Westmoor Country Club, a private golf and social club in Brookfield, Wisconsin, agreed on December 15, 2025 to pay $1.25 million to resolve federal allegations that it should never have received a Paycheck Protection Program loan. The Westmoor Country Club PPP settlement, announced by the U.S. Attorney’s Office for the Eastern District of Wisconsin, closes a case built on a simple premise: private clubs that limit membership for reasons other than capacity were categorically ineligible for PPP funds.1Milwaukee Journal Sentinel. Brookfield Golf Club to Pay $1.2M for Improperly Obtained PPP Loan
The Loan and Why the Government Said It Wasn’t Allowed
Westmoor received a PPP loan of $755,471 in March 2021. The SBA forgave the loan in late July of the same year.2Lake Country Tribune. Brookfield Country Club Settles Over Improper PPP Loan
The problem, according to prosecutors, was structural. Westmoor is a 501(c)(7) social and recreational club, a tax-exempt designation it has held since 1936, and its membership is by invitation only across active golf, intermediate golf, and social-swim-tennis tiers.3ProPublica. Westmoor Country Club Nonprofit Filing4Westmoor Country Club. Membership Categories SBA regulations excluded private clubs from PPP eligibility, and the U.S. Attorney’s Office alleged that when Westmoor applied for the loan and later for forgiveness, it “limited its membership for reasons other than capacity,” making it ineligible from the start.5BizTimes Milwaukee. Westmoor Country Club Will Pay $1.25 Million Settlement Related to PPP Loan Borrowers had to self-certify eligibility when they applied.
What the Settlement Does
The $1.25 million payment is roughly 1.65 times the original loan, in line with the multiplier the Department of Justice has applied in comparable PPP enforcement actions. Westmoor does not admit liability under the agreement, and no court made a formal determination on the allegations.5BizTimes Milwaukee. Westmoor Country Club Will Pay $1.25 Million Settlement Related to PPP Loan
Why Forgiveness Didn’t End the Matter
SBA forgiveness of a PPP loan generally validates how the money was spent, not whether the borrower was ever eligible to receive it. That distinction is why Westmoor’s 2021 forgiveness did not shield the club from a later False Claims Act inquiry.
Many of these cases have started outside the government. The False Claims Act’s qui tam provisions let private individuals sue on behalf of the United States and collect a share of any recovery, and serial relators have mined publicly available SBA loan data to flag borrowers that appear to have been ineligible. The DOJ can then elect to join the resulting suits.
Where Westmoor Fits in the Country Club PPP Crackdown
The Westmoor settlement is one of a growing set of DOJ actions against private clubs that took PPP money. In June 2024, four nonprofits including two California country clubs paid a combined $5.8 million to settle similar False Claims Act allegations. Glendora Country Club paid roughly $709,000 on a $471,685 loan, and The Palms Golf Club paid about $690,000 on a $327,000 loan.6DOJ. Nonprofit Organizations Pay Over $5.8 Million to Resolve Allegations of Fraudulently Obtaining PPP Loans
In August 2025, the members-only Core Club in New York settled for $360,000, with a conditional judgment of more than $8.1 million enforceable if the payments failed; those defendants admitted responsibility for the conduct alleged.7SBA. U.S. Attorney Announces Settlement With Members-Only Social Club for COVID Relief Fraud In April 2026, Maryland’s Woodholme Country Club agreed to pay over $1 million to resolve allegations that it certified eligibility for a $695,000 PPP loan despite being an ineligible 501(c)(7) organization.8DOJ. Maryland Country Club Agrees to Pay Over $1 Million to Resolve False Claims Act Allegations
The pattern across these cases is consistent. A 501(c)(7) club certifies eligibility, receives funds, obtains forgiveness, and years later pays the government a multiple of the loan to close out a False Claims Act matter.