Kabbage
FRA provided sophisticated forensic and data analytics expertise in support of the DOJ’s investigation into False Claims Act violations by fintech lender Kabbage.
Kabbage, a prominent fintech lender and participant in the US Paycheck Protection Program (PPP), became the subject of a government investigation led by the District of Massachusetts and the US Department of Justice (DOJ). The DOJ alleged that Kabbage had defrauded the PPP through improper loan practices during the Covid-19 pandemic, resulting in a resolution in which the company agreed to pay up to $120 million to settle the allegations.
This high‑profile matter required sophisticated financial analysis, detailed review of program‑related evidence, and subject matter fluency in False Claims Act (FCA) matters. Given the complexity of PPP processes and the substantial regulatory scrutiny surrounding fintech lenders, counsel needed a trusted forensic partner capable of navigating large datasets, compliance questions, and the nuances of DOJ expectations.
Applying sophisticated data analytics to identify potential indicators of misconduct
FRA contributed its deep experience in government‑led investigations and False Claims Act matters to support the needs of counsel throughout the engagement.
Our work included:
- Leveraging forensic and data analytics expertise to identify potential breaches in US Small Business Administration’s (SBA) loan calculation rules, particularly regarding the salary cap of $100,000 per employee, double counting of taxes, and the inclusion of fringe benefits in the loan
- Reviewing Kabbage’s complete loan portfolio, analyzing over 320,000 loans and 40 million data points to refine the loan population to just over 200 potentially problematic loans
- Assisting legal teams in evaluating patterns, potential indicators of misconduct, and documentation relevant to the allegations
- Providing strategic support aligned with DOJ processes and expectations around evidence presentation and analytical rigor
FRA also carried out an ability-to-pay analysis to quantify the maximum penalty that the company could pay without interrupting its ordinary and necessary business and to minimize the going concern risk.
A successful conclusion to a difficult investigation
FRA equipped counsel with a clear, defensible understanding of the issues, delivering support to meet regulatory demands and navigate sensitive discussions with government authorities.
In May 2024, the DOJ publicly announced that Kabbage agreed to pay up to $120 million to resolve the False Claims Act allegations.
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