Like me, you’ve already reviewed SOP 50 10 7─patiently, and perhaps apprehensively. And like me, you’ve noticed the occasional inconsistencies. I know it from the lender emails coming in to us at JRB. Understand. Inconsistencies are not unexpected. So many changes: Eligibility, Credit Elsewhere, Guaranty Fees, Insurance Requirements, Change of Ownership─and more. Consistency in a document the size of the SOP is a challenge indeed.
I also know that, along with me, many lenders have shared with the SBA the places we have found to be inconsistent. From what I understand, SBA has listened. And we can look forward to SBA issuing technical corrections to the SOP in the next few weeks or so.
Now, let’s manage our expectations: The technical corrections will be just that. Technical. Don’t expect the SBA to change its regulations. And the effective date of SOP 50 10 7 is August 1, 2023, still weeks away. We can all appreciate the time SBA has given us to ask questions, identify potential issues, and gain clarity. Meanwhile, better keep SOP 50 10 6 handy, annotated with the regulatory changes already made.
The technical corrections to SOP 50 10 7 are in clearance at SBA which means they’ll likely come out any day now. And when they do, they’ll be posted on SBA’s website.
As always, we’re here to answer your questions about the new regulations so you and your teams will have a full understanding before August 1. And of course we’ll advise you of the technical corrections as they roll out.
Richard Jeffrey
Senior Associate
richard@jrbrunoassoc.com
www.jrbrunoassoc.com