Networking with so many 504 professionals is one of the things I enjoy most at NADCO’s Annual Meeting. We had a pretty steady stream of visitors at the J R Bruno booth, with a lot of people asking how we build CDC capacity. Hearing from congressional representatives and the SBA leadership team is also one of the things I look forward to at these meetings.
Importantly, this meeting gives us a heads up of what’s coming down the pike. This year’s session was rich in information – one of the most informative I’ve attended. There’s a lot of information to share:
- The new SOP coming out soon will contain changes to CDC governance and add details on Affiliation and Personal Resources. Scheduled for release in December, SOP 50 10 5 (K) will be effective early in 2019 and will be the last of the 50 10 5 series. Subsequent versions will use a new numbering system. At this point I’m not sure if that’s a small detail or if we can expect a re-working of the SOP in the future. I’ll keep you posted.
- Lender Oversight Bills for 7(a) loans (HR 4743; S 2283) are making their way through Congress, along with legislation to raise the appraisal requirement threshold to $500,000. One provision of this legislation addresses Credit Elsewhere. It gives OCRM increased authority to enforce it and gives OCRM authority to substantiate how lenders determine and document the Credit Elsewhere test.
- Although the Community Advantage Pilot Program is closed to new lenders, SBA advised us that this is only temporary. SBA is analyzing program data and anticipates allowing new lenders in the program after the analysis is done. Of course the analysis may result in some new program requirements.
- Expect to see increased automation in the 504 program, particularly regarding submitting governance documents. This may happen as soon as December.
- Sometime soon, SendThisFile will no longer be used to send closing documents. SBA is developing a repository for closing documents within ETRAN. Not only will this make the process more secure, it promises to streamline the closing process. This too may happen as soon as December.
- OCRM presented its top 10 findings from its SMART Reviews. To help all CDCs pass their next SMART review with flying colors, I’m going to cover this in a future eBulletin or two.
Sounds like the J R Bruno Team will be busy in December, studying the new SOP and learning the ETRAN enhancements. We’ll want to make sure that the CDC industry is well prepared to enter 2019 with the best information available.
Please continue to send me your questions. It’s great to hear from you!
Associate, CDC/504 Programs