CUNA Regulatory Comment Call

September 28, 2007

EXECUTIVE SUMMARY

• The Small Business Administration (SBA) is looking to redesign its standard 7(a) loan application form and re-engineer its standard 7(a) loan process for loans of $350,000 or less.
• The initial phase of this process is the redesign of SBA Form 4, Borrower Application, and SBA Form 4-1, Lender’s Application for Guaranty or Participation.
• Comments are due to the SBA by November 9, 2007. Please submit your comments to CUNA by October 26, 2007. Please feel free to fax your responses to CUNA at 202-638-7052 or e-mail them to CUNA SVP and Deputy General Counsel Mary Dunn at mdunn@cuna.com. You may also contact her at 800-356-9655, ext. 6736.
• You may access a copy of SBA’s notice and request for comment here.

DISCUSSION

• The SBA is beginning the process of redesigning its standard 7(a) loan application form and re-engineering its standard 7(a) loan process for loans of $350,000 or less, which will be processed through a centralized and highly automated and streamlined loan facility.
• As required by the Paperwork Reduction Act of 1995, the SBA is issuing this notice and request for comment on its intentions to seek approval on new and currently approved collection of information.
• The first phase of this process is the redesign of SBA Loan Form 4, Borrower Application, and SBA Form 4-1, Lender’s Application for Guaranty or Participation, initially for loans of $350,000 or less.
• There will ultimately be a tiered loan application process that will require less information for smaller loans and appropriately more information as the size and/or complexity of a loan increases.
• This redesign is intended to reduce the time and paperwork of lenders and applicants to prepare an SBA loan application.

1. The SBA is proposing to redesign its Borrower Application Form (SBA Form 4). Would you make changes to this form?
   a. Yes _____
   b. No _____
   If yes, what modification(s) do you suggest?
   
   

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2. The SBA is also proposing to redesign its Lender’s Application for Guaranty or Participation (SBA Form 4-1). Would you make changes to this form?
   a. Yes _____
   b. No _____
   If yes, what modification(s) do you suggest?
   
   

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3. Do you agree with SBA’s plan to implement a tiered loan application process that will require less information for smaller loans but more information