NAGGL in the Big Easy: Time well spent October 28-30. As always NAGGL was information-packed but the most common thread was “COMING SOON.” Here’s an SOP update: SOP 50 10 6 is in the review and approval stages with anticipated release in early March 2020. The new 50 57 3 for Servicing & Liquidation is also in process and word is that release is slated for month-end March, following release of SOP 50 10 6.
So as much as we’re itching to see the changes, we’re left to wonder for a while longer. What was confirmed is that SOP 50 10 6 is more streamlined with new format. And SOP 50 57 3 is scheduled for later so it can include the changes to 50 10 6 that affect servicing and liquidation.
So much for the SOPs. For now. Other takeaways from the Conference and Sessions include:
Loans for a partner buyout. The 10% injection must come from the partner’s cash not company cash. Apparently, SBA is seeing this done improperly.
Investors of 20% or less. SBA encouraged lenders to tread lightly when an applicant’s investors of 20% or less expect repayment of the investment from distribution. This is not truly injection.
Liquidated and charged-off loans. Remember that you’re required to notify SBA TOPS of any bankruptcy notices you receive.
New Repurchase Tabs are on the SBA website. As I write, the Information Notice isn’t out yet. Once the notice is issued, lenders may continue to use the old Tabs for 30 days before they will no longer be accepted.
The Version 15, 4/25/19, Unilateral Action Matrix has been out for some time, but was not on the SBA the website. SBA has confirmed that it’s online now.
When adding a signature addendum to an SBA document, be sure to name the Addendum. For example, for a Form 1050 Settlement Sheet you might label the Addendum: “Addendum to form 1050 Settlement Sheet for SBA Loan #1234567890.”
More SOP revisions coming. OCRM is revising SOP 50 53 Supervision and Enforcement and SOP 51 00 Examination.
SBA Confirmed no penalties or targeting for PLP lenders if they send loans through the LGPC as GP. In fact, the SBA encouraged lenders to take this cautionary step if they’re concerned about eligibility or other aspects of the loan.
At JRB, we always enjoy our participation in NAGGL conferences. The networking and shared knowledge is a springboard for a new drive and focus in our work. We had a great time meeting new lenders, vendors and SBA staff and look forward to the new year and changes to come in our industry.