5 . Be ready to provide valid reasoning behind deferrals . If the loan received a servicing action to include a deferral , include the written analysis used to justify the action .
6 . Review the SBA Form 1919s . Ensure the SBA Form 1919s are complete for the loans chosen to be reviewed . Are all required attachments documented in the file ? Are all applicable areas initialed , dated and signed prior to submission to the Loan Guaranty Processing Center ( LGPC ) or for delegated lenders , prior to loan approval ?
7 . Evaluate the SBA Form 1920s . Review all the SBA Form 1920s to confirm they are completed for the loans chosen to be reviewed . Are all the answers accurate ? If a section is not applicable to your loan , be sure the “ N / A ” checkbox is selected on the title line of any not applicable sections . Are all applicable areas initialed , dated and signed prior to submission to the LGPC or for delegated lenders , prior to loan approval ?
8 . Review any SBA Form 159s for accuracy . Are all applicable sections / boxes completed ? Are any required itemizations and supporting documentation attached ? Is the SBA loan number included in the form ? Have you provided evidence in the loan file for the date of Form 159 submission to the SBA ?
9 . Allocate time to respond to the exception sheets . Make sure you have sufficient staffing available to respond to the exception sheets within the allotted amount of time for each loan ( typically two days ). Your institution ’ s response to each loan ’ s exception should include supporting documentation and a clear explanation indicating why the exception should be cleared .
10 . Display loan history . Provide a transcript or loan history for each of the sampled loans . Be sure to provide a description for any transaction codes appearing on the loan transcript as well .
Staying One Step Ahead Whether you perform your SBA loan review function internally or partner with a third-party provider , it ’ s important to stay proactive to ensure a smooth and successful review . If you do have a third-party perform the review , be sure to partner with qualified professionals who specialize in SBA loans , as they will have an in-depth understanding of the SBA expectations and compliance . Having performed over 15,000 SBA independent loan reviews , Doeren Mayhew ’ s SBA loan specialists stand ready to assist in helping your institution with its next review . Contact us today to learn more about our SBA loan services . ■
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Looking for a way to enhance your SBA loan reviews ? Consider leveraging Doeren Mayhew ’ s GOLoan Review software to ensure compliance , provide helpful tips and more . Scan our QR code to schedule a demo today .
Issue 1 | 2023 VIEWpoint 5