Quick SBA Compliance Tips from NAGGL 2025

As always, NAGGL was a whirlwind of meetings, workshops, information, and saying Hello! to new and old friends. We’ll be writing more about what we learned in the coming weeks – and to start with, here are a few quick tips.

SOPs and forms and check boxes, oh my!

• The original version of SBA SOP 50 10 8 is out of date. Be sure you’re using the version with Technical Updates as well as all subsequent Notices.
  

• Many of you are using your own version of Form 413 – but have you reviewed the updated Personal Financial Statement versus your version to ensure you’ve included all the required verbiage?
  

• On the same subject: several other SBA documents allow Lenders to use their own version. But you must make sure all SBA-required elements are present, or you risk delays and screen-outs. 
  

• Remember that the small loan limit for SBA 7(a) loans has decreased to $350M. However, the SBA express loan limit remains at $500M.
  

• Credit not available elsewhere? Beware of check boxes! If credit isn’t available elsewhere, you must now include a written narrative explaining why. Per SOP 50 10 8, “The SBA Lender must include in its credit memorandum the specific reasons why the Applicant does not meet conventional loan policy requirements, along with relevant supporting documentation.”

Exceptions – or not!

• SBA has been receiving many more requests for exceptions since they created a new email box for Lenders to ask questions. Not surprising, perhaps, but definitely a case of unintended consequences on SBA’s part, as this was never the intent of the new email box! So be careful and thorough if you need to request an exception, and provide ample reason, in SBA’s opinion, of why the exception would be appropriate.
  

• There are no exceptions or waivers for Business Personal Property insurance when the loan is over $50,000 and the assets are taken as collateral. The assets must be insured, period.

Fun with Form 1919

• All Applicants should complete a separate certification that includes citizenship status, using a template drafted by the Lender. This ensures support for the certifications made on Form 1919 by the Authorized Signer for the business.
  

• And that Authorized Signer of Form 1919 should be made fully aware of what they’re certifying!
  

• 100% of ownership, as documented on Form 1919, must be entered into ETran.

Finally, some new certifications require Lenders to create a certification template, since SBA is still working through updating their documents. These change on a regular basis, so, rather than risk out-of-date information, we recommend careful due diligence!

Of course, you can always reach out to us – as your friendly Lender Service Provider, we’re here to help with all of this and more, ensuring you stay in full SBA compliance. Give us a call at 877-576-0819, or drop us a note here.