This point has gotten too little attention. PPP set up a purportedly universal program that had to be rationed not just because of limited money available, but because of limited admin capacity to get it out. But then it let banks be the sole arbiter of who got money first! https://twitter.com/jimtankersley/status/1252951942055317504

Under typical SBA guarantee programs, lenders are on the hook for some portion of the loan -- which requires them to make a determination of whether a small biz is creditworthy. So there's intentionally a role for banks to have discretion as to who gets an SBA loan or not.

But PPP loans are 100% guaranteed! Banks aren't on the hook for losses, and aren't being asked to determine whether a business is creditworthy or much of anything else. Yet the program still gives the banks the same discretion as to who gets money and who doesn't.

So essentially, the government has outsourced the decision to JP Morgan Chase as to who gets money first (or at all!) -- with hundreds of millions in fees to go with that privilege -- along with no guardrails or guidance as to who should be at the front of the line.

If someone told you that we were letting JPM or Bank of America decide who gets their unemployment insurance claims processed first, you would look at them funny. But that's almost exactly what PPP has done for small businesses.