March 29, 2022
SBA Hot Topic Tuesday – SBA FAQs on Fingerprinting for Character Determinations
Although the Form 912 no longer exists, the SBA recently released the new Character Determination process. Lenders must contact OCACD@sba.gov for all character determinations. Information within the email should include the borrower’s name, the ETRAN number, and a note stating that the documentation for the character determination has been submitted. All documentation for the character determination must be submitted through ETRAN.
Character determinations are necessary for any Subject Individual that answers “Yes” on the SBA Form 1919 for question 18 or 19. Lenders will need a detailed written statement from the individual regarding the “Yes” response, the date of each offense, the city/county/state the offense occurred in, the specific charge and conviction, the disposition of the charge, and the supporting court documentation.
Fingerprints are required for any individuals who had a felony conviction, a misdemeanor or disposition charge within 6 months of the loan application, or a misdemeanor charge involving a crime against a minor.
Lenders must refer the individual to the approved channeler’s website, www.applicantservices.com/sba, to conduct fingerprint background checks. Subject individuals will have to create an account and register on the channeler’s website. The FBI-approved, SBA-contracted channeler will direct the individual to an approved electronic fingerprinting facility.
Once the fingerprints have been submitted, lenders should upload the character determination package to ETRAN and notify the SBA that all necessary documentation has been uploaded to ETRAN.