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September 27, 2017

Best Practices: Keeping Your Employees Current On SBA Requirements

by Janet M. Dery

A successful SBA lender will insure that its employees who deal with SBA loans, whether daily or just occasionally, are well trained in SBA requirements, processes, and procedures. Knowing where to turn for training and how to find relevant information is key to staying in good standing with SBA and protecting SBA loan guarantees.

Training can be handled either internally or through organizations that offer specialized SBA loan training. Some organizations that handle such training include the National Association of Government Guaranteed Lenders (NAGGL) and the National Association of Development Companies (NADCO). SBA District Offices are another great resource for training.

The current version of SBA’s Standard Operating Procedure (SOP) for Lender and Development Company Loan Programs (SOP 50 10 (5)(I) issued January 1, 2017) should be available to employees who handle eligibility and loan closings, and the SOP for 7(a) Loan Servicing and Liquidating (50 57 (2) issued December 1, 2015) and the Servicing and Liquidation Actions 7(a) Lender Matrix should be available to employees who handle servicing, workout and foreclosure. To be sure that employees have the most recent versions of the SOPs and Matrix, lenders should regularly check the SBA’s lender website, where they can access the most recent versions of the SOPs and Matrix, as well as find other SBA forms and guidance on SBA lending policies and procedures.

However, just reviewing the SOPs and the Matrix is not enough to keep up to date with the 7(a) and 504 loan programs. To stay as current as possible, employees should have access to all notices issued by the SBA throughout the year. Information Notices are the most common notices issued by the SBA. These notices alert the lending community about fee changes, SBA form revisions, and reminders about items such as SBA Form 1502 reporting requirements. Policy Notices alert the lending community about changes in the SBA’s policies. For example, in 2017 Policy Notices have been issued to advise about: (i) the revised risk-based review/examination protocol for SBA supervised lenders, and (ii) changes to the franchise review process for 7(a) and 504 loans. Procedure Notices alert the lending community about changes to procedures used by lenders (i.e. requirement for CDCs to submit all 504 applications through ETRAN beginning June 30, 2017). Occasionally, there are Federal Register notices, advising about proposed changes to the Code of Federal Regulations, which are the statutory rules that govern SBA lending.

One method for finding these notices is to go to the SBA’s lender’s website, locate “Find Forms, SOPs, Notices and More”, choose looking for a Lender Notice, click here. Alternatively, sign up for email notifications from the SBA. On the SBA’s lender’s website there is a box on the top right labeled “Subscribe to E-mail Updates.”

Training and keeping employees informed of SBA’s current policies and procedures is an important part of a successful SBA lending program. For more about SBA loan training, and staying informed on SBA’s policies and procedures, please contact Janet at jdery@starfieldsmith.com or at 267-470-1189.