SBA has issued Procedural Notice 5000-866054, Update to SOP 50 10 7.1 Section A, Chapter 5, Paragraph E, Environmental Policies and Procedures (effective March 20, 2025). The notice revises the guidance in SOP 50 10 7.1 relating to environmental requirements for loans processed on a nondelegated basis, excluding 7(a) Small Loans. The notice does not modify the Environmental Policies and Procedures for delegated processing of loans under PLP, SBA Express, Export Express, 7(a) Small Loans, or PCLP authority, except that environmental reports must be dated within one year of issuance of the SBA loan number.
Per the notice:
“For those loans being processed under delegated authority, and for all 7(a) Small Loans (regardless of whether processed non-delegated or delegated), SBA Lenders cannot seek SBA approval of the Environmental Investigation, but they may continue to contact [email protected] when relying solely upon SOP 50 10 7.1, Section A, Chapter 5, Paragraph E, 5.d.ix, “Other Factor(s)” for disbursement in the presence of Contamination.”
Under the new process, for loans being processed via non-delegated procedures (except 7(a) Small Loans) where environmental contamination is found, the legal review now will be handled by SBA district counsel. Please see the notice for complete details regarding the new process for these loans. Questions regarding SBA’s environmental requirements must be directed to: environmental [email protected].