Servicing Actions Required by SBA Lenders for PPP Disbursed Loans
Date: Wednesday, September 2, 2020
Time: 2:00 p.m. Eastern
Download a Registration Form
In accordance with SBA Interim Final Rules, FAQs, and SBA Procedural Notices, lenders must perform the following servicing action for PPP disbursed loans.
SBA PPP Servicing
1. Maturity date of a PPP Loan
2. Guidance available at the time of the relevant application
3. Scanned copies of documents, e-signatures, e-consents
4. PPP sold on secondary market
5. Change in ownership after February 15, 2020
6. SBA review of individual PPP loan files
7. Laid off employees
8. Safe harbor
9. Good faith
In accordance with SOP 50 57 2 and 13 C.F.R § 120.530, Lenders may assist borrowers experiencing temporary cash flow issues by deferring payments for a stated period of time.
1. For a Loan Not Sold on Secondary Market: Lenders may grant a deferment of up to six (6) consecutive months.
2. For a Loan Sold on Secondary Market: As outlined in the Secondary Participation Guaranty Agreement (SBA Form 1086), Lenders may grant a one-time unilateral deferment of up to 90 days without requiring prior investor consent. The Lender notifies the investor through the Fiscal Transfer Agent (FTA) (Info@colsonservices.com) of the unilateral deferment and reports the affected loan on SBA Form 1502. Lenders may make additional loan deferments only with prior investor consent.
For additional guidance regarding deferments of 7(a) loans, please refer to SOP 50 57 2.
SBA 7(a) Servicing
1. Forbearance
2. Reinstatement of Maturity Date
3. Deferment
4. Modification of Repayment Terms of Note
5. Assumption of Loan
6. Subordination to Working Capital Loan
7. Relief on Secured Senior Loan
8. Voluntary Sale of Collateral
504 Business Loans
In accordance with SOP 50 55 and 13 C.F.R. § 120.530, CDCs may assist borrowers experiencing temporary cash flow issues by deferring payments for a stated period of time.
The amount deferred should not exceed six (6) cumulative monthly payments or 20% of the original loan amount, whichever is less. Unless SBA has purchased the Debenture, the CDC must notify the Central Servicing Agent (CSA) of any deferment in order to avoid acceleration of the Note and the need to purchase the Debenture.
For additional guidance regarding deferments of 504 loans, please refer to SOP 50 55.
Microloans
In accordance with SOP 52 00 B, Intermediaries may provide a deferment on a loan made to a small business to ensure full repayment of the Microloan. Microloan Intermediaries may make deferments for up to six (6) months. No deferment may cause the life of the Microloan to extend beyond the maximum six (6) year maturity.
Former SBA Little Rock Deputy Director Lance Sexton will discuss the new servicing actions you must perform in 2020.
PLUS, he will analyze and dissect the 14 PARRiS Score criteria and how to get ready for your SBA review.
Don’t take anything for granted when it comes to SBA reviews. Too many deficits can cause SBA to assess penalties or disqualify you for SBA lending. We’ll help you address each of these 14 criteria—and lay out the critical scoring thresholds that can put you in trouble—before you’re judged on them:
Performance
5-Year Cumulative Net Yield
12-Month Default Rate
5-Year Default Rate
Asset Management
Stressed Rate
Early Problem Loan Rate
High-Risk Origination Rate
Regulatory Compliance
1502 Reporting Rate
Loans in Active Default Status over 3 Years Rate
24-Month Repair/Denial Rate
Risk Management
FDIC total Risk-Based Rate
Non-Performing Asset Ratio
Lender Purchase Rating
Special Items
Average SBPS (weighted)
Recovery Rate (Over last 5 years)
Has Prudential Regulator (Preferred)/No Corrective Action Request (Preferred)
Register today by emailing joseph@colemanreport.com.
Lance Sexton served as Deputy Director of the SBA Little Rock Commercial Loan Servicing Center managing the Servicing of SBA Loans, the liquidation of SBA Express Loans, and the Liquidation of SBA 504 loans in a 24 state area. Lance has 30 years of experience in the origination, servicing, and liquidation of SBA Loans, ten years of experience directly managing portfolios of SBA loans that are both performing and nonperforming, and six years of experience as a small business owner.
