Download:
pdf |
pdfOMB Control Number 3245-0365
Expiration Date XX/XX/XXXX
SBA Supervised Lender Safety and Soundness Examination/Full
Review Information Request
Attachment to Notice of Intent
to Perform a Review
In accordance with 13 CFR §120.1000 (Risk-Based Lender Oversight) and 13 CFR §120.1050
(Reviews and Examinations), SBA conducts reviews and examinations of the SBA loan
operations of SBA Lenders. The information requested below assists in SBA’s evaluation of the
Lender’s portfolio performance; SBA operations management; credit administration; compliance
with Loan Program Requirements and as applicable, SBA Supervised Lender capital adequacy,
earnings, and liquidity.1 Submission of this information is required so that SBA can conduct that
evaluation.
Instructions for the submission of requested information are in the attached cover letter.
**Please note, in general, for information that has already been provided by a 7(a) lender but is
unchanged, a lender may certify that the information was already provided and is unchanged in
lieu of resubmitting the information. The certification that must accompany this document
submission must also state to whom and on what date the information was provided to SBA.
List of Loans in the Sample for Review/Examination
To be provided to the SBA Supervised Lender on or about two (2) weeks prior to the onsite activities INSERT DATE
Items Requested for Pre-Site Review/Examination
Management and Operations
1. Organization
Current organization chart and a summary of delegations and
responsibilities for the SBA program executives and program managers.
2. Business Plan
Strategic and current operating plans, budgets and comparative performance
reports related to lender’s SBA program objectives for portfolio growth,
performance, product lines, and geographic and industry (i.e. NAICS)
concentrations.
3. Financial Information
a. Annual Report and year-end audited financial statements for prior 3 years.
Most recent interim financial statements.
1
Information requested may be applicable to the evaluation of more than one area.
PLEASE NOTE: You are not required to respond to any collection of information unless it displays a currently valid OMB Approval number. The
number for this collection of information is 3245-0365. The total estimated time to respond to this collection of information, including
gathering and maintaining the data needed, and completing and reviewing the collection of information, is 2280 minutes. You may send
comments or questions regarding this estimated time or any other aspect of this collection of information including suggestions for reducing
the time or other burden to: Director, Records Management Division, 409 Third Street, S.W., Washington D. C. 20416, and Desk Officer for the
Small Business Administration, Office of Management and Budget, New Executive Office Building, Room 10202, Washington DC 20503.
b. Final or, if reports are not finalized, draft reports received within the last
two years related to your SBA program:
i. Internal audits, examinations, reviews and management letters;
ii. External audits, examinations, reviews and management letters; and
iii. Management's response and a summary of actions taken to address the
findings and recommendations of each audit, examination or review.
Eligibility and Credit Administration
1. Written policies and procedures, including:
a. Credit policies;
b. Internal controls policies and procedures (including policies to determine
whether employees are subject to criminal, civil, or administrative actions);
c. Loan servicing policies and procedures;
d. Any credit scoring methodology employed to screen or approve loans;
e. Annual validation, with supporting documentation and methodologies
demonstrating that any scoring model used by the SBLC is predictive of loan
performance; and,
f. Risk rating methodology.
2. Documentation that demonstrates testing of lender compliance with policies and
procedures and internal controls. For example, internal audit documentation,
external audit test results, or other proof of quality assurance activities.
3. Description of the internal and/or external methodology employed, including
credit scoring techniques if applicable, utilized to:
a. Screen or evaluate for loan approval; and
b. Grade existing loans.
4. List of all SBA guaranteed loans as of INSERT DATE in the Excel format
provided, which includes current risk rating grade/score.
5. List of all SBA loans approved since INSERT DATE that have exceeded 30 days
past due on principal or have been purchased from the secondary market and the
current status of that account.
6. List of all SBA loans approved since INSERT DATE that were made as an
exception to underwriting standards. Also, please state the nature of the
exception.
7. List of all SBA loans that had servicing actions since INSERT DATE . Please
include a description of the servicing action taken and the current status of the
account.
8. List of all SBA loans purchased from another lender since INSERT DATE.
Also, please state the originating lender's name and date of purchase.
Compliance with Loan Program Requirements
1. If agents are used - provide your written policy on lender’s use and oversight of
agents and provide a narrative describing any relationships with non-employee
commissioned or any other type of non-employee loan application agents (e.g.
packagers), brokers or similar individuals.
2. For all SBA guaranteed loans referred by an agent, provide a list of loans by
agent and the current status of each loan (current, past due, in deferment, in
liquidation, charged-off).
3. Lender Service Providers (LSPs) (If applicable)
a. Provide a list of LSPs and documentation including a copy of the LSP Agreement
SBA Supervised Lender
Attachment
Page 2
and date of contract acceptance by the SBA.
• If the LSP assists with origination, provide details on who prepares and
approves the credit memo.
• For servicing and liquidation activities, describe who (Lender or LSP) is in
contact with the applicable SBA processing center.
• Who has physical possession of the loan files?
b. Provide the name of the Lender staff who manages the LSP relationship (i.e. vendor
management) as well as a copy of policies and/or procedures regarding the use,
oversight and management of the LSP(s).
c. Provide any reporting information by the Lender (e.g., to management or the Board)
regarding the performance of the LSP(s).
d. Provide a summary describing any revisions or changes to the original LSP
Agreement and date of revised contract acceptance by the SBA. If the revised LSP
Agreement has not been submitted to the SBA for review, please do so now via email
([email protected]) and provide a copy of the submission email.
4. If the LSP Agreement has been terminated, provide a copy of the termination letter or email
submitted to the SBA.Proof of fidelity insurance coverage.
5. List and dates of SBA-specific training provided to staff.
6. Copies of the minutes of all Board of Directors meetings since INSERT DATE.
Items Requested During the On-site Review/Examination (Compliance)
1. A copy of the monthly and daily (unscheduled payments) SBA Form 1502, Guaranty
Loan Status and Lender Remittance Report in SBA loan number order, Lender
Exception reports and confirmation of related remittances for the last three (3)
months. Provide reports in Excel files.
2. Data relating to the most recent 10 SBA loans submitted for purchase to SBA, or all
requests for purchase for the past 60 months, whichever is the smaller number of
loans. Please provide information relating to amount of purchase request, amount
received, and an explanation of circumstances relating to any reductions in purchase
request amount. Provide a transcript of account for each purchase request loan
reported here (for life of loan).
3. A transcript of account for the life of the loan for each loan selected for review.
4. The loan files selected for review.
SBA Supervised Lender
Attachment
Page 3
File Type | application/pdf |
Author | daripley |
File Modified | 2018-09-18 |
File Created | 2018-09-17 |