Third Party Lenders participating in the SBA’s 504 Loan Program should become familiar with new, specific matters that must be included in a CDC’s financial analysis of the borrower and documented in the CDC’s credit memorandum, for all loans made during the COVID-19 emergency through at least December 31, 2020. In SBA Procedural Notice 5000-20040, effective July 28, 2020, the SBA requires the CDCs to perform an additional financial analysis of the borrower’s ability to repay the loan in light of the ongoing pandemic. These new requirements address the adverse impact the COVID-19 emergency may have had on the operations of small business borrowers and the resulting negative effect on their cash flow and corresponding ability to repay the loan.
As with the 7(a) loan program, the cash flow of the borrower is the primary source of repayment for 504 loans. Regardless of available collateral, if a prospective borrower lacks a reasonable ability to make loan payments in a timely manner from the cash flow of the business, the 504 loan request should be declined. The SBA has enumerated eight COVID-specific criteria that must be addressed in the CDC’s credit memorandum, as follows:
With the adoption of the 25 year debentures, the volume of SBA 504 loans has increased significantly. Concurrent with the increase in loan volume, and the significant impact the COVID-19 emergency has had on the operations and personnel of all government agencies, has come an understandable delay in processing periods by the Sacramento Loan Processing Center. By partnering with CDCs in addressing the SBA’s new requirements proactively, Third Party Lenders can help avoid unnecessary delays caused by screen outs requesting the missing information. For questions regarding SBA 504 loan originations during COVID-19, please contact the attorneys at Starfield & Smith at 215-542-7070.
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