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.
Comment on FR Doc # E7-24381
This is comment on Proposed Rule
SBA Lender Oversight Program
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