Sba sop 51 00 On-Site Lender Reviews/Examinations Office of Lender Oversight
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- 17. Workpapers
16. Report Preparation and FormatThe EIC is responsible for the preparation of the Report. The Report must include sufficient detail to present and support all significant Findings and recommendations and to present the Findings and recommendations in an objective manner. The Report format identifies the SBA Lender, provides an executive summary of the Findings and recommendations and includes a comprehensive discussion of the Findings supported by tables and exhibits (when necessary to add clarity to the Findings and recommendations). The Report contains the following: Cover Page - A cover page will be the first page of the Report. It identifies the name of the SBA Lender, the SBA Lender’s address, the “as of date” of the examination, the period during which the on-site portion of the review was conducted, and the date of the exit conference. Executive Summary - Each Report will start with a brief overall summary of the present and the expected condition of the SBA Lender and the assessment category assigned. The summary should not provide the extensive detail that follows in each subsequent section. Rather, it should contain a description of the overall condition of the lender and the causes and effects of said condition. It should also summarize the Findings for each review/examination component. Components Narrative - The Report narrative should discuss the Findings and conclusions of each review/examination component. For 7(a) lenders and CDC review Reports, the review components to be addressed are i) portfolio performance, ii) SBA management and operations, iii) credit administration and iv) compliance. For SBA Supervised Lenders, the review components to be addressed are i) capital, ii) asset quality, iii) management, iv) earnings, v) liquidity and vi) compliance. Further descriptive information on each review component can be found in subsequent Chapters in this SOP. The discussion of each review/examination component should describe the scope of review/examination undertaken, the Findings, recommendations, management’s response and/or plans to address Findings, and the EIC’s assessment of management’s plans. Selected charts and graphs may support significant issues. Considerable judgment needs to be exercised when deciding what other matters beyond the specific review/examination components need to be addressed. Appendices - Appendices provide details that lend further support to Findings and conclusions cited in the Report narrative. All appendices must be numbered and have titles/headings. The appendices are dictated by the Findings of the review/examination. Regardless of the nature of the appendices, they must be easy to understand. If the purpose is not immediately recognizable, the Report should include an explanatory paragraph. Examples of appendices that may be included in a Report include: Summary of Findings, recommendations, and prior SBA Lender responses; Summary of SBA Lender actions taken since last review/examination, if applicable; List of loan files subjected to loan file review/examination, including loan number, borrower names, SBA loan program, performance status and any additional data considered appropriate; and Listing of compliance and/or credit administration exceptions identified in the review/examination including any material exceptions identified that may affect SBA’s guaranty. For SBA Supervised Lenders, three appendices are required, at a minimum -- a balance sheet, an income statement and key statistical data. Additional appendices other than those discussed above may include, but are not limited to, summaries of classified loan lists; credit administration deficiencies; trend comparisons; and details supporting allowance for loan losses recommendations. Report Findings - The Report formally documents SBA’s evaluation and explains the conclusions that are drawn from the weaving together of the conditions or criteria, the cause and effect analysis, and the risk exposure that each Finding poses to the Agency. It also documents what action is necessary on the part of the SBA Lender to ensure that the risk is managed at a level acceptable to the SBA. The conclusions contained in the Report must be concise and supportable. The Report prepared by the EIC will identify i) the assessment category assigned the SBA Lender, supported in the Report by a detailed description and evaluation of all Findings, ii) recommendations for improvement, iii) any Corrective Actions required, and iv) management’s response including planned actions. Individual components of the review are not rated, but rather summarized as strengths and weaknesses individually. It is important to remember that the Report is not an exception report. It is not intended that the Report be a listing of the problems. The Report must have proper balance. Areas where the conditions are satisfactory may merit only a sentence, but should still be addressed. It is preferable that language explaining necessary Corrective Action be persuasive rather than directive. The Report will be submitted to the AA/OLO or designee for review, concurrence and issuance. Final authority for the assessment category assigned rests with the AA/OLO. 17. WorkpapersA thoroughly completed and documented set of workpapers is required to demonstrate that the review analyses have been completed, and that the Findings have been substantiated. The examiners should analyze and summarize in the workpapers all pertinent data gathered during the review. The review/examination file must contain all required documentation, including the Plan, criteria and related workpapers, observation and interview notes and all other documentation developed during the review/examination necessary to support the Findings and recommendations contained in the Report. All workpapers required to meet the scope of the review/examination must be completed and, if relevant to the Findings, supported by documentation developed during the course of the review/examination. Special effort must be made to ensure that all issues that may be discussed in the Report or may be cited in support of a Report recommendation are documented in the workpapers to the extent necessary to withstand challenge on the basis of the material contained in the review/examination file. The preparation of the workpapers is guided by the scope of the review/examination and the criteria for the review/examination components. The form and nature of the workpaper varies with the nature of the review/examination criteria. In most instances where the element is qualitative in nature the workpaper will be narrative in form, whereas in cases where the review/examination criteria are quantitative in nature the workpaper will generally take the form of a “spreadsheet,” table or graph. (See discussion below on workpapers form.) The Plan and criteria usually provide sufficient guidance to complete the workpaper requirement. Instances will arise, however, where the reviewer will have to rely on a general statement of the work. This condition will usually arise when the scope of the review/examination is expanded in the field as a result of on-site Findings. Instances may also arise where the source documentation may be so voluminous or otherwise not amenable to inclusion in the workpapers. In these instances, the Findings must be written in the field and verified by the EIC or a reviewer designated by the EIC. Workpapers are the primary resource for data supporting the Findings of the
