Introduction

Since 1953, the Small Business Administration (SBA) Disaster Loan Program has provided disaster loans to eligible households and businesses to help them rebuild and recover after a disaster. Disaster loans for individuals and households (known collectively as home disaster loans) fall into two categories: (1) Personal Property Disaster Loans and (2) Real Property Disaster Loans. Disaster loans for businesses (known collectively as business disaster loans) also fall into two categories: (1) Business Physical Disaster Loans, and (2) Economic Injury Disaster Loans (EIDL).

Beginning in 1957, the SBA set loan limit amounts which were published in the Federal Register and presented in SBA's Administrative Manual. In 1968, SBA started setting limits through regulation. Since 1980, Congress has established disaster loan limits (or caps) in statute establishing a maximum amount of money that can be borrowed through these programs for any one disaster. The SBA Administrator is authorized to set the limit at a lower rate because the statutory language establishes a ceiling for disaster loans but does not establish a floor.¹ Historically, businesses have been eligible for the full amount set in statute whereas individuals and households have been eligible for a lesser amount set in federal regulation by SBA. This is presumably because the costs associated with repairing and rebuilding a home are less than repairing and rebuilding a business. Working capital expenses may also be significantly higher than home repair and rebuilding costs. Additionally, smaller loan amounts may help the SBA provide more loans to individuals and households if there are budgetary limitations for these programs.²

The current maximum amount available to individuals and households for home disaster loans was set in regulation by the SBA Administrator in 1994. They are (1) $100,000 for Personal Property Disaster Loans; and (2) $500,000 for Real Property Disaster Loans. The SBA Administrator is authorized to increase disaster home loan limits based on "appropriate economic indicators for the region(s) in which the disaster occurred."³ The economic indicators include current building costs, regional median home prices, the Consumer Price Index (CPI), and the Producer Price Index (PPI).

The current maximum amount available to businesses through Business Physical Disaster Loans and EIDLs is $2 million, the same amount that was set in statute in 2008 (see Figure 1).⁴ For small business borrowers that are considered major employers and designated as a Major Source of Employment (MSE), the SBA may, under specified circumstances, exceed the $2 million loan limit to avoid substantial unemployment in a disaster area. P.L. 110-246 included a provision granting the SBA Administrator this waiver authority.⁵ The SBA has granted waivers for eligible MSEs in the past. For example, based on SBA disaster loan data in FY2022, the SBA approved 37 applications for disaster loans exceeding $2 million.⁶ A similar waiver authority is not provided for the individuals and households programs.

This report provides an overview of the historical developments of disaster loan limits, followed by policy options related to disaster loan limits. To help contextualize disaster loan limits, this report includes narratives about inflation, construction costs, and median home values and prices. A description of SBA disaster loan categories is located in the Appendix of this report.

Historical Developments

SBA disaster loan limits were first introduced in 1957 through SBA notices published in the Federal Register and presented in SBA's Administrative Manual. For example, on July 20, 1957, SBA announced that it would not provide disaster loans exceeding $100,000.⁷ Previously, the disaster loan amount was determined on an individual basis, taking into account the circumstances of the applicant and the disaster. A search of the Federal Register indicates that SBA limited disaster loans to no more than $350,000 in 1965.⁸

SBA disaster loan limits first appeared in the Code of Federal Regulations (C.F.R.) in 1968. Prior to that, the C.F.R. indicated that "there is no statutory limitation on the amount of a disaster loan"⁹ and, as mentioned, SBA announced its disaster loan limits through notices published in the Federal Register. In this 1968 C.F.R. reference, SBA revised paragraph (a) of 13 C.F.R. §123.6, in part, by setting limits on business disaster loans at $100,000 for any one disaster (except for an additional amount to refinance any prior SBA disaster loan), personal property loans at $10,000, and real property loans at $20,000.¹⁰ In 1970, the SBA increased the limit for business disaster loans to $500,000 and the limit for real property loans to $50,000. The SBA did not change the limit for personal property loans ($10,000).¹¹ The SBA did not provide a rationale for establishing the 1968 and 1970 disaster loan limits, or why those particular dollar amounts were selected.

