Best Practices: Recent Updates to SBA Form 1086 – Secondary Participation Guaranty Agreement
https://starfieldsmith.com/wp-content/uploads/2024/08/8e2bff5f-1c54-4fe2-b3dd-b2e72ecb2a14.mp3 An updated SBA Form 1086 – Secondary Participation Guaranty Agreement, which is used to sell the guaranteed portion of an SBA 7(a) loan in the secondary market, was issued effective August 1, 2024. SBA has stated that its intention is to streamline and update the Agreement to reflect recent SBA policy changes, and to ... Read More
Best Practices: Do What You Do… as Long as it is Prudent!
https://starfieldsmith.com/wp-content/uploads/2024/08/a6d26be2-da0e-4a32-a280-347b25a1d3e9.mp3 “Experience is what you get when you didn’t get what you wanted.” Randy Pausch, The Last Lecture Since August 1, 2023, SBA lenders have been instructed by the SBA to follow the “policies and procedures the Lender uses for its similarly-sized non-SBA guaranteed commercial loans” for 76 different SBA loan requirements. This new approach ... Read More
Best Practices: Leasing Requirements
https://starfieldsmith.com/wp-content/uploads/2024/08/f7403bbc-1bb6-4266-9bb6-ba4d5833e398.mp3 During the 7(a) Connect Quarterly Update call on July 9, 2024 the Office of Credit Risk Management (“OCRM”) demonstrated an example of how it reviews a specific loan program requirement when reviewing loan files. The example used was use of proceeds, occupancy and leasing requirements, and responsibilities when the borrower is leasing space. In ... Read More
Best Practices: Care and Preservation of Collateral Tabs
https://starfieldsmith.com/wp-content/uploads/2024/08/6d6198cb-fa6e-4f52-8a46-c61c7b366e93.mp3 There have been plenty of changes to SBA’s regulations over the past year, and lenders should be aware that these changes have not only been in the SOP’s. One of the other changes made by the SBA back in November 2023 was an update to the Care and Preservation of Collateral Tabs (the “CPC ... Read More
Best Practices: SBA 7(a) Working Capital Pilot Program: What You Need to Know
https://starfieldsmith.com/wp-content/uploads/2024/07/ef33fee2-dbba-4b36-a062-fb57ce368da2.mp3 The Small Business Administration (SBA) has launched its new 7(a) Working Capital Pilot (WCP) program, which will take effect on August 1, 2024. SBA published notice of the WCP in the Federal Register on July 15, 2024 at Federal Register :: 7(a) Working Capital Pilot Program and is accepting comments currently through August 14, ... Read More
Best Practices: Proceed with Caution: Applicant’s Certifications
https://starfieldsmith.com/wp-content/uploads/2024/07/92ed1333-36c4-40d9-9d4c-cc17d6d06379.mp3 SOP 50 10 7.1 provides several situations where SBA lenders can rely upon borrower certifications to determine loan eligibility and/or for loan approval purposes. Although this is a welcome change for SBA lenders, lenders should be cautious about replying upon these borrower certifications alone in making approval decisions and should continue to follow prudent ... Read More
