Dear Members –
NAGGL is acutely aware that lenders are continuing to struggle to implement the 7(a) program changes that took effect beginning in May with the implementation of the Final Rules, and culminating with the August 1 effective dates for SOPs 50 10 7, 50 56 1 and 50 57 3. We understand that as lenders, you are facing challenges with how best to navigate ambiguous and conflicting program guidance and how to provide answers to your borrowers. In turn, some of your borrowers are faced with real consequences as time-sensitive deals might get held up without any insight as to why. And NAGGL continues to hear from lenders their concerns about policy changes that might encourage imprudent lending practices. As you know from other member messages, our Capitol Sound Bites publications, and postings on NAGGL’s home page, over the past many months, NAGGL has been working on various fronts to accomplish two objectives with regard to these concerns.
First, on a longer-term basis, we have been working with the Congress and our trade association partners to seek legislation that would amend some of the recent policy revisions that NAGGL believes are not in the best interests of lenders, small business borrowers, and the 7(a) program, generally. Second, on a more immediate basis, we have been sharing with SBA our comments, concerns and suggestions regarding necessary clarifications and corrections to the policy guidance as it exists today.
As part of that second effort, in addition to the ad hoc comments that we have been providing to SBA on an ongoing basis, on August 27, NAGGL sent to the Office of Capital Access leadership team a detailed summary of the most pressing issues that had been identified by lenders regarding the recent program changes. That document, which I am attaching for your reference, was intended to provide critical lender feedback to SBA.
In the email transmitting the NAGGL issues summary, we asked SBA for a quick resolution to the outstanding program issues and specifically requested that any new guidance be provided either as technical updates versions of the issued SOPs or through formal notice(s) issued in accordance with SBA’s program guidance issuance requirements. While we have disagreed on the underlying policy issues, NAGGL expects and hopes that SBA would engage in discussions on the implementation strategies and provide lenders and borrowers what they deserve – clear and communicated guidance that does not harm our shared goal of access to capital. Right now, given the ambiguity and silence from SBA, lenders and borrowers find themselves in a state of uncertainty on numerous issues amid this implementation rollout.
As we wait for additional guidance from SBA, we ask that you continue to reach out to NAGGL by writing to [email protected] with your concerns and questions—it is through your feedback that we are able to best voice your concerns. And I would encourage you to monitor naggl.org for up-to-the-minute information on any program modifications issued by SBA and on the status of the proposed legislation affecting 7(a).
As always, I want to thank you for all that you do to make critically needed capital available to America’s small businesses. NAGGL’s goal remains what it always has been through our nearly 40-year history – to fully support those efforts and to ensure the long-term viability of the 7(a) program.
Tony Wilkinson
President & CEO
NAGGL