In 1980, disaster loan limits were first placed in statute (P.L. 96-302).¹² Section 119(a) of P.L. 96-302 amended Section 7(c) of the Small Business Act by adding a new paragraph:

Provided further, that no loan under subsection (b)(1) shall be made, either directly or in cooperation with banks or other lending institutions through agreements to participate on an immediate or deferred basis, if the total amount outstanding and committed to the borrower under such subsection would exceed $500,000 for each disaster, unless an applicant constitutes a major source of employment in an area suffering a disaster, in which case the Administration, in its discretion, may waive the $500,000 limitation.¹³

Congress did not provide a rationale for placing the limit in statute, or why $500,000 was selected as the limit.¹⁴

It appears that businesses—not individuals and households—became eligible for the $500,000 limit established in P.L. 96-302. Instead, individuals and households continued to be eligible for the maximum amount established in the 1970 revised federal regulation: $50,000 for real property disaster loans, and $10,000 for personal property loans.¹⁵

Starting in the 1980s, SBA commonly made businesses eligible for the full amount established in statute and individuals and households eligible for a lesser amount by regulation. The Small Business Act authorizes SBA to set limits for home loans in regulation so long as they do not exceed limits established in statute by Congress. Under the Small Business Act, "no loan[s] ... shall be made ... [that] exceed $500,000." Thus, home disaster loans remained capped at the amount established in 1970 despite the statutory loan limit increase in 1980 (P.L. 96-302).

In 1984, SBA increased the limits for real property disaster loans to $100,000 and personal property loans to $20,000 in federal regulation. SBA disaster loan limits for business disaster loans remained at the maximum amount established in P.L. 96-302 ($500,000).

In 1993, without specific explanation, Congress tripled the limit on disaster loans in statute (P.L. 103-75) from $500,000 to $1.5 million.¹⁶

Following the Northridge earthquake in California in 1994, SBA increased personal property disaster loans from $20,000 to $40,000 and real property disaster loans from $100,000 to $200,000 in regulation.¹⁷ According to SBA, the maximum loan amount was increased because previous loan amounts were insufficient to meet the needs of "homeowners and renters confronted by the effects of physical disasters by virtue of the impact of economic inflation."¹⁸ SBA further stated that the previous maximum loan amounts were

inadequate to compensate many disaster victims for the costs associated with rebuilding, replacing and repairing residential, real property and household effects such as clothing, furniture and appliances which have been lost or damaged as a result of a physical disaster. Moreover, in the aftermath of disasters, especially large catastrophes, construction costs often increase sharply.¹⁹

Generally, regulatory changes are made after issuing a public notice. However, in this instance, SBA stated that the new maximum loan amount was established without public notice in an effort to meet immediate disaster loan demand caused by the earthquake. According to SBA, 13 C.F.R. §123.1(b)

authorizes emergency changes in the regulations governing its disaster assistance program, and 5 U.S.C. 553(b)(B) which permits publication of regulations in final form without notice of comment when an agency finds that good cause exists for publication in final form on an emergency basis, and that notice and comment is impracticable, unnecessary or contrary to the public interest. In this regard, the public interest in seeing to it that the new limitations are effective as to the recent California earthquake disaster makes the utilization of notice and comment rulemaking impracticable.²⁰

In 2008, Section 12078 of the Food, Conservation, and Energy Act of 2008 (P.L. 110-246) amended the Small Business Act to make the disaster assistance program more accessible to disaster victims, including by raising the statutory loan limit for disaster loans from $1.5 million to $2 million and authorizing the SBA Administrator to "increase the aggregate loan amount ... for loans relating to a disaster to a level established by the Administrator, based on appropriate economic indicators for the region in which that disaster occurred.''²¹ While SBA revised the C.F.R. to make businesses eligible for the full amount, SBA did not revise disaster loan limits for home disaster loans in regulation and limits for home disaster loans remained the same as those established in 1994 by regulation ($40,000 for personal property disaster loans and $200,000 for real property disaster loans). Section 12078 of the Food, Conservation, and Energy Act of 2008 has been the most recent adjustment to disaster loan limits in statute. Figure 1 provides a list of regulatory and legislative disaster loan limit developments.

