Comment on FR Doc # E7-24381

Document ID: SBA-2007-0009-0006
Document Type: Public Submission
Agency: Small Business Administration
Received Date: January 30 2008, at 10:47 AM Eastern Standard Time
Date Posted: April 24 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: October 31 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: February 29 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 803a4eef
View Document:  View as format xml

This is comment on Proposed Rule

SBA Lender Oversight Program

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This communication is relative to the proposed rule, RIN 3245-AE14 relating to SBA lenderoversite. As the manager of the processing group at a large financial instiution, with close to $300MM in outstanding SBA loans, it is the Bank's belief that the fees being charged for off site as well as onsite reviews are outregous. As a preferred lender, enough faith should be instilled in the Bank that an on going offsite review is not needed. To date we've not seen where there has been any added benefit for these ongoing off site reviews. What the purpose of these is appears unknown, since what it comes down to is that in the event of a default, we would not be paid out if improperly closed. A recent onsite audit yielded a bill for $26,000, again an outrageous number for the services that were provided. If SBA continues on this path, financial institutions everywhere will be exiting this product arena as it will prove to be cost prohibitive going forward.

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