The extent of the workpaper documentation will vary with the scope of the review/examination. The experience level of the reviewers can also be a factor, with the possibility that reviewers being trained may be required to produce an increased amount of documentation to more fully demonstrate and document the thoroughness of a review/examination procedure. At a minimum, workpapers should conform to the scope of the review/examination and demonstrate support for the results of the review/examination. Materials provided by the SBA Lender that are of particular importance to the completion of the workpapers should be filed in the Workpaper File. All retained documents in-file should relate to review components or Findings. Workpapers should be clear and accurate, thus providing an easily understood representation of the reviewer’s analysis, Findings, and conclusions regarding condition, cause and effect. The workpapers should be legible and neatly stored. Whenever possible, workpapers should be prepared on only one side of standard 8½ x 11” paper. a. Work Paper FormsThe team will document all Findings in the workpapers with particular attention being given to major Findings that may become subject to Report comment. Major Findings become the basis for recommendations. The EIC is responsible for assuring that the documentation in the workpapers is sufficient to support the team’s Findings. In addition to providing support for the review/examination Findings, the workpapers must document the SBA Lender’s response to the Findings wherever applicable. The documentation should detail whether management agrees with the Finding or, if there is disagreement, the reason(s) for the disagreement. Documentation should also detail management’s explanation for the cause of the problem and any planned Corrective Action. The source(s) of this information should be detailed. It should also be noted that much information is learned during the discussions held with senior officials. Reviewers should document these discussions in writing for retention when they provide information for other reviewers or for future reviews/examinations. The reviewer assigned to each component of the review/examination will be responsible for developing documentation in support of Findings, including development and organization of all relevant workpapers. Workpapers generally take one of several forms: Narrative Summary - A narrative description of a condition, reviewer’s actions, management’s response(s) and/or reviewer’s conclusions and recommendations. Narrative summary workpapers should be initialed and dated by the author, at a minimum. Narrative workpapers of a critical nature should also be initialed by the EIC. Loan File Review Workpaper - A summary of information from an individual loan file review. Any such summary should also be initialed and dated by the author. SBA Lender Provided Documentation – Where the SBA Lender provides documentation for the review, the reviewer will create a workpaper that lists the documents collected, outlines the specific areas reviewed within the documents and attaches the documents, if possible. Statistical Analysis - In cases where the data to be gathered is statistical in nature (e.g. loan production analysis, demographic analysis, currency and delinquency analysis), the workpaper may consist of a grid and an attachment defining the objective of the analysis and the data source, or other tables or graphs, as applicable. Checklists - Those situations which lend themselves to a checklist format where all of the elements are listed with a “Yes” or “No” response and space to make brief comments. Spreadsheets - Any statistical analysis or tabular material suitable for spreadsheet and/or electronic analysis. Compilation(s) of Exception - An automated compilation may be employed in file reviews to produce a compilation listing of the SBA Lender’s SBA SOP compliance issues. b. Organizing Work PapersThe EIC is responsible for assuring that the workpaper file is properly organized, and contains all relevant material. Workpapers should be logically organized, numbered, and bound at the conclusion of each review/examination to facilitate quality assurance and future review/examination activities. Care should be taken to include only those documents relevant to the work performed. The goal of all review/examination filing is to maintain complete and easily-accessed information for any discussion or subsequent actions determined appropriate by review/examination Findings. Workpapers are to be sorted and organized so that reviewers can quickly find pertinent documents. If a workpaper file contains extensive information, the EIC may want to include an index for sections. The name of the SBA Lender should appear clearly on the outside of each workpaper package along with date of the review/examination. The documentation and workpapers are to be sorted into the following subject sections filed as follows:
Review/examination criteria for the individual review components are listed on a lead sheet which is to be signed and dated by the reviewer preparing the sheet and reviewed and initialed by the EIC. The workpapers for each review component are to be bound together with the lead sheet attached to the top. Directory: sites -> default -> files files -> Answer True False 2 points Question 2 files -> Northern England’s set-jetting locations files -> Nstructions for Acquiring Excess Equipment online, through the 1033 Program files -> Occupational health and safety files -> The Black Panther Party’s Ten Point Program files -> International programs roel profile files -> Fermi Questions a guide for Teachers, Students, and Event Supervisors Lloyd Abrams, Ph. D. DuPont Company, cr&D/ccas experimental Station Wilmington, de 19880 files -> Personal Information Name: Maha Al-Ammari Nationality: Saudi Relationship Status Download 0.62 Mb. Share with your friends:
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