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After months of court proceedings, the U.S. Small Business Administration (SBA) released the loan details of all Payroll Protection Program (PPP) borrowers on Dec. 1, 2020.

The release of the PPP loan level data comes after a number of media organizations filed Freedom of Information Act (FOIA) requests and subsequently filed federal lawsuits seeking the release of the PPP loan level details when the SBA failed to release the requested data pursuant to the FOIA.

Previously, on July 6, 2020, the SBA released PPP loan-level data for PPP borrowers, including business names, addresses, North American Industry Classification System (NAICS) codes, zip codes, business type, demographic data, non-profit information, name of lender, jobs supported and loan amount within a range segregated by loan size. At that time, for all loans below $150,000, the SBA released the same information, but excluded business names, addresses and specific loan amounts.

On Nov. 5, 2020, a federal judge ruled that the SBA must release all loan level data, including names, addresses and precise loan amounts of all PPP loan borrowers, including borrowers with loan amounts less than $150,000. Based on the SBA's PPP Report showing approvals through Aug. 8, 2020, the release of the loan level data for loans less than $150,000 will result in additional detail regarding 4.5 million PPP loans (out of a total number of PPP loans of 5.2 million) and provide the exact loan amount for the approximately 700,000 loans exceeding $150,000.

The release of this information may provide unexpected risks for PPP borrowers.  For example, the American Bankers Association notified its members that some third-party businesses were using the publicly released data to solicit business from PPP borrowers, specifically referencing the name of the lending institution—in some cases not disclosing that they are unaffiliated with the PPP lender, and others are implying a business relationship where none exists.[1]

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[1] "SBA Releases PPP Loan Data; ABA Updates Talking Points, Resources." ABA Daily Newsbytes.

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