The Next SBA Loan Audit Risk: Undocumented Debt and Unsupported Working Capital — 3/17
A Coleman Training Webinar
Date: Tuesday, March 17, 2026
Time: 2:00 p.m. Eastern
Includes e-certification & recording
Effective March 1, SBA introduced new documentation requirements that change how lenders must verify borrower debt obligations and working capital needs.
Lenders must now obtain the two most recent months of commercial bank statements for the borrower’s primary operating account and reconcile those statements directly to the debt service coverage ratio calculation.
This change moves SBA underwriting beyond borrower financial statements and tax returns. Lenders are now expected to verify actual cash flow behavior using real bank activity.
For SBA lenders, this is not a minor procedural change. It fundamentally alters how compliant credit files must be documented.
The Problem
The rule directly affects SBA 7(a) lenders, credit analysts, underwriters, portfolio managers, and credit administrators responsible for building compliant credit files.
SBA is no longer relying solely on borrower financial statements to identify debt obligations. Lenders must now verify those obligations through the borrower’s operating account activity.
At the same time, SBA reinforced another documentation requirement. When 50 percent or more of loan proceeds are used for working capital, the lender must explain in the credit memorandum why that level of working capital is necessary for the business.
Together, these requirements change how underwriters build the credit file. Debt obligations must be supported by bank activity, and working capital requests must be supported by clear narrative analysis.
The Solution
This webinar provides a practical framework for integrating bank statement analysis and working capital documentation into SBA underwriting workflows.
Instead of treating bank statements as a checklist item, underwriters will learn how to use them as a verification tool that strengthens credit analysis and protects lenders from SBA file deficiencies.
The result is a credit file that clearly shows how the lender verified the borrower’s financial obligations and why the working capital request is appropriate.
10 Benefits Attendees Will Gain
● Understand the operational changes underwriters must implement under current SBA guidance
● Learn how to efficiently analyze two months of commercial bank statements as part of the underwriting process
● Convert raw bank statement activity into compliant SBA credit documentation
● Reconcile DSCR debt schedules to actual bank withdrawals to verify borrower obligations
● Identify recurring ACH obligations, undisclosed lender payments, and hidden debt
● Detect merchant cash advance debits and other short-term liabilities not reflected in tax returns
● Verify revolving line of credit usage patterns using bank activity
● Build a complete and accurate commercial debt schedule directly from bank statements
● Strengthen working capital justification and documentation within the credit memorandum
● Protect SBA guarantees and reduce audit risk by creating stronger, fully supported credit files
SBA underwriting expectations are changing. Lenders that fail to adapt their documentation process face increased file repair risk.
Co-hosted by Michael Bland, this webinar will show your underwriting team how to analyze borrower bank statements, reconcile debt obligations, and properly document working capital needs in the credit memorandum.
Your Training Instructors
Michael Bland
Michael Bland is a 30-year SBA veteran. He is the Chief Credit Officer for Phoenix Lender Services, which provide LSP services to Community Bank & Trust – W Georgia, now the 35th largest SBA lender in the country. He was the Chief Credit Officer and Chief Operating Officer for Fountainhead SBF LLC, as well as the interim CEO. Michael served as the Head of SBA Lending for TCF Bank, and prior to that was a credit manager for a number of institutions. Recognized for his credit performance over the years, he has worked at Zions Bank, The Bancorp, Banco Popular, and other national and regional lenders.
Bob Coleman
Bob Coleman is the Author of “Easy Money, Hard Time: 19-COVID PPP Loan Fraud Stories.” He is the founder of Coleman Report, 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 SIPA industry awards including “Podcast of the Year” and 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. 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 when we distribute the presentation and handouts shortly before the webinar.
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
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 anna@colemanreport.com. 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 QuickBooks $500 or QuickBooks $800
2) EMAIL –Send an email to cindy@colemanreport.com 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
Publisher, Coleman Report
bob@colemanreport.com