The information you need to submit perfect 504 packages

Transcription

1 The information you need to submit perfect 504 packages

2 Benefits of Centralized Processing What is e504? Benefits of e504 Submissions Screen outs 10 Most Common Errors in Using e504 Most common omissions from Temporary Debt Refinance Applications Top Two Hints for Avoiding Screen Outs Environmental Issues

3 Consistency 3 Day Turn-Around Increased Speed of Processing Applications

4 Automated document routing & tracking system 1,000 documents received per day Creates work orders for all departments without being touched by human hands

5 Faster turn-around No mailing time or costs Fewer screen outs

6 Clock stops Delays & Frustrations

7 Not completing the Electronic Credit Memorandum Not putting documents in the correct section Not submitting all documents

8 Not filling in the e504 number on resubmissions Forgetting the Screen Out Checklist Submitting a Screen Out Checklist when not required

9 Submitting environmental documents as other document types Not filling in the point of contact information in full loan submissions Not marking a pre-application submission as a pre-application Not scanning in black and white

10 Recorded copies of collateral documents Forbearance agreements (if applicable) Financials on EPC (if applicable)

11 Explain unusual events/issues Please proofread!!

12 Tips to Reduce Environmental Screen Outs

13 Submitting Environmental Investigations to SLPC Ensure the environmental submissions on CDs are properly labeled and in PDF format Ensure all appendices and attachments to the environmental assessment are submitted Ensure all scanned documents are legible

14 CDC Checklist for Submitting Environmental Investigation Ensure the CDC Checklist is included for all environmental document submittals Ensure the correct NAICS codes for the past and current use of the property is included on the CDC Checklist The CDC must provide comments and sign the CDC Checklist Ensure the CDC comments on the CDC Checklist match the environmental professional s recommendations and conclusions Provide the SBA Loan Number or the control number on the CDC Checklist If a 504 Loan is approved after pre-application, include the control number and/or SBA Loan Number so the documents can be associated with the pre-application file

15 Reliance Letters Any Transaction Screen (TSA), Phase I Assessment or Phase II Assessment must be accompanied by the SBA Reliance Letter and Certificate of Professional Liability Insurance Ensure the SBA Reliance Letter is not altered or modified Ensure the Certificate of Professional Liability Insurance with errors and omissions statement is submitted with the SBA Reliance Letter. Ensure the coverage period in the Certificate of Professional Liability Insurance includes the date of the environmental assessment. Ensure the SBA Reliance Letter has the same date as the TSA, Phase I Assessment or the Phase II Assessment

16 Address Changes If the addresses on the CDC Checklist and the environmental documents are different than the address on the loan authorization, please provide an explanation Submit a 327 form for an address change prior to submitting the environmental documents Resubmissions Send in the requested environmental documents not all documents Follow the instructions provided at the bottom of the environmental response from SLPC

17 Contamination Ensure all information- as stated in SOP 50-10(5) (E), Subsection G (Approval and Disbursement of Loans When There is Contamination or Remediation) - is submitted if requesting approval of funds with known contamination, on-going remediation, or monitoring on the property If there are contaminants on the property, get the environmental documents to SLPC as soon as possible SLPC will need concurrence by SBA District Counsel If the RSRA indicates elevated or high risk, conduct a Phase I Assessment not a Phase II Assessment

18 Environmental Professional Recommendations Recommendations by the environmental professional need to be completed before submission. Send in documentation such as contractor s receipts, etc Gas Station Loans In addition to a Phase I Assessment, gas station loans must include a determination by the environmental professional stating whether or not the gas station is in compliance with all state requirements, if any, pertaining to tank and equipment testing. Regular monitoring and inspection results do not meet this requirement

19 Environmental Questionnaire State the past and current use of the property and the adjoining properties in an Environmental Questionnaire (EQ) The EQ must be signed by the owner or operator of the site and the CDC. If the owner is unable or unwilling to sign the EQ and the property is not in an environmentally sensitive industry (ref Appendix 4 of SBA SOP 50-10(5)), then a Transaction Screen Analysis (TSA) is the minimum requirement for submission Environmental Appeals Committee Attach any SBA Environmental Appeals Committee decisions with the environmental submissions and resubmissions. All requests for an exception to SBA s SOP environmental policy must be sent to the SBA Environmental Appeals Committee at environmentalappeals@sba.gov

20 If you have any questions on environmental issues, send them to Be sure to check out our 504 Wiki Page at & our 504um Environmental Page at

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