Who approves an SBA Express loan, the lender or SBA?
Short answer
The lender does. Under SOP 50 10 8.1, Sec. B, Ch. 2, Para. C.2.b, the lender makes the credit decision without prior SBA review. SBA issues the loan number and can review the file later.
The lender approves an SBA Express loan. SOP 50 10 8.1, Sec. B, Ch. 2, Para. C.2.b says the lender makes the credit decision without prior SBA review.
What SBA does before closing
SBA Express loans run only through the lender's delegated authority (Para. C.1.b). The lender submits the guaranty request and SBA issues a loan number in the SBA Loan System (Sec. B, Ch. 6, Para. A.1). SBA does not review the lender's analysis of the credit or the loan structure before issuing that number.
What the lender must still show
- Credit analysis consistent with the lender's similar non-SBA loans (Para. C.2.b.i).
- Why credit is not available elsewhere on reasonable terms (Para. C.2.b.ii).
- A reasonable assurance of repayment (Para. C.2.b.iii).
- Compliance with the core eligibility rules in Section A of the SOP.
When SBA looks at the file
SBA reviews the lender's analysis when the lender asks SBA to purchase the guaranty, or during lender oversight (Para. C.1.b). It also reviews early loan defaults under SOP 50 57 (Para. C.2.b.v). If a lender failed to comply materially with SBA requirements, SBA can be released from its guarantee (13 CFR 120.524).
Credit policies vary by lender, so ask each lender what it requires.
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