Sba sop 51 00 On-Site Lender Reviews/Examinations Office of Lender Oversight


Objectives for Risk-Based Lender Reviews and Examinations



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3. Objectives for Risk-Based Lender Reviews and Examinations


SBA has three primary objectives for the on-site reviews/examinations it conducts on SBA Lenders: (i) To enhance SBA’s ability to gauge the overall quality of the SBA Lender’s 7(a) or 504 portfolio; (ii) To identify weaknesses in an SBA Lender’s SBA operations before serious problems develop that expose SBA to losses that exceed those inherent in a reasonable and prudent SBA loan portfolio, as periodically defined by statute, SBA Loan Program Requirement and/or Notice; and (iii) To ensure that prompt and effective Corrective Actions are taken, as appropriate.


Further, the on-site review/examination approach is designed to incorporate the following four management objectives:
Materiality: The on-site review process is designed to evaluate issues that represent program risk and material loan file guaranty risk to SBA. By way of example, such risks include but are not limited to the risks associated with an SBA Lender’s credit administration program for SBA lending and the determination of borrower eligibility;
Objectiveness: The on-site review process should be viewed as fair, objective and reasonable to all parties. There should be a determinable logic to the review components and the manner in which risks are evaluated;
Efficiency: The on-site review process is designed to minimize regulatory burdens on SBA Lenders and on SBA offices. On-site reviews are generally only conducted on SBA’s largest lenders ($10 million or more in SBA dollars outstanding) and at a frequency that corresponds with the risk characteristics of an individual lender (utilizing 12-24 month review cycles); and
Usefulness: The review should provide useful information for both SBA and SBA Lenders.

4. Approach to Risk-Based Lender Reviews and Examinations

SBA should oversee and monitor the financial performance, SBA loan operations, and regulatory compliance of SBA lenders to ensure the soundness of SBA’s business loan programs. Reviews and examinations foster effective, sound and reliable delivery of SBA loan programs. Each review involves three primary functional steps: (i) assessment, (ii) evaluation, and (iii) reporting.


Assessment – The review and analysis of pertinent data, documentation, and information on the SBA portfolio generated and serviced by the SBA Lender.

Evaluation – The determination as to the quality and management of an SBA Lender’s SBA loan operations.

Reporting – The submission of written results and oral presentation of findings and conclusions.
Risk-based principles provide the framework for review/examination policies. Application of these principles may result in considerable differences in the scope and depth of review/examination activity among individual SBA Lenders. SBA achieves efficient use of reviewer resources by limiting work in areas of minimal risk, and expanding resource commitments in areas expected to have substantial risk or potential additional risk. Review/examination activities are specifically tailored for each SBA Lender.
The scope of the review/examination is determined prior to commencing on-site activities, utilizing information and data from various sources, including previous Review Reports (RR) or Reports of Examination (ROE) (collectively “Reports”), portfolio performance data, and information provided by the SBA Lender. The on-site review/examination focuses on issues specific to an individual SBA Lender. These issues may vary from SBA Lender to SBA Lender depending upon an SBA Lender’s specific risk characteristics.

5. Relationship to Lender Oversight Program

The lender on-site review/examination process is part of a comprehensive program of lender oversight. Lender oversight activities are comprised of off-site monitoring/reviews, selective on-site reviews/examinations conducted in accordance with this SOP, and a series of graduated supervisory and enforcement actions used as appropriate and necessary.


At the heart of SBA’s lender oversight activities is the Agency’s L/LMS. L/LMS includes use of predictive small business credit scoring. All SBA small business loans with an outstanding balance and businesses with 504 debenture guaranties that have an outstanding balance are credit-scored quarterly. This data is aggregated, analyzed and evaluated to assess the credit quality of each individual SBA lender’s portfolio of SBA loans. It allows SBA to monitor and conduct off-site reviews of all SBA Lenders. It serves as the primary means of reviewing less active SBA Lenders (generally SBA Lenders with less than $10.0 million in SBA dollars outstanding) although SBA may determine at its discretion to conduct on-site reviews of these SBA Lenders depending upon their level of SBA lending activities and their performance. For SBA’s largest lenders, L/LMS provides performance data, both historical and projected: (i) for use in planning and conducting on-site reviews or examinations; (ii) to assist in prioritizing on-site reviews/examinations; and (iii) as a system to monitor SBA Lenders between on-site reviews/examinations.

6. On-Site Lender Review/Examination Program

OLO is responsible for selecting lenders to be reviewed or examined. Priorities for on-site reviews/examinations, though discretionary, are generally established based on an SBA Lender’s risk characteristics including portfolio performance (metrics and trends), credit risk as measured by credit scores, and/or occurrence and results of last lender review/examination. Other factors may also play a part in determining review priorities including referrals or requests from other SBA offices.


The review cycle includes the following activities: (i) Pre-review activities; (ii) on-site activities; (iii) Reporting of Findings; and (iv) Resolution of issues.
On-site lender review/examinations results may be used in determining an SBA Lender’s risk rating, establish recommendations for improvement in an SBA Lender’s SBA loan portfolio, and to assist in the evaluation of applications for, expansion of and/or renewal of delegated or other program authority. OLO is responsible for the on-site review and examination process including managing the on-site review and examination schedules, conducting on-site reviews and examinations, assessing performance, preparing the written Report, and following up with the SBA Lender to address weaknesses or deficiencies identified during the review or examination.



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