In May 2020, SBA lowered the maximum loan amount for Economic Injury Disaster Loans (EIDL) for Coronavirus Disease 2019 (COVID-19) relief to $150,000 due to unprecedented demand for limited loan resources.²² The maximum loan amount was raised again as the SBA Disaster Loan Account was replenished with supplemental funding (see Table 1). In March 2021, SBA announced an increase in the maximum amount for COVID-19 EIDL relief from $150,000 to $500,000.²³ In September 2021, SBA raised the maximum amount to $2 million.²⁴

In June 2023, SBA raised the maximum loan amount for personal property disaster loans to $100,000, and real property disaster loans to $500,000 (see Figure 1).²⁵

Figure 1. Regulatory and Statutory History of Disaster Loan Limits

Source: CRS interpretation of regulatory and statutory adjustments to disaster loan limits.

Contextualizing SBA Disaster Loan Limits

One challenging aspect of establishing disaster loan limits is the lack of consensus on a model or formula for determining disaster recovery rebuilding and repair costs. Establishing an appropriate disaster loan limit is difficult for a variety of reasons, including (1) demolition, labor, construction, and material costs vary by region and fluctuate over time; (2) variation between states and regions with respect to median home costs and prices, building permits, and codes; and (3) "normal" reconstruction costs may be of limited value to establish disaster reconstruction costs because disasters can deplete labor and/or material in an area, which may lead to increased labor and material costs.

An additional consideration associated with developing disaster loan limits is whether the current loan limits are restrictive to individuals and households residing in areas with higher property prices and values.

The following sections help frame these issues by examining a range of factors Congress might consider in evaluating disaster loan limits.

Inflation

Inflation, or the general rise in prices of goods and services in the economy, is an important indicator of purchasing power over time, or the value of a dollar. One tool used to measure inflation, the CPI, covers prices for consumer goods and services typically purchased by households, and is often used to adjust household incomes for inflation.

Figure 2 shows the CPI from 1994, when personal and real property disaster loan limits were last updated, to 2023. The CPI grew from about 148 in 1994 to just over 304 in 2023 (note that CPI values fluctuate from month to month), which can be expressed as a growth rate of 106%. In 2008, when the business disaster loan limit was last revised, the CPI was 215, representing 42% growth from 2008 to 2023.

Figure 2. Consumer Price Index Change 1994-2023

Source: U.S. Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers, https://www.bls.gov/cpi/data.htm. Notes: Data represent annual averages of monthly values.

Construction Costs

SBA home and business physical disaster loans are used to fund reconstruction projects to repair and replace primary residences and businesses. Figure 3 shows how construction costs have risen since 1994, based on a well-known construction cost index (CCI) used by the construction industry to estimate project costs and prepare bids. The index takes into account the costs of both construction materials and labor, which vary by market (geographic area) and type of construction (e.g., commercial or residential building; wood-frame or steel-frame structure).²⁶

According to the index, construction cost increases began to accelerate in 2004, during the years leading up to the 2008 financial crisis, with the largest year-to-year increases occurring between 2020 and 2022. From 1994 to 2023, the CCI grew by 147%, and from 2008 to 2023, it grew by 61%.

Figure 3. U.S. Construction Cost Change 1994-2023

Source: Engineering News-Record (ENR), Construction Cost Index History, https://www.enr.com/economics/historical_indices. Notes: Data represent annual averages of monthly values.

The data provided in Figure 3 may not be analogous to reconstruction costs after a disaster. As mentioned, disasters potentially stress the availability of labor, local resources, and materials which may compound reconstruction costs after a disaster takes place.

The graph in Figure 4 plots the CPI along with the CCI, to show the difference between the rise of the cost of a general basket of goods and services and construction costs. In 2013, the CCI eclipsed the CPI and has remained higher.

Figure 4. Consumer Price and Construction Cost Comparison 1994-2023

Source: Bureau of Labor Statistics, Consumer Price Index for All Urban Consumers, https://www.bls.gov/cpi/data.htm; Engineering News-Record (ENR), Construction Cost Index History, https://www.enr.com/economics/historical_indices. Notes: Data represent annual averages of monthly values.

Median Home Prices and Values

Another factor that may be considered when contemplating maximum loan amounts for SBA disaster loans are home costs. The following sections examine home prices and values, including how they have changed over time.

Home Prices

The Federal Reserve Bank of St. Louis indicates that the median sales price for a used home in the United States was $130,000 in 1994. Since then, median home sales prices have steadily increased to $212,700 in 2004, peaking at $457,475 in 2022, and then dropping to $426,525 in 2023 (see Figure 5).

