• Rebecca Mendoza

The clock is ticking … don’t miss SBA’s deadlines!


Do you have a list of all the SBA deadlines for your Standard 7a and Small SBA 7a loans?


They’re essential to protect the guaranty, enhance your reputation as a competent SBA Lender, and for getting things done in a prudent and timely manner.


Here’s a handy list you can use to update your SBA lending processes and procedures.


Origination:


Personal Financial Statements – within 90 days of:

  • Submission of the application to SBA through ETran for GP loans.

  • Lender approval for PLP loans.

Applicant and seller business financials – within 120 days of:

  • Submission of the application to SBA through ETran for GP loans.

  • Lender approval for PLP loans.

Guaranty Fee – must be paid within:

  • 10 business days of approval for loans with short-term maturity.

  • 90 days of approval for loans with greater than 12-month maturity.

Servicing:


SBA Authorization submission to CAFS

  • Within 15 days of Final Disbursement

Form 159 submission to CAFS

  • Within two 1502 reporting cycles.

1502 Reports

  • Monthly by the due dates set by the FTA. Here’s the link for the 2022 Due Dates.

Credit Reporting

  • After the loan has been funded.

  • And then regularly throughout the life of the loan.

Deferments (see SOP 50 57 2 if longer deferment periods needed)

  • Once each month for three consecutive months for loans sold on the secondary market.

  • Six consecutive months for unsold loans.

Liquidations:


Semi-annual report

  • Twice a year. SBA sends these to the main contact for the Lender.

Environmental Reports

  • Within 180 calendar days of servicing/liquidation action.

Transfer to Liquidation Status

  • At the time the Note is accelerated.

Liquidation Plan for CLP loans

  • Within 30 business days of site visit.

Litigation Plan

  • Prior to taking any material legal action.

  • SBA approval is required for legal expenses exceeding $10,000 or non-routine litigation.

Guaranty Purchase Package

  • May be submitted if the loan is 60 or more days in default.

  • Must be submitted to SBA within 45 days when SBA purchases the loan from the secondary market.

  • Must be submitted within 180 days after maturity date, or upon completion of liquidation on a matured loan.

TIP: Verify that the SBA Maturity Date matches Lender’s Maturity Date in ETran.


Wrap-up reports (Charge Off Tabs)

  • Within 30 calendar days after completing all liquidation efforts.

  • No later than 24 months from SBA’s purchase of the guaranty.

Care & Preservation Tabs (CPC Tabs)

  • May be included when the Guaranty Purchase Package is submitted.

  • May be included when Charge Off Tabs are submitted to SBA for approval.

Note: SBA will not process requests at any other time.


Recovery proceeds

  • SBA must receive net recovery within 15 business days of receipt by Lender.

Other important dates:


Site Visits

  • Origination

  • Prior to underwriting for change of ownership transactions, since it’s required to be discussed in your credit memo.

  • Servicing

  • Within 15 days of an adverse event (such as death of owner, business closure).

  • Within 60 days of uncured payment default.

TIP: Must be in a written report and maintained in the loan file. If you have pictures to include, that’s a plus.


CRE Appraisals

  • Origination

  • Within 12 months of Application

  • Liquidation

  • Less than 120 days, and no more than a year

Seasoned Loan

  • 18 months after initial disbursement.

  • OR 18 months after final disbursement if initial disbursement was more than six months from initial disbursement.

Early Default

  • Within 18 months of initial disbursement.

  • OR within 18 months of final disbursement if initial disbursement was more than six months from initial disbursement.

These dates are based on the current SOP 50 10 6 and SOP 50 57 2.


As suggested above, we highly recommend that you add these dates to your processes and procedures. These are easy to lose track of, and the consequences aren’t fun!


Want some help? We can review your processes to make sure the correct dates are included – and also that all appropriate steps are in place and in the correct order.


Having your processes and procedures 100% correct is the best way we know to make sure your SBA lending program stays on track. Click this link to schedule a consultation!