All of us, I’m sure, have eagerly awaited the calendar’s roll over into February and the official end of the Holiday Season. High time to put away all the lights and start using, returning, or regifting those presents! Punxsutawney Phil didn’t see his shadow on Groundhog Day 2024, suggesting sunny days ahead. Time to gorge on Super Bowl snacks, celebrate Presidents Day – Washington’s and Lincoln’s birthdays combined for long-weekend convenience – and Valentine’s Day.
Of course, as an SBA lender, you began February by toasting the end of the 30-day grace period SBA allowed for implementing Information Notice 5000-852422 regarding renewals and updates to various forms. Using the new forms is now mandatory. Most notable for 7(a) lenders: SBA Form 1919.
I’m sure you have already appreciated the sleek look of the reorganized and streamlined Form 1919. And its convenience. Although you must obtain and retain the signed Form in your loan file, you need only enter the information from 1919 in E-Tran, not the Form itself.
And now, the Form has only one question regarding the criminal history of an SBA loan applicant: You needn’t print out an entire rap sheet. SBA isn’t asking whether an applicant rode with Jesse James to the Northfield Bank. Just provide the required information on whether … an Associate of the Applicant is currently incarcerated, on probation, on parole, or presently subject to an indictment for a felony or any crime involving or relating to financial misconduct or a false statement. Character determination wrapped up in one fell-swoop.
Importantly, the updated 1919 tells lenders how to calculate the number of existing employees at the time of application and the number of jobs to be created and/or retained as a result of the loan. Make sure to read and thoroughly understand this section, as it is in accordance with 13 CFR § 121.106. The process is easy to follow, although it may require a change in the way you have been calculating jobs. If you get stumped, give us a call. Contact JRB.