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What Does Project 2025 Say?

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On November 5, 2024, the United States Elected Donald J. Trump to a second term. The day after that, his allies gleefully admitted that Project 2025 was their – and his – agenda the entire time.

This is what we’re up against.

Section 4.5: Small Business Administration

“Although PPP worked through private lenders and as a result experienced relatively less fraud than EIDL experienced, it is estimated “that at least 70,000 [PPP] loans were potentially fraudulent.””

Citation: Project 2025, Section 4.5: Small Business Administration, Karen Kerrigan, page 778, paragraph 3
Context:

Is that true? Evidence is mixed on that and still being collected, but there was definitely a ton of fraud.

PPP Stands for Paycheck Protection Program, and was credited for saving millions of jobs during COVID. For more about the fraud claims, see the analysis below.

Full contextual analysis of Section 4.5: Small Business Administration here.

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“Today, initiatives aimed at “inclusivity” are in fact creating exclusivity and stringent selectivity in deciding what types of small businesses and entities can use SBA programs. For example, even though the SBA under President Donald Trump proposed a rule to remove all of the unconstitutional religious exclusions from its regulations to conform with Supreme Court decisions that have made their unconstitutionality clear, the SBA has not acted on the proposed rule and still uses religious exclusions in determining eligibility for business loans.”

Citation: Project 2025, Section 4.5: Small Business Administration, Karen Kerrigan, page 781, paragraph 5
Context:

In context, Kerrigan is arguing that the rules that prevent certain religious organizations or businesses with religious affiliations from benefiting from SBA programs, are exclusionary and unconstitutional. I’d argue that since the SBA is a government program and we have separation of church and state, such restrictions are precisely Constitutional.

The Supreme Court ruling she’s likely referring to here is Trinity Lutheran Church of Columbia, Inc. v. Comer (2017), where the SCOTUS ruled that denying public benefits to an organization solely because of its religious character was unconstitutional. More about the ruling and why it was wrong in the analysis below.

Full contextual analysis of Section 4.5: Small Business Administration here.

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“An end to SBA direct lending.”

Citation: Project 2025, Section 4.5: Small Business Administration, Karen Kerrigan, page 782, fifth bulleted point
Context:

Without direct SBA loans, small businesses would have to rely solely on private banks and financial institutions for funding. This shift could make it harder for small businesses – especially new, underserved, or high-risk enterprises – to access the capital they need. Banks may view these businesses as too risky without the SBA’s direct involvement.

It would also result in higher interest rates for the businesses that CAN get private funding – SBA offers lower interest rates than businesses can typically get from private lenders. This would reduce access for businesses in marginalized and underserved communities.

Kerrigan goes on to argue that neither should the SBA provide disaster relief funds to small businesses, and that no new direct lending programs be developed at the SBA.

Kerrigan then goes on to argue for making religious entities eligible for SBA loans. This raises a key question: Is the goal to end SBA lending altogether (as explicitly stated), or to expand access to religious organizations? This is a contradictory position. It’s possible that she’s arguing for ending direct SBA loans, which are loans disbursed directly by the SBA, but not other forms of SBA support like loan guarantees or R&D grants. This isn’t explicitly defined, however, so I’m left speculating in order to give Kerrigan the benefit of the doubt.

Kerrigan may also be arguing here to shift the SBA’s focus from direct lending to facilitating private lending, which would allow religious organizations to access capital via guaranteed loans rather than direct SBA funds. But again, this isn’t specified.

Full contextual analysis of Section 4.5: Small Business Administration here.

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