Best Practices: Debt Refinance Requirements Under SOP 50 10 7
https://starfieldsmith.com/wp-content/uploads/2023/07/24badeb5-fe02-45e2-adb6-1d707f7ae31c.mp3 As we approach August 1, 2023, the effective date of the new SOP 50 10 7, the SBA lending community continues to digest and analyze the changes from the previous SOP 50 10 6. One portion of SOP 50 10 7 that saw significant changes is the debt refinance requirements. The following types of ... Read More
Best Practices: Insurance Requirement Changes for SBA 7(a) Loans
https://starfieldsmith.com/wp-content/uploads/2023/07/ccfe1e25-db60-4b39-9d10-9c786d7c391d.mp3 Hazard insurance requirements for SBA 7(a) loans were updated in SBA Procedural Notice No. 5000-846607, which went into effect on May 11, 2023. The changes to Hazard insurance, along with changes to flood insurance requirements for SBA 7(a) loans are being updated under SOP 5010(7), which takes effect August 1, 2023. Hazard insurance requirements ... Read More
Best Practices: Partial Changes of Ownership on SBA Loans
https://starfieldsmith.com/wp-content/uploads/2023/07/d7183016-f7a6-4bfa-bdfa-42c14f92e6f3.mp3 On May 9, 2023, the SBA issued Procedural Notice 5000-846607 (“SBA Notice”) which addresses the implementation of SBA’s Final Rule on Affiliation and Lending Criteria for the SBA Business Loan Programs effective May 11, 2023 (88 FR 21074) (“New Rules”). The SBA Notice revises the guidelines in the SOP 50 10 6 pertaining to ... Read More
Best Practices: Collateral Requirement Changes for 7(a) Loans
https://starfieldsmith.com/wp-content/uploads/2023/06/77149cdd-e606-40bf-ad66-5a280cf3221d.mp3 Collateral requirements for Standard 7(a) Loans (those greater than $500,00) and 7(a) Small Loans (those under $500,000) will be updated under the new SOP. For 7(a) Small Loans, the collateral requirements were largely already based on the “do what you do,” concept prior to issuance of the new rules. Two significant changes in the ... Read More
Best Practices: Credit Not Available Elsewhere
https://starfieldsmith.com/wp-content/uploads/2023/06/ee50fc56-96bd-4aa0-90d0-6e4b4b899732.mp3 One of SBA’s core requirements for all 7(a) and 504 loans is to verify and document the unavailability of credit on reasonable terms from non-federal, non-state, and non-local government sources, thereby necessitating the need for SBA-guaranteed financing. See 15 USC 636(a)(1)(A) and 13 CFR § 120.101. SBA’s SOP 50 10 7 (“SOP”), effective August ... Read More
Best Practices: Updates to Equity Injection Guidelines
https://starfieldsmith.com/wp-content/uploads/2023/06/99220fca-82e8-4eec-ae94-099a9da6b368.mp3 On May 9, 2023, the SBA issued Procedural Notice 5000-846607 (“SBA Notice”) that revised the guidelines in the SOP 50 10 6 pertaining to equity injection requirements. These changes are also reflected in the SOP 50 10 7, which will go into effect August 1, 2023. The SBA Notice removed the requirement that certain ... Read More
