Per SOP 50 10 7 (p. 13), beginning August 1, SBA now determines “whether the [loan] Applicant is eligible by requiring the Applicant to certify to certain program eligibility requirements and validating those certifications through a digital, real-time regulatory compliance framework. Lenders have made NAGGL aware that since that date, some loans input into E-Tran for SBA approval, under both delegated and nondelegated authority, have been withdrawn by SBA because of eligibility issues identified by the Agency.  It is our understanding that SBA has been working with lenders to resolve individual loan issues on a case-by-case basis. But, to date, the Agency has not provided comprehensive guidance on the specifics of the eligibility review process. 

However, SBA has established an email address where lenders can send questions relating to compliance code issues: [email protected].  And recent correspondence from that mailbox provides some guidance for checking and clearing compliance codes within E-Tran:

Checking Compliance Codes
If your file is showing a status of Withdrawn the following are steps to view compliance code checks that were issued:

1) Log into ETRAN > Origination and pull up your Application
2) Click on the menu labeled Application Info on the left-hand side 
3) Scroll to the bottom of the page to view Compliance Codes
4) Click on the dash within the Star Comments column to view additional detail

Clearing Compliance Check Codes
The Processing Centers can clear codes if lenders provide supporting documentation to mitigate the issuance of the compliance code.

1) After reviewing the issued Compliance Code and gathering supporting documentation to mitigate the findings, log into ETRAN and pull up your Application
2) If your loan status is in Withdrawn, upload supporting documentation via the Documents blue bubble and select Compliance Support Documents
3) Email the proper SBA processing center at [email protected] with the Application # and alerting them that documents have been uploaded to the Compliance Support Documents bucket for their review

NAGGL is hopeful that SBA will provide more formal guidance regarding the eligibility determination and the E-Tran Terms and Conditions processes, and to address various issues that need correction or clarification in SOPs 50 56 1, 50 10 7 and 50 57 3.  We will share information with members as we receive it.