If your inbox is overflowing like mine is, you’ve been inundated with hot topic notices SBA issued during the “dog days of summer.” Topics that won’t cool off any time soon, even when the weather does.
Colson to Guidehouse. The Great Migration. Well, we’ve arrived. We’ve followed the transition trail and now it’s time to settle in. As with all new environments, settling in will take some time – and a learning curve. SBA has provided a multitude of tools to help acclimate you as quickly as possible. Migration to the new Fiscal Transfer Agent (FTA) for all 7(a) systems and applications took many steps over many weeks. To recap:
- CARES Act system applications have migrated to SBA’s Capital Access Financial System (CAFS).
- SBA introduced a new 7(a) program APIs, including APIs for LoanList and 1502 Report Submission within the FTA Portal.
- FTA “Wiki.” keeps everyone up to date. Check it out, and go to the Downloads and Resources page for the latest information and resources and to reach the FTA Customer Support Team.
This first wave of migration is a stepping stone to enhancements improving automation, security, efficiency and analytics. So after you’re settled, get ready to pack up and hit the migration trail again. SBA is looking for your ideas for this next wave. Contact Modernize7a@sba.gov.
Environmental Questionnaire. Due Diligence. Doing it Right. “The devil is in the details.” How often do we say it in our business? Yet especially in our business, we know that details matter. They matter a lot. I listened to an SBA session on Environmental Due Diligence last week, and the Agency mentioned a new detail in the SOP that many lenders are missing: Every Environmental Questionnaire must include a Fact Statement Certification. Here’s that not-so-little detail:
“An acceptable Environmental Questionnaire must include, in addition to the required areas of inquiry listed below, the following language with respect to false statements: ‘The undersigned owner(s) and/or operator(s) acknowledge(s) and agree(s) that intentionally falsifying or concealing any material fact with regard to the subject matter of this Environmental Questionnaire may, in addition to other penalties, result in prosecution under applicable law including 18 U.S.C. section 1001.’”
The SOP adds that SBA will accept the ASTM questionnaire used for … all purposes in an Environmental Questionnaire. It’s all in SOP 50 10 6, Appendix 4. Definitions — Environmental, pgs. 539-540. A detail not to be missed!
PPP Direct Forgiveness. And ‘The Unforgiven.’ As of this writing, nearly 1,300 lenders nationwide have opted into SBA’s PPP Direct Forgiveness Portal. It appears lender momentum is slowing as borrower activity picks up. Direct forgiveness is now more visible on SBA’s website. And the Agency is strongly encouraging lenders to opt in on their PPP platform and to work on the forgiveness process for PPP loans.
Yet, according to SBA, some lenders aren’t “… yet accepting forgiveness applications …” and/or “… are not actively reaching out: to their PPP borrowers …” If PPP borrowers don’t request forgiveness SBA won’t grant it. Lenders choosing not to opt in to the Direct Forgiveness Portal are encouraged to reach out to their PPP borrowers to complete the forgiveness process. It’s also a good idea to discuss other opportunities with these borrowers. Reminder: Lenders who opted in are reporting saving significant processing time, which should encourage more use of this tool.
Good to know!