Justification

November 25, 2020
Susan Minson
OMB Desk Officer
Office of lnformation and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Ms. Minson:
Pursuant to the Office of Management and Budget (0MB) procedures established at 5 CFR 1320,
the Small Business Administration (SBA) requests that the collection of information associated
with payments to 7(a) Lenders under Section 1112 of the Coronavirus Aid, Relief, and Economic
Security (CARES) Act be processed in accordance with section 1320.13, Emergency Processing,
by December 2, 2020.
To assist in addressing the drastic decrease in economic activity created by the COVID-19
pandemic, Section 1112 requires SBA to pay the principal, interest and associated fees that are
owed for a 6-month period on certain loans issued under SBA’s 7(a), 504, and Microloan
Programs. In order for SBA to make these loan payments in SBA’s 7(a) Loan Program in an
accurate and timely manner, SBA created a form that 7(a) Lenders are required to submit to SBA
on a monthly basis to provide the loan information necessary for the Agency to make the Section
1112 payments on behalf of borrowers. It has come to light that this Lender reporting
requirement has not been submitted to OMB for review and approval. The need for this
information will continue until at least the spring of 2021 and longer if the benefit is extended by
pending legislation.
Given the ongoing need to make the payments, SBA is asking for emergency review of the
“Section 1112 Gross Loan Payment Template” to enable SBA to continue to collect the
information without further violation. SBA has determined that this information must be
collected prior to the expiration of time periods established under Part 1320, and that this
information is essential to SBA's ability to provide the debt relief required by that section to
certain SBA borrowers. Delaying the payments while the Agency pursues standard processing
procedures would cause harm to the 7(a) Lenders who are depending on the payments, as well as
to the borrowers who could either default on payments or be forced to use limited resources to
make such payments. SBA also requests a waiver from the requirement to publish the public
comment notice in the Federal Register before seeking review.
Sincerely,

JI KIM

Digitally signed by JI KIM
Date: 2020.11.25 13:40:14
-05'00'

Jihoon Kim
Director
SBA Office of Financial Program Operations