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BMW of Springfield USA Loses Federal Appeal Over PPP Loan Forgiveness
Industry News

BMW of Springfield, operating as Celebrity of Springfield, LLC, has lost its federal appeal seeking partial forgiveness of a $2 million Paycheck Protection Program (PPP) loan.

On September 18, 2026, the U.S. Court of Appeals for the Third Circuit upheld a lower court ruling in favour of the Small Business Administration (SBA).

The dealership, controlled by automotive dealer Thomas Maoli, exceeded the SBA’s Corporate Group Rule borrowing limit.

The rule capped aggregate PPP borrowing at $4 million for qualifying commonly owned businesses, but Maoli’s dealership group received approximately $5.06 million across multiple loans.

Although the dealership acknowledged the violation, it sought $936,963 in partial loan forgiveness, arguing that this amount fell within the permitted borrowing threshold.

Its legal team maintained that the business had lost track of its affiliates’ loans.

Writing for the unanimous appellate panel, Judge Thomas Hardiman affirmed that federal regulations did not require partial forgiveness when a borrower breached the aggregate borrowing cap.

The court also noted that the failure to track affiliated loans was not a minor error.

The ruling leaves the dealership responsible for the outstanding loan balance, underscoring the importance of monitoring aggregate borrowing and complying with SBA eligibility requirements.

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