July 25, 2013
SBA requires lenders to report information to the appropriate credit reporting agencies whenever they extend credit with an SBA loan. Thereafter, the lender should continue to routinely report information concerning servicing, liquidation, and charge-off activities throughout the life cycle of the loan.
This appears to be rather new direction from SBA per the SOP 50 57 (see page 30), but it is requirement per the Federal Credit Bureau Guide (FCBG) and OMB Circular A-129, which states these reporting requirements apply to all non-tax non-tariff delinquent and current commercial debts. Therefore, any lender, bank or non-bank, issuing government-backed loans is bound by the reporting requirements.
The FCBG explains, “Account information should be reported on a non-exclusive basis … to each designated commercial credit reporting agency receiving Federal data, unless circumstances dictate otherwise.” Appendix 3 of the FCBG lists the designated credit reporting agencies for commercial accounts such as Dun & Bradstreet, Experian, and Equifax.
The FCBG also explains commercial account information should be reported on a quarterly basis, but “more frequent updates may be provided as necessary to maintain the integrity and accuracy of the information being reported.” Lenders should begin recording in accordance with the reporting requirements set forth in section 2 on page 30 of the SOP 50 57, which states, “Lenders are required to report information to the appropriate credit reporting agencies whenever they extend credit via an SBA loan.”
All of this guidance is provided in the Guide to the Federal Bureau Program (A Companion to the Treasury Financial Manual Credit Supplement) and Circular No. A-129, Policies for Federal Credit Programs and Non-Tax Receivables.