Figure 5. Median Sales Price for Used Homes in the United States 1994-2023

Source: Derived from Federal Reserve Bank of St. Louis, Median Sales Price of Houses Sold for the United States, https://fred.stlouisfed.org/series/MSPUS#0. Note: The current SBA Real Property Disaster Loan limit is $200,000.

Home Values

Some datasets assess homes by value rather than price. Value is generally considered what homes with similar features and in similar condition might be sold for in a given area. Based on U.S. Census Bureau data, the median home value in 2022 was $354,100. Half of states in the United States (including Washington, DC) had median values above the $315,000 range (see Figure 6).

Figure 6. Financial Characteristics for Housing Units with a Mortgage, 2022 Median Home Values

Source: U.S. Census Bureau, S2506, Financial Characteristics for Housing Units with a Mortgage, 2022, https://data.census.gov/table/ACSST1Y2022.S2506?q=S2506&g=010XX00US$0400000&y=2022.

Some may object to the use of home prices and values to determine appropriate home disaster loan limits. Home sale prices, they might argue, cannot be compared to repair and rebuilding costs. For one, not all home disaster loans are for completely destroyed homes. Rather, most are for making structural repairs (such as replacing a roof). Similarly, some may question the use of median home values as a tool for determining loan caps. Homes in California and Washington, DC, for example, have higher values, in part, because of their location. According to this line of thinking, property values remain high in those areas even if the homes are destroyed. Disaster loans, it could be argued, should be used to repair and replace the structure, not replace the property. It could be further argued that people living in high-cost areas have higher incomes and are therefore more capable of purchasing insurance.

Others might argue that federal disaster assistance is intended to supplement, not replace private insurance. It could be further argued that increasing disaster loan limits induces moral hazard if homeowners believe the limit is high enough to make them whole again after the incident. If that is the case, some homeowners may decide not to not to insure (or decide to underinsure) their property.²⁷

Variations in State and County Home Costs

Throughout the United States, there are counties that have median home costs that are significantly higher than the rest of the nation. For example, a major disaster declaration issued for the Camp Fire in California made home disaster loans available to individuals and households residing in Butte, Los Angeles, and Ventura counties.²⁸ The median owner occupied home values for those counties in 2020 were well above the national median of $251,700 at the time at $304,700, $615,500, and $609,200, respectively.²⁹ In another example, in some Florida counties with a history of hurricane damages—Collier and Monroe counties—also have median owner occupied home values well above the national median ($443,700 and $696,900 from 2018 and 2022, respectively).³⁰

Personal Property, Home Furnishings, and Vehicles

SBA personal property loans may be used to repair or replace clothing, furniture, cars, or appliances damaged or destroyed in the disaster. The following section examines the cost of furnishings and vehicles in the United States.

According to economic data published by the Federal Reserve Bank of St. Louis, from 2010 to 2023, prices for household furnishings and supplies increased 9.7% (see Figure 7).³¹ From 1994 to 2023 new vehicle prices increased 30.03%, and used cars and trucks increased 34.96% (see Figure 8). The data may suggest to some that the $100,000 disaster loan limit may not presently be sufficient to replace vehicles, home furnishings, and supplies. Others may disagree and argue that, while some household costs have increased, others have decreased. According to the Federal Reserve Bank of St. Louis:

It is natural to complain that some prices increase. But ... prices can also decrease. While there are obvious seasonal fluctuations for some goods (say, agricultural products), other goods have been declining year over year, contributing to a general price inflation that is lower than one may think. [A] prime example is anything related to information technology.... IT devices with a given set of characteristics have continuously fallen in price. Or, to put it differently, a device of the same price year after year will provide much better performance; its price by "unit of performance" must therefore be declining.³²

Figure 7. Consumer Price Index for All Urban Consumers: Household Furnishings and Supplies in the United States

Source: Federal Reserve Bank of St. Louis, Consumer Price Index for All Urban Consumers: Household Furnishings and Supplies in U.S. City Average, May 2024, https://fred.stlouisfed.org/series/CUUS0000SAH31.

