After loan disbursement, SBA lenders are often asked by borrowers to subordinate the position of a lien securing an SBA loan. Lenders must consider these subordination requests in…
Although there is no extensive discussion in the SBA’s Standard Operating Procedure 50 10 7.1 (SOP) regarding borrower’s compliance with business license requirements, the SOP does make it…
What is the Beneficial Ownership Information (“BOI”) Reporting Rule? The Financial Crimes Enforcement Network (“FinCEN”) recently implemented significant changes in beneficial ownership reporting, for the purpose of combating…
Once a loan is purchased off the secondary market by SBA, lenders must proceed with liquidation before they can request a loan to be charged off. When liquidation…
As we continue highlighting updates to SBA loan programs, we now focus on Chapter 26 of SOP 50 57 3. This chapter covers the duty to report suspected…
Effective August 1, 2023, all SBA 7(a) loans (regardless of when they were originated) are subject to SBA’s SOP 50 57 3. The new SOP includes changes and…