More yikes: SBA has made it clear that they’re relying on the Lender to follow their own policies and procedures. (Yes, they’re looking at you, Lender.) Basically, they’re saying “Go forth! Do what you do!”
What does that mean? It means your policies and procedures, not just for SBA but for your similarly sized non-SBA loans, had better be robust enough to live up to this challenge. Especially since they haven’t yet indicated how they’ll be auditing or monitoring Lenders for compliance.
Here are our recommendations to make sure you’re prepared.
1. Review your policies and procedures in light of these new SOPs, making sure you
cover previously existing requirements as well as the new updates.
2. Make sure that as you update your policies and procedures, you also update your
checklists and forms.
3. When in doubt – follow industry best practices. (Not sure what those are? Reach
out to us; we can help!)
4. SBA is taking on the core eligibility requirement screening. However, we
recommend that you continue to do this yourself, to ensure that ETran entry and the SBA approval process proceed smoothly. Otherwise, you’ll find yourself having to redo work when SBA finds problems.
5. Practice patience. And then practice it some more. The ETran approval process
has new Hold Codes, similar to what we saw with PPP. And as we all know all too well, new processes require time to adjust and to iron out the kinks.
And please, always remember to breathe. Change isn't easy, and it’s necessary for growth – and for a successful SBA lending program!
Want some help? We’re deep in the details of these new SOPs, and we can help you sort out what they mean for you, and help you update policies, procedures, checklists, and forms. Give us a call at 877.576.0819, or click here to use our email contact form.