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About Victor A. Diaz

Best Practices: Recently Updated SBA Form 1919 Highlights Agency’s Continued Focus on 401(k) Plans

Effective November 3, 2020, the U.S. Small Business Administration (SBA) announced the update and release of SBA Form 1919, Borrower Information Form.  SBA Information Notice 5000-20059.  Among other things, the…
  • November 18, 2020
  • Victor A. Diaz

Best Practices: Lenders Need to Work Closely with CDCs to Avoid 504 Loan Approval Delays

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…
  • August 5, 2020
  • Victor A. Diaz

Best Practices: Who is an Authorized Representative under the Paycheck Protection Program?

While the CARES Act, the First PPP Interim Final Rule and guidance issued by the U.S. Treasury and U.S. Small Business Administration repeatedly state that lenders may rely on representations…
  • April 15, 2020
  • Victor A. Diaz

Best Practices: Impact of the OIG’s Audit Report on SBA’s Oversight of High-Risk Lenders

On November 12, 2019, the SBA’s Office of the Inspector General (OIG) published a report on its Audit of SBA’s Oversight of High-Risk Lenders (Report).  While the Report is directed…
  • January 8, 2020
  • Victor A. Diaz

Best Practices: The Importance of Providing a Detailed Narrative in the Credit Memo When Documenting Credit Elsewhere

The importance of documenting one’s credit elsewhere (“CE”) analysis cannot be overstated. Arguably, no other provision of the Small Business Act has come under closer scrutiny.  This is understandable, given…
  • October 23, 2019
  • Victor A. Diaz

Best Practices: Untimely Notices of Commencement – Restoration of Priority in Florida

A Notice of Commencement recorded prior to your mortgage can wreak havoc on your construction loan.  In Florida, before any work can begin to improve real property, a Notice of…
  • August 28, 2019
  • Victor A. Diaz
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