The SBA Lender and its LSP: What SBA and OCC Examiners Expect in 2026 from Your LSP Third-Party Vendor Relationship — 12/18
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A Coleman Training Webinar
Date: Thursday, December 18, 2025
Time: 2:00 p.m. Eastern
Includes e-certification & recording
Lender Service Provider oversight is no longer a routine file check—it’s a regulatory priority. Under SOP 50 10 8 (effective June 1, 2025), SBA emphasizes that “SBA reserves the right to audit compliance with any SBA-reviewed LSP agreement” and that lenders, not LSPs, bear full responsibility for all SBA loan operations. SBA will review your agreements and supporting documentation to verify that the lender maintains day-to-day control over origination, servicing, and liquidation functions.
If you are a bank, this scrutiny extends beyond SBA. The OCC has placed a growing spotlight on third-party vendor oversight. Its 2023 interagency guidance on Third-Party Relationships: Risk Management and the 2024 OCC “Guide for Community Banks” both stress that banks remain fully accountable for outsourced activities. Examiners are focusing on whether vendor relationships are governed, monitored, and embedded in the institution’s risk framework—particularly for fintech, payments, and other critical partners.
The Risk
While SOP 50 10 8 does not explicitly require independent reviews or certifications, it clearly expects lenders to demonstrate active, documented control. The OCC guidance reinforces that expectation, calling for risk-based oversight that includes due diligence before engagement, well-defined contracts with audit and termination rights, ongoing monitoring proportional to risk, and board-level reporting throughout the vendor’s lifecycle.
Together, SBA and OCC examiners are looking for the same outcome: evidence that your institution manages its LSPs and other third-party vendors as part of a mature, documented risk program—not as an afterthought. Lenders may want to consider conducting internal reviews now to confirm that their LSP agreements and oversight processes meet both SBA and OCC expectations before the next examination cycle.
The Solution
This Coleman webinar gives senior management a practical roadmap to align LSP oversight and third-party governance with 2026 regulatory expectations.
Our instructors translate the exact provisions in §§ E and F of SOP 50 10 8—and key OCC vendor-management principles—into a clear internal-review checklist. You’ll learn how to test your existing LSP agreement, strengthen oversight documentation, and ensure your governance structure is consistent with both SBA and OCC review standards.
Ten Benefits of Attending
- Understand precisely what SBA and OCC examiners will review in 2026.
- Confirm that your LSP agreement clearly documents lender control over all SBA functions.
- Ensure the scope of services covers origination, servicing, and liquidation duties.
- Verify that compensation terms prohibit borrower-paid or contingent fees.
- Review conflict-of-interest and affiliation disclosures for completeness.
- Check that termination provisions meet SBA’s reasonableness standard and OCC expectations for exit readiness.
- Learn how to document oversight and monitoring in a risk-based framework.
- Create audit-ready files demonstrating ongoing governance and board review.
- Integrate LSP oversight into enterprise vendor-risk and compliance reporting.
- Strengthen your institution’s PLP compliance and third-party governance before regulators arrive.
Be Proactive Before Examiners Arrive
Join Former SBA Associate Administrator, Bren Ciurlino for this concise, actionable session and learn how to evaluate your LSP and third-party vendor oversight against SBA and OCC standards.
When regulators conduct their reviews, your documentation will already demonstrate full control, accountability, and compliance readiness.
Your Training Instructor
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