SBA’s “Do What You Do Rule” and the Credit Memo – A Coleman Webinar 5/14

Preparing the SBA Credit Memo for 7(a) Loans
Incorporating “Do What you Do” with the 5 C’s

Attend the Live Webinar Event
Tuesday, May 14, 2024
2:00 PM Eastern
75-minute training with e-certification

The problem with SBA’s “Do what you do rule” is SBA 7(a) loan underwriters cannot solely rely on their internal credit policy to write the credit memo.

It’s really a “Do what you do, and make sure you follow our rules too.”

SBA rules must be followed. And addressed in the credit memo.

So, lenders are left with little directions on a number of mandatory SBA regulations.

We help solve the lender’s confusion by bringing clarity to the important considerations that must be addressed in the underwriter’s credit memo that protects the SBA loan guaranty.

You will learn how to address the following SBA specific checklist items in your credit memos:


● Define “character”
● Define “applicants must be creditworthy”
● clearance
● Elimination of Form 912 and criminal history clearance
● E-Tran Hold Codes
● Management experience


● Debt to service ratio cash flow requirements
● Global cash flow requirements
● Using projections to document positive cash flow
● When you can substitute a credit score for cash flow


● SBA equity injection verification
● SBA equity injection documentation requirements
● Common equity injection mistakes


● Affiliation rule
● Underwriting the Franchise Loan without the Franchise Directory
● Ineligible businesses
● Special rules for business acquisition loans
● Funding the loan without a loan authorization


● All available collateral rule
● Liens on guarantor personal real estate
● Life insurance requirements
● Guarantor requirements

By joining the webinar, you will learn how to navigate the “Do what you do” rule while ensuring compliance with SBA regulations. Our team will break down the essential elements you need to include in your credit memos to protect the SBA loan guaranty. From defining character and assessing cash flow to understanding equity injection and eligibility criteria, we’ll cover it all. By the end, you’ll have a clearer understanding of how to address these key aspects in your credit memos, making the underwriting process smoother and more efficient.

Your Training Staff

Lance Sexton, Coleman Faculty Instructor
A former small business owner, Lance Sexton has a successful history of working with small business owners and students related to entrepreneurship and SBA loan origination, servicing, and liquidation.
He has received three training industry awards for his webinar instruction and his 8-week loan closing course.
Lance has over 30 years of experience, including ten years directly managing portfolios of SBA loans. Lance was an entrepreneurship faculty member of the Sam M. Walton College of Business at the University of Arkansas. He is an Executive Vice President of Fountainhead Commercial Capital and has been affiliated with Coleman Publishing for over eight years.

Host: Bob Coleman, Founder, Coleman Publishing
He is the founder of Coleman Publishing, a publisher of newsletters, reports, data, conferences, webinars, online training videos — to help finance professionals become small business lending experts.
Bob is the nationally recognized expert on small business financing. He has appeared frequently on Fox Business News, NPR and other numerous media outlets. He is sourced by all print media. He is a frequent speaker about small business lending throughout the US and EU. Bob has a BA in Medieval History from the University of California Santa Barbara and a MBA in Real Estate Finance from the University of Southern California. Bob has earned numerous awards as a producer of events and video training. His passion is getting capital to Main Street and Rural American small business.

How the Webinar Works

We use Microsoft Teams as the webinar platform.
We will open the webinar for attendees to join at 1:30 pm ET. This will give each attendee thirty minutes before the webinar begins to troubleshoot any technical issues. Call 586-804-8775 if you need assistance.

All Coleman webinars are recorded and a link is sent to all attendees.

Single Site License
The single site license grants your institution one viewing of the webinar. It is permissible to use a single site license on one device in a conference room to be viewed by multiple attendees The webinar can be viewed on any device.

Multiple Site License
A multiple site license is an unlimited access pass for anyone at your institution. You will be given a link that will be usable to anyone with your email domain.

Webinar Links and Handouts
The webinar link will be included on your sales receipt.
The link will also be included when we send the presentation and handouts. These will be sent by eod the day before.

Participants Earn Certificates of Participation
All Coleman Webinar attendees will receive a certificate of participation. This documents your continuing education history for SBA and your regulators.

Questions throughout the webinar are strongly encouraged. There are two ways to ask a question. The first is to ask the question via the chat in Microsoft Teams. The second is to send an email to Also, feel free to ask pre and post-webinar questions.

The Fine Print
1) Substitutions are allowed at no charge.
2) Cancellations receive a 100% credit for any Coleman product.
3) As with all our products, we offer a 100% money back satisfaction guarantee — no questions asked.

3 Easy Ways to Order
1) ONLINE — Register and pay online via Stripe
2) EMAIL –Send an email to with “Webinar Registration” in the Subject Line. We will do all the paperwork and either send you a sales receipt or an invoice.
3) PHONE — Call us at 818-790-4591.

Bob Coleman
Founder & Publisher