Bob Coleman is the Author of “Money Money Everywhere and Not a Drop for Main Street.” He is the Publisher of the Coleman Report, a trade newsletter and website for SBA and small business lenders. He produces online training videos and webinars for small business lenders to teach them to make less risky loans to Main Street.
Certificates of Participation
All Coleman Webinar attendees will receive a certificate of participation. This documents your continuing education history for SBA and your regulators.
We will automatically forward a certificate of participation for those who are registered to attend the webinar via GoToWebinar.
If you have purchased the unlimited site license and would like certificates for all who attend simply forward their names and email addresses to jeanne@colemanreport.com. She will email the certificates to all attendees.
Questions
Questions are strongly encouraged. There are two ways to ask a question. The first is to ask the question via the chat box on the GoToWebinar dashboard. The second way is to send an email to joseph@colemanreport.com. Also, feel free to ask pre-webinar questions.
About Coleman Webinars
Coleman is the largest producer of small business banking video webinars and online training for the banking industry.
Our faculty are professional instructors are the absolute experts in their fields.
Why a Coleman Training Webinar?
It’s very cost effective. No airfare, no hotels. Just cram as many people as you wish into your conference room and turn on the computer. You have several options to view the program. You may watch on screen, or listen in on your phone.
You can choose to have any many connections nationwide as you wish when you purchase unlimited access for only $589.
A great benefit of the program is that you may have your questions answered by the faculty. All of our webinars are recorded. Buyers of the unlimited site license option will receive a DVD recording of the event to share with anyone you wish.
A transcript of the program is also provided to purchasers of the unlimited site license.
How it Works
We use GoToWebinar for the webinar platform. You will receive a link that will direct you to an Internet site to view the presentation. If you would like to test this process to make sure you will be able to access the link through your system’s firewall, just send an email to joseph@colemanreport.com, and he will schedule a test run.
Accessing GoToWebinar
There are two ways to access the webinar. The first is to simply click on the link we will provide when you register.
If you have a firewall issue, or you can’t get the GoToWebinar link to work, don’t panic!
The second way to access the webinar is directly from the GoToWebinar website. You will simply need to input the webinar ID and access code. These will also be provided when you register, and again the day before the webinar when we distribute the handouts.
Note we will open the webinar for attendees to join at 12:00pm ET. This will give each attendee two full hours before the webinar begins to troubleshoot any technical issues. Call (818) 790-4591 if you need assistance.
All Coleman Webinar Speakers are seen Live via Video Stream
You will see our speakers live through a video feed. You may customize the size of the speaker and PowerPoint presentations by clicking on the webcam button on the GoToWebinar dashboard. You may position the speakers at the top, bottom, right or left hand sides. You may also choose to eliminate the video stream and just view the PowerPoint.
Telephone Only Option
You may also choose to listen to the program on your telephone. The phone number will be provided with the handouts.
PDF Handouts
You will receive the PDF handout via email the day before the event. These may be distributed to all of your attendees.
Replay Link
If something comes up and you miss any part of the webinar, or there are technical issues such as a power failure, Internet dropout, fire alarm drills, actual fires or, earthquake (yes that has happened!) simply email joseph@colemanreport.com and he will send you a link you may watch all or part of the webinar at your leisure. There is no charge for this service.
The Fine Print
1) The single user registration fee of $489 is based on location not attendance. You may have as many people in one location attend. You may distribute the materials to anybody in your company.
2) For only $100 more ($589), you may invite as many people from your institution from as many locations as you wish. (You also get the reply link and transcript!) We will forward you a link that allows you to sign up as many people as you wish.
3) Substitutions are allowed at no charge.
4) Cancellations receive a 100% credit for any Coleman product.
5) As with all our products, we offer a 100% money back satisfaction guarantee — no questions asked.
1) Previous customers need only to send an email to joseph@colemanreport.com with “Register SBA Servicing Webinar” in the Subject Line. We will do all the paperwork and charge your credit card on file, or send you a PayPal request.
2) Call Joseph Coleman at Customer Service at 818-790-4591 extension 1
3) Fax the order form to: 818-790-7859
4) Mail the order form to: Coleman Publishing, 28081 Marguerite Pkwy, #4525, Mission Viejo, CA 92690
5) Click “Add to Cart” to pay using PayPal
Bob Coleman
Editor, Coleman Report
28081 Marguerite Pkwy #4525
Mission Viejo, CA 92690
(818) 790-4591
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