Figure 8. Consumer Price Index for All Urban Consumers: New Vehicles; Used Cars and Trucks in the United States

Source: Federal Reserve Bank of St. Louis, Consumer Price Index for All Urban Consumers: Used Cars and Trucks in U.S. City Average, May 2024, https://fred.stlouisfed.org/series/CUSR0000SETA02; and Federal Reserve Bank of St. Louis, Consumer Price Index for All Urban Consumers: New Vehicles in U.S. City Average, May 2024, https://fred.stlouisfed.org/series/CUUR0000SETA01.

Policy Options

The following sections describe policy options that Congress may consider when contemplating disaster limits, including formulas and the establishment of disaster limit floors.

Disaster Loan Limit Formulas

Rather than periodically adjusting disaster loan limits, Congress could require SBA to set disaster loan limits by formula, incorporating measures such as CPI, PPI, inflation, economic indicators, and/or home values and prices. SBA applies a similar formula-based model to determine disaster loan interest rates for individuals and households that are unable to secure a disaster loan through a private lender:

the rate prescribed by the [SBA] Administration but not more than one-half the rate determined by the Secretary of the Treasury taking into consideration the current average market yield on outstanding marketable obligations of the United States with remaining periods to maturity comparable to the average maturities of such loan plus an additional charge of not to exceed 1 per centum per annum as determined by the Administrator, and adjusted to the nearest one-eighth of 1 per centum, but not to exceed 4 per centum per annum.³³

A disaster loan limit formula could be applied nationwide, or regionally for areas with higher housing costs.

Disaster Loan Limit Floors

As described in "Historical Developments," SBA lowered disaster limits for COVID-19 EIDL assistance in 2020 from $2 million per loan to $150,000 to meet COVID-19 EIDL demand. According to the SBA Office of Inspector General, SBA "approved and disbursed more loans for COVID-19 relief than for all other disasters combined in the agency's history."³⁴ As mentioned previously, the Small Business Act authorizes SBA to set disaster loan limits so long as they do not exceed the loan limits established in statute. The absence of a statutory floor allowed SBA to temporarily reduce the loan limit so that it could continue to provide COVID-19 EIDL assistance to struggling businesses. While the SBA's decision to lower loan limits may have helped the agency meet high levels of demand, some were concerned the amount was insufficient to meet the economic recovery needs of businesses.³⁵

It may be argued that the factors that led to SBA's decision to lower the loan limit were extraordinary and unprecedented. Historically, SBA has never had to lower limits to meet loan demand for natural disasters such as hurricanes or floods. Still, there may now be some concern that SBA might reduce loan limits in the future if the SBA Disaster Loan Account runs low on funding.³⁶ If so, some homeowners and/or businesses may not be able to make a full recovery from the incident. Against this concern it might be argued that SBA should be allowed to lower loan limits to meet loan demand if needed. According to this line of thought, the lower limit would allow SBA to provide as many disaster loans as possible, which is seen as better than denying loan applications on the basis of inadequate funding. To summarize, on the one hand, establishing floors would prevent SBA from lowering limits to an amount Congress believes is too low. On the other hand, floors could limit the number of loans that can be serviced if loan demand is high.

SBA Disaster Loan Account Report

The SBA Disaster Loan Program is funded through the SBA Disaster Loan Account. The SBA Disaster Loan Account is a "no year" account, meaning that funding does not lapse at the end of the fiscal year. Rather, any remaining funds are rolled over to the next fiscal year. In addition to rolled over funds (if available), the SBA Disaster Loan Account may receive annual appropriations, revenue from disaster loan payments (including interest on the loans), and supplemental appropriations.³⁷

Appropriations for disaster loan administration and servicing (including disaster loan credit subsidies to account for loan defaults), and disaster loan revenues (loan payments and default collateral recoveries) replenish the SBA Disaster Loan Account. As funding comes into the account, SBA disaster loans are paid as installments. Each dollar of disaster loan credit subsidy supports about seven dollars in disaster lending authority.

Congress has provided supplemental funding for the SBA Disaster Loan Account when the balance of the account becomes low (see Table 1). At times, however, there has been some confusion about the remaining balance in the SBA Disaster Loan Account.

