Advocacy

Reevaluate and Amend SBA’s Regulatory, Standard Operating Procedure (SOP), and Fee Waiver Policies

SBA’s sweeping rulemaking, SOP, and fee waiver policies over the past several years removed the prudent lending guardrails that are essential to protecting small business borrowers and preserving a low-cost access to capital program for all participants. These policies need to be reevaluated and, in many cases, amended to maintain programmatic integrity, and many helpful program elements that saw wholesale removal should be restored, such as the Franchise Directory and lenders’ Preferred Lender Program (PLP) status. (We understand that this revaluation process is underway at the Agency.)

Secure an Appropriate Authorization Level in Annual Funding Legislation

To ensure that 7(a) authorization remains available for borrowers throughout the entire Fiscal Year, appropriate annual authorization levels must be set and an ‘apportionment anomaly’ must be established in any Continuing Resolution (CR). These measures prevent either insufficient annual authorization or prorated CR caps that stifle authorization availability during a CR, both of which can cause uncertainty or even programmatic shutdowns.

Support Resources for the Office of Credit Risk Management

OCRM plays a vital role in maintaining programmatic integrity. Ensuring that OCRM maintains an appropriate set-aside for oversight activities in annual funding legislation, as well as other needed support and resources, is critical to keeping the program in good standing.

Pause Further Uncapped Small Business Lending Company (SBLC) Expansion

Existing SBLCs play a vital role in delivering access to capital—but unfettered expansion to an uncapped number of de novo SBLCs without increased oversight resources and regulatory oversight is not prudent.

Oppose Direct Lending Proposals in the 7(a) Program

Direct lending has been proven over the decades to be less effective, rife with fraud, and cost the government 10 to 15 times more than SBA’s loan guaranty programs, causing SBA to stop issuing direct business loans in the 1990s. Rather than the government pick winners and losers through direct lending, the 7(a) Loan Program’s private-sector driven model in which the nation’s lenders deliver the loans is a success story that cannot and should not be replicated by the government outside of disaster programs.

Preserve Lender Protections in Outstanding PPP Loans

There are still PPP loan guaranty purchase requests that are outstanding or have been denied. Borrowers are still making payments or even applying for forgiveness. And other PPP complications remain. The statutory protections afforded to lenders must be honored while these issues are resolved.