Steeplechase: a footrace over an obstacle course that includes

 water ditches, sand traps, and fixed barriers*

 Not sure about you but for me, Loan Servicing brings back memories of my high school track and field elective, specifically the steeplechase. Those were fun days … Jumping over hurdles. Splashing thru water ditches. And all along, minding your laps. On your mark . . . Get set . . . GO!!!

On Your Mark!  At origination, you must check whether all policy documents, including ACORD forms, match the Authorization and are properly documented. This is a key step. Does Ventures accurately reflect whatever must be tracked?  Are ticklers set up correctly? Contact information present and accurate? You don’t want to be tying your laces midway thru the fifth loop.

Get Set!! Work with your closing officer, using the Authorization to create a comprehensive list of all items to be tracked:

  • Were all insurance documents collected at closing? Is the property in a flood zone? Declarations and endorsements? Or only ACORD forms or notices?
  • UCCs. What is the collateral?
  • Financials. Were the latest statements collected at closing e.g., Financial Statements, Business Tax Returns?
  • Jobs. Get the Jobs Requirement from the Loan Application.
  • Site visit. Was it done at the Loan Application stage? If yes, enter the data into Ventures.

GO!!! To an American sports fan, steeplechase may look boring – just like Insurance tracking. But the good runners find joy in navigating race’s multiple hurtles.

Insurance

  • New policy or carrier. For a new policy, the dates change. Note: Your CDC should have received a Life-of-Loan document when you obtained the FEMA form for closing.
  • Flood zone change. Did the Borrower address change? Makes sure it is not in a Flood Zone. Otherwise, Flood Insurance is required, or flood damage won’t be covered.
  • Bankruptcy, death of a principal, business closure. In all cases but bankruptcy, contact the remaining principals and perform a site visit.
  • Site visits. Any other non-routine issues with the loan require a site visit.
  • Financials. Has the corporate structure changed? Do you need to collect additional financials?

Mind Your Laps!  (a.k.a. Set your Tickler dates)

  • Expiration of the most recent evidence.
    • UCCs. Renewals Three (3) months prior to the 5-year expiration from the date of initial filing.
    • Financials. EOY as of 12/31/prior year or the end of the FY if the borrower has a different date.
    • Jobs. Two-year anniversary of the funding date. Use the proper SBA-approved format for certification.
    • Site visit. Site visits are required only for a material adverse change or if the borrower is 60 days delinquent. Then, the visit must be done within 30 days. Note: Your CDC’s procedures manual may have stricter requirements.
    • Other “advanced” servicing items needing to be tracked/entered e.g., ACH, liquidation.

Critical: Memo to File. Documenting all Servicing actions with a Memo to File is always a good habit, but it becomes critical if the loan is unfortunate enough to enter the Repurchase Package stage.

There are still two years ‘til the next summer Olympics, but your insurance steeplechase is going on now. Pay close attention to those hurdles and make sure you know how to clear them! Want to chat with an experienced track coach? Contact JRB!

Alex Liberchuk, Principal
J.R. Bruno & Associates
855.JRB.4.SBA (855.572.4722)
alex@jrbrunoassoc.com
www.jrbrunoassoc.com

*Source: “Definitions of Olympic Sports”