PLP Authority and How PLP Lenders Can Obtain SBA’s Guidance Under SOP 50 10 8

With the issuance of SOP 50 10 8, which became effective June 1, 2025, SBA 7a Lenders with delegated PLP authority have had to make some changes in how they process loans.  Prior to SOP 50 10 8, a lender with delegated PLP authority could choose to submit a loan to SBA through non-delegated general processing.  PLP Lenders would sometimes utilize non-delegated general processing if they had questions or concerns regarding the eligibility of a loan.  Under non-delegated general processing, SBA, rather than the lender, determines the eligibility of the loan.

Under SOP 50 10 8, PLP Lenders are required to process all 7(a) loans using their delegated PLP authority, except for two exceptions (in which PLP Lenders are permitted to submit the loan through non-delegated procedures):

1. When the loan will refinance the Lender’s same institution debt; and
2. For international trade loans, when the collateral securing the loan will not be in a first lien position

In place of submitting loans to SBA for general processing, SBA has created a new mailbox for PLP Lenders to submit questions regarding specific 7(a) loan files and to request exceptions to policy.  The email address for such correspondence is 7aDelegatedLoanApps@sba.gov. Consulting an SBA creditor lawyer can provide valuable guidance when PLP Lenders face complex eligibility questions or policy exception requests.

If a PLP Lender submits questions on a specific 7(a) loan application to 7aDelegatedLoanApps@sba.gov, the submission should include the names of the principals of the applicant, the address of the project (or applicant), and a summary of the facts and pertinent information in the application which gives rise to the question at issue, so that SBA can answer the Lender’s questions.  While an SBA employee will provide responses to specific questions, SBA will not review the entire file or review multiple attachments to the email.  SBA will send an email response to the Lender’s question.

Similarly, PLP Lenders who are requesting an exception to an SBA policy for a 7(a) loan application, should use 7aDelegatedLoanApps@sba.gov to submit the specific facts of the application, including names of the principals of the applicant, address of the project (or applicant) and a summary of the key facts and information in the application, along with a discussion of the policy for which the exception is being requested, as well as an explanation as to why SBA should grant an exception to policy.  Again, SBA will review a summary of the file, but SBA will not review the entire file or multiple attachments.  If SBA approves the exception, SBA will send an email to the Lender confirming SBA’s approval.

Whether it is SBA guidance or approval of an exception to policy, PLP Lenders should retain such email in their loan file and continue to process the 7(a) loan through their delegated authority.  Such approval email is specific to that 7(a) loan application and should not be relied on in the future for other 7(a) loan files.

The mailbox should only be used for PLP Lenders who have questions about specific 7(a) loan applications or are requesting an exception to policy for a specific application.  For all general questions on 7(a) loans, Lenders should continue to submit those requests to 7aQuestions@sba.gov.

It is important to note, that while the new mailbox for PLP Lenders will be a useful tool, PLP Lenders cannot rely on the mailbox for a full eligibility determination of the 7(a) loan application, as that responsibility still lies with the PLP Lender. An experienced SBA guaranty attorney can help lenders navigate SOP 50 10 8 changes while protecting their delegated authority and guaranty rights. For questions regarding SOP 50 10 8 or SBA eligibility determinations, contact the attorneys at Starfield & Smith at 215-542-7070 or email us at info@starfieldsmith.com.