“June marks the seventh annual celebration of Immigrant Heritage Month, which honors the individual and collective contributions made by immigrants in communities across the United States … On an average day, we … grant permanent residence to more than 2,500 people.”

 Tracy Renaud
USCIS Acting Director

 It’s highly likely that the flow of SBA loan applications from people claiming Legal Permanent Residency continues coming through your door. As we know, verification of immigration status is necessary for these applications to move forward. And as we know, there’s a form for that: U.S. Citizenship and Immigration Services (USCIS) Form G-845 Verification Request for use in verifying an applicant’s immigration status when they apply for federal, state, or local public benefits and licenses.

SBA requires submission of this form for business loan applications involving non-U.S. citizens. Recommendation: Start the verification procedure early-on in the process to eliminate potential delays. Verification must be completed before application submission to SBA. When your applicant completes  SBA Form 1919, check out question #20 ASAP.

Updated Form G-845 Reminder and Reference. This past April, USCIS released an updated Form G-845 (04/08/21- 04/30/2024) and instructions for use in verifying an applicant’s immigration status. Effective June 1 2021, with a drop-dead deadline of June 28, 2021, SBA requires use of the updated Form G-845 for all status verification requests. Please make sure to begin using the updated USCIS Form G-845 immediately.

As We Know, It’s a Process. For more information about processing loans to non-U.S. citizens and use of USCIS Form G-845, see SBA’s guidance in SOP 50-10-6, pgs. 157-160. C. Specifics to Form G-845 begin on pg. 158. Some key highlights:

At time of application, for any individual who is not a U.S. citizen and is located in the U.S., and is required to complete the SBA application, the following applies:

  • Provide the USCIS Form I-551. i.e., a “green card” or an acceptable substitute.
  • SBA Lenders must obtain a copy of the individual’s USCIS documentation from the Sacramento Loan Processing Center (SLPC) and maintain all documentation in the loan file.
  • The SLPC will provide instructions on how to complete registration and use the electronic verification process.
  • SBA Lenders are to submit a USCIS Form G-845 with supporting information to the SLPC and state on the G-845 that the request is for an SBA loan.
  • As required by USCIS, SBA will release information about the status of an alien to SBA Lenders or other non-governmental entities ONLY when a signed and dated authorization from the alien is attached to and submitted with the G-845.
  • The original Document Verification Request (G-845) and authorization for release must be maintained by the SBA Lender in the Applicant’s file for review by SBA and USCIS, if requested.

Best practice. Set up access to request this verification before you anticipate needing it. SOP page 159: “In order to request Document Verification from the SLPC, all SBA Lenders must register designated personnel with the SLPC at Sacramento504Register@sba.gov.“

 Lisa Lerner
JRB Senior Associate
lisa@jrbrunoassoc.com