 60

Data that would close it: 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)
How to get access: The borrower signs IRS Form 4506-T. IRS law bars other sharing. SBA began collecting tax transcripts for EIDL in April 2021.
V-Finder flag it would enable: “Self-employed income on the application doesn’t match the tax return” or “No Schedule C on file for the year claimed.”

Sources: PRAC: SBA PPP Phase III Fraud Controls (Jan 2021)

Inflated payroll or employees at a real business

28 missed charged loans explained (18 under $150k) · could address up to 28

Data that would close it: 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)
How to get access: IRS: borrower consent (4506-T). State and NDNH wage data: only agencies with legal authority, under data-sharing agreements.
V-Finder flag it would enable: “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

Fake or shell business

21 missed charged loans explained (17 under $150k) · could address up to 21

Data that would close it: 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
How to get access: Many states publish registries as open data (V-Finder already uses CO, NY, CT, OR and TX). Others sell bulk data. A state can plug its file into V-Finder.
V-Finder flag it would enable: “Business registered after Feb 15, 2020” or “Not registered in its state.”

Sources: PRAC example: 5 of 11 businesses created after Feb 15, 2020

Ring, recruiter or kickback member

13 missed charged loans explained (4 under $150k) · could address up to 13

Data that would close it: 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)
How to get access: Already used by SBA OIG link analysis and PACE. A lender or agency could share hashed identifiers so V-Finder can link loans without exposing them.
V-Finder flag it would enable: “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

Stolen or synthetic identities

11 missed charged loans explained (9 under $150k) · could address up to 11

Data that would close it: 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)
How to get access: SBA has screened new PPP applications through Do Not Pay since January 2021. eCBSV is a paid service for permitted financial institutions and needs the person’s consent.
V-Finder flag it would enable: “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

Also took EIDL or other relief

4 missed charged loans explained (3 under $150k) · could address up to 4

Data that would close it: 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)
How to get access: PACE already matches across programs (“multi-dipping”). SBA and the states could share EIDL and UI records with authorized analysts.
V-Finder flag it would enable: “Same owner also received an EIDL loan or collected unemployment while claiming payroll.”

Sources: PRAC: About PACE

Fake tax or payroll documents

4 missed charged loans explained (3 under $150k) · could address up to 4

Data that would close it: IRS transcripts to compare with the Form 941, W-2 or 1099 the borrower uploaded
Who holds it: IRS (borrower consent)
How to get access: Form 4506-T consent at application time.
V-Finder flag it would enable: “The uploaded Form 941 is not on file with the IRS.”

Sources: PRAC: Phase III Fraud Controls

Lender insider or tax preparer

4 missed charged loans explained (4 under $150k) · could address up to 4

Data that would close it: Lender underwriting files (loan officer, preparer and processor IDs) and suspicious activity reports (SARs) filed by banks
Who holds it: Lenders; SBA; FinCEN (SARs)
How to get access: SARs are confidential. FinCEN allows a PPP lender to tell SBA a SAR exists when it asks SBA to buy the guarantee. Banks filed over 21,000 PPP-related SARs from April to October 2020.
V-Finder flag it would enable: “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.