Appendix I: Objectives, Scope, and
Methodology
Page 60 GAO-21-577 Paycheck Protection Program
a minority-owned depository institution, and (3) geography, using regions
identified in a Census Bureau map. We conducted pretests of the survey
with the seven banks we interviewed to ensure survey questions were
clear, obtain any suggestions for clarification, and determine whether
representatives would be able to provide responses to questions with
minimal burden.
To examine the safeguards SBA put in place during the PPP loan
approval process, we analyzed key provisions related to PPP in the
CARES Act, the Paycheck Protection Program and Health Care
Enhancement Act, the Consolidated Appropriations Act, 2021, and the
American Rescue Plan Act, among others.
4
We also analyzed SBA’s
design and implementation of those provisions based on interim final
rules, procedural notices, and responses to frequently asked questions
(FAQ), including changes to the program SBA made when it launched
Round 2 in January 2021. We reviewed SBA’s annual financial statement
audit, reports issued by the SBA Office of Inspector General, and prior
GAO reports.
5
To analyze lending activity for PPP loans issued to borrowers charged by
the Department of Justice (DOJ), we identified fraud-related cases by
reviewing publicly available DOJ and court information as of March 2021.
We compared borrowers identified through DOJ cases to PPP loan-level
data, which contained associated lender information. We did not conduct
in-depth analyses of lender antifraud controls. We interviewed three
industry professionals with knowledge of synthetic identity fraud, lending
4
Pub. L. No. 116-136, 134 Stat. 281, (2020); Pub. L. No. 116-139,134 Stat. 620 (2020);
Pub. L. No. 116-260, div. N, tit. III, 134 Stat. 1182, 1993 (2020); and Pub. L. No. 117-2, §
5001, 135 Stat. 4, 81 (2021).
5
For example, Small Business Administration, Office of Performance Management and the
Chief Financial Officer, Agency Financial Report Fiscal Year 2020 (Washington, D.C.:
Dec. 18, 2020); Small Business Administration, Office of Inspector General, Flash Report:
Duplicate Loans Made Under the Paycheck Protection Program, Report No. 21-09
(Washington, D.C.: Mar. 15, 2021); GAO, COVID-19: Opportunities to Improve Federal
Response and Recovery Efforts, GAO-20-625 (Washington, D.C.: June 25, 2020);
COVID-19: Brief Update on Initial Federal Response to the Pandemic, GAO-20-708
(Washington, D.C.: Aug. 31, 2020); COVID-19: Federal Efforts Could Be Strengthened by
Timely and Concerted Actions, GAO-20-701 (Washington, D.C.: Sept. 21, 2020); COVID-
19: Urgent Actions Needed to Better Ensure an Effective Federal Response, GAO-21-191
(Washington, D.C.: Nov. 30, 2020); COVID-19: Critical Vaccine Distribution, Supply Chain,
Program Integrity, and Other Challenges Require Focused Federal Attention, GAO-21-265
(Washington, D.C.: Jan. 28, 2021); and COVID-19: Sustained Federal Action Is Crucial as
Pandemic Enters Its Second Year, GAO-21-387 (Washington, D.C.: Mar. 31, 2021).