What checks does an SBA lender run on your business?
Short answer
SBA lenders must check CAIVRS for federal debt problems, SAM.gov for exclusions and the OFAC sanctions lists, and follow customer identification rules. Trucking firms also get a USDOT check. Sources: SOP 50 10 8.1, Sec. A, Ch. 1, Paras. E, I, J; Ch. 4, Para. B.
In this answer, CAIVRS means Credit Alert Verification Reporting System and OFAC means Office of Foreign Assets Control.
SBA lenders must run several federal screens on top of credit review. SOP 50 10 8.1, Sec. A sets each one.
CAIVRS
The lender checks the Credit Alert Verification Reporting System for prior federal losses and delinquent federal debt. It keeps proof in the file (Ch. 1, Para. E).
SAM Exclusions
The lender searches SAM.gov for suspensions, debarments and exclusions. Searches cover the business and, depending on entity type, proprietors, partners, 20% owners, officers, directors and Key Employees (Ch. 4, Para. B, p. 60). Anyone excluded may not do business with SBA.
OFAC and customer identification
The lender must determine that the business and its owners are not on the Office of Foreign Assets Control (OFAC) sanctions lists at application (Ch. 1, Para. J, p. 39). It must also follow Treasury's customer identification rules at 31 CFR 1020.220 (Para. I).
Ownership
The lender certifies that no direct or indirect owner or required guarantor is an Ineligible Person (Ch. 1, Para. F, p. 28).
Trucking companies
If Federal Motor Carrier Safety Administration (FMCSA) requires a USDOT number, the lender must verify it in SAFER Web. The number must be active and in good standing, and the address must match the company's physical address (Ch. 4, Para. B).
Criminal history and taxes
Form 1919, question 4, covers the applicant and any Associate. SBA is authorized to verify criminal history (SBA Form 1919). The lender verifies tax filings through IRS transcripts (Ch. 5, Para. B).
Lenders add their own checks, which vary by lender.
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