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Best Practices: Underwriting and Documenting Working Capital Disbursements

SBA’s Office of Credit Risk Management continues to focus on the adequacy of lenders’ underwriting and documentation of working capital disbursements on their 7(a) loans. Lenders are required to thoroughly…
  • May 11, 2022
  • Ethan W. Smith

Best Practices: SBA Form 1050 and Other Disbursement Considerations for SBA 7(a) Loans

One common reason for SBA to issue a repair or denial of the SBA guaranty is a Lender’s failure to properly disburse an SBA loan in accordance with the use…
  • May 4, 2022
  • Katie O'Brien

Best Practices: Debt Refinance Documents Lenders Should Obtain

In a recent presentation by SBA on guaranty purchases and its 10 tab process, the Agency noted that lenders not infrequently provide inadequate documentation to support their debt refinancing “uses…
  • April 27, 2022
  • Janet M. Dery

Best Practices: The Federal Reserve’s Interest Rate Policies Require SBA 7(a) Lenders to Re-examine their Interest Rate Practices

On March 16, 2022, the Federal Reserve (“the Fed”) raised interest rates by 25 basis points (or “bps”) in an effort to tamp down inflationary pressures.  The Fed also indicated…
  • April 20, 2022
  • Allen Connor

Best Practices: Lender Liability for PPP Loan Fraud

As reported in an earlier edition of Best Practices, it has been estimated that at least 15% of all PPP loan disbursements have at least one indicia of fraud. Until…
  • April 13, 2022
  • Norman E. Greenspan

Best Practices: PPP Lender Portal FAQ Changes: Use of Setoff Rights

On March 3, 2022, through its PPP Lender Platform, SBA provided informal guidance to lenders on several issues, including whether lenders “should” consider offset as a remedy for borrowers who…
  • April 6, 2022
  • Jessica L. Conn
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