Congress has required disaster funding reports from other agencies to delineate funding activities and estimate the date on which the funds may be exhausted. For example, after Hurricane Katrina, Congress required the Federal Emergency Management Agency (FEMA) to issue funding reports on the Disaster Relief Fund (DRF).³⁸ The DRF is "an appropriation against which FEMA can direct, coordinate, manage, and fund eligible response and recovery efforts associated with domestic major disasters and emergencies that overwhelm State resources pursuant to the Robert T. Stafford Disaster Relief and Emergency Assistance Act."³⁹ DRF monthly reports help Congress track disaster relief funding activities and determine how much funding is available for current and future incidents. The SBA could be required to issue a similar report on the Disaster Loan Account. The report could include information such as the account balance, available lending authority, monthly revenues, and cost and exhausted funding projections.

Concluding Observations

SBA disaster loan limits have been placed in statute and created by SBA regulatory action. Historically, businesses have been eligible for the maximum amount set in statute whereas homeowners have been eligible for a lesser amount than has been set in statute. To some, this has been an effective approach to (1) supplement, as opposed to replace, private insurance, (2) avoid moral hazard, and (3) balance the desire to help disaster victims with the need for prudent federal spending.

Others may be concerned that SBA regulatory action has not been timely. As mentioned previously, from 1994 to 2023, disaster home loan limits were not adjusted for two decades (from 1993 to 2023). During that time inflation, building costs, and median home values and prices increased and some homeowners may not have been capable of fully recovering from a disaster because their disaster loans covered too small a share of their repair and rebuilding costs. There may also be concern that SBA may reduce disaster loan limits to an amount lower than an amount that is acceptable to Congress. On the one hand, a lack of a disaster loan floor provides SBA with the flexibility to meet loan demand in unpresented situations such as COVID-19. On the other hand, the lower limit imposed by SBA in such cases may not provide enough for businesses to get by on until they can resume normal business operations. If these or other issues related to disaster loan limits are a concern, Congress could consider taking measures to ensure disaster loans are not prohibitively low.

Appendix. SBA Disaster Loan Categories

The following provides a brief overview of each SBA disaster loan category, including eligible recovery activities and loan terms.

Personal Property Disaster Loans

Personal Property Disaster Loans cover only uninsured or underinsured property and primary residences in a declared disaster area. Personal Property Disaster Loans can be used to repair or replace clothing, furniture, cars, or appliances damaged or destroyed in the disaster. Interest rate ceilings for Personal Property Disaster Loans are statutorily set at 8% per annum or 4% per annum if the applicant is unable to obtain credit elsewhere.⁴⁰ The loans can have maturities up to 30 years. The maximum loan amount for a Personal Property Disaster Loan is set in regulation at $100,000.⁴¹

Real Property Disaster Loans

Real Property Disaster Loans provide creditworthy homeowners located in a declared disaster area with up to $500,000 to repair or restore the homeowner's primary residence to its pre-disaster condition. Only uninsured or otherwise uncompensated disaster losses are eligible for loan assistance. The loans may not be used to upgrade a home or build additions to the home, unless the upgrade or addition is required by city or county building codes. Secondary homes or vacation properties are not eligible for Real Property Disaster Loans.⁴² Limits for Real Property Disaster Loans are set in regulation.⁴³

Business Physical Disaster Loans

Business Physical Disaster Loans are available to almost any business located in a declared disaster area.⁴⁴ Business Physical Disaster Loans can be used to repair or replace damaged physical property—including machinery, equipment, fixtures, inventory, and leasehold improvements—that are not covered by insurance. Interest rates for Business Physical Disaster Loans cannot exceed 8% per annum or 4% per annum if the business cannot obtain credit elsewhere.⁴⁵ Business Physical Disaster Loans can have maturities up to 30 years. The maximum loan amount provided for a Business Physical Disaster Loan is $2 million.⁴⁶

Economic Injury Disaster Loans

EIDLs are available to businesses located in a declared disaster area that have suffered substantial economic injury, are unable to obtain credit elsewhere, and are defined as small by SBA size regulations.⁴⁷ Small agricultural cooperatives and most private and nonprofit organizations that have suffered substantial economic injury as the result of a declared disaster are also eligible for EIDLs. The loans are designed to help businesses meet financial obligations and operating expenses that could have been met had the disaster not occurred. The loan proceeds can only be used for working capital necessary to enable the business or organization to alleviate the specific economic injury and to resume normal operations. The interest rate ceilings for EIDL are statutorily set at 4% per annum or less and the loans can have maturities up to 30 years.⁴⁸ The maximum loan amount for EIDL is $2 million.⁴⁹