The analysis of portfolio performance focuses on an evaluation of a lender’s SBA loan portfolio to assess historical, current and projected performance and to identify various risk characteristics of the portfolio. This analysis considers a lender’s performance compared to the portfolio, to SBA-defined peers, and to itself, over time (trends). While the criteria and procedures identified are not an exhaustive list and may be modified during review planning or on-site activities, they provide a reasonably complete list of the processes used to evaluate this category. The procedures are not mandated rules to be rigidly followed by the examiners. The lending business is a dynamic one, requiring examiners to use their judgment to tailor examination practices to individual situations. Examiners can add, delete and/or modify procedures as appropriate, with written approval of the AA/OLO or designee, when a lender’s particular circumstances and risk characteristics warrant. (Electronic mail is an acceptable means of obtaining the written approval of the AA/OLO or designee.) Any criteria not used in a particular review should be so identified in the Report, along with the reason for the change.
f. Examination Criteria – Portfolio Performance Subcomponent
13 CFR §120.410 requires that all participating lenders have a continuing ability to evaluate, process, close, disburse, service and liquidate small business loans. SBA assesses this ability, in part, through review criteria regarding portfolio performance, as described below. The criteria are not all inclusive and during the course of the review, additional criteria may be identified as well as certain criteria may be determined not to apply.
The purpose of the credit quality review is to establish a picture of the SBA Supervised Lender’s SBA portfolio risk characteristics using predictive credit scoring as the measure of credit risk. This allows SBA to predict purchases over a 12-24 month period. SBA aggregates the lender’s loan scores, analyzes the lender’s SBA loan credit quality and compares it to SBA’s portfolio and peer group performance.
The portfolio performance criteria are:
Loan production activity;
Key performance statistics and comparative performance analysis;
Credit quality; and
Any other risk characteristic(s) identified in the Plan.
g. Examination Objectives – Portfolio Performance Subcomponent
The objective of the Portfolio Performance review is to assess the performance of an SBA Supervised Lender’s SBA 7(a) loan portfolio and the demographics of the portfolio, and to determine whether SBA Supervised Lender is failing to meet any portfolio performance requirements based upon statute, SBA Loan Program Requirement or Notice.
h. Examination Procedures – Portfolio Performance Subcomponent
Procedures are provided as guidance in conducting each component Examination. The procedures are not an exhaustive list. They will be expanded and contracted or adapted as warranted, in SBA’s sole discretion, based on (i) the circumstances of the individual lender, particularly if there are program or operational changes, (ii) changes in economic conditions, or (iii) Agency policy changes.
The Portfolio Performance procedures are designed to analyze portfolio characteristics such as growth rates, performance, industry and geographical concentrations; determine whether the SBA Supervised Lender is meeting any portfolio performance requirements of SBA Loan Program Requirements or SOP; and assess portfolio credit quality (as measured through credit scores). The examination procedures include analysis and comparison of SBA and SBA Supervised Lender data.
Summary of Key Performance Statistics
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Identify the lender’s outstanding SBA portfolio and program composition.
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Analyze the lender’s portfolio composition, portfolio performance rates, and delivery method performance characteristics.
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Identify any significant variations, fluctuations or performance trends in the individual delegated loan programs for further assessment.
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Analyze lender’s Active Purchases to establish a basic picture of the outstanding loans which have been purchased but are still within the purview of the lender’s control.
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Identify any significant characteristics of the Active Purchases, or trends of increasing numbers, for further assessment.
Loan Production Activity
Analyze the annual production (numbers and dollars), delivery method break-down, average loan size, and discuss any trends or significant period-to-period fluctuations.
Comparative Performance Analysis
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Compare the SBA Supervised Lender’s SBA loan portfolio performance to overall SBA portfolio and peer group, and past trends of SBA Supervised Lender itself.
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Identify and analyze outstanding portfolio performance (in numbers and dollars) by loan payment status (e.g. current, delinquent, etc.) and delivery method, and in comparison to portfolio, program and peer group performance rates, as available.
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Identify and analyze any deviation of performance in SBA Supervised Lender’s portfolio or in any particular program as compared to the available standards (SBA portfolio and peer).
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Compare to past trends within lender itself.
Active Purchases
Identify and analyze the SBA Supervised Lender’s outstanding Active Purchases (in numbers and dollars) and trends over two fiscal years, as available.
Industry Concentration
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Identify and analyze industry concentration(s) within the SBA Supervised Lender’s portfolio, and risk implications; i.e. significant percentage of dollars in one or more industries.
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Compile a table of industry concentrations for loan portfolio (numbers and dollars).
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Compare to SBA portfolio and peer averages, if available.
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Analyze concentrations of 20% or more identifying the risk implications of such concentrations.
Geographic Concentrations
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Identify and analyze any geographical concentrations and risk impact; i.e. any current economic issues of the geography with positive or negative impact on the portfolio.
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Compile a table of geographic industry concentrations for loan portfolio (numbers, dollars and any available performance metrics.
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Compare to SBA portfolio and peer averages, as available.
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Analyze concentrations of 20% or more identifying the risk implications of such concentration.
Early Defaults
Identify early defaults and analyze risk implications (early default defined as default reported within 18 months of disbursement); i.e. sporadic versus trend evidence, etc.
Guaranty Purchases
Identify any trends in SBA Supervised Lender’s guaranty purchases. Consult available Agency data regarding SBA Supervised Lender’s purchase activity for both the past-one year and five-year periods.
Other Segmentation
Identify and analyze any other segmentation of the portfolio with risk implications, and compare to SBA portfolio and/or peer averages, as available.
Compile any other tables or presentation of data, as appropriate during the review investigation, and as available, compare to any available applicable standards.
Credit Quality
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Compare SBA Supervised Lender’s SBPS data to SBA’s portfolio and peer averages, and discuss risk implications; i.e. significant deviation from the SBA portfolio average, positive or negative trends, quarter-to-quarter and/or year-to-year fluctuations, etc.
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Analyze stratification of SBA Supervised Lender’s portfolio by credit score ranges and discuss proportions of predicted at-risk loans, both low and high, and risk implications; i.e. percentage of portfolio at high risk, trend over time, etc.
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Analyze Projected Purchase Rate (PPR), and compare to SBA portfolio and peer averages.
Other Risk Characteristics
Identify and analyze any other risk characteristics as noted in evaluations or other research.
Conclusion
Discuss all portfolio performance Findings with management.
Conclude on the portfolio performance of the SBA Supervised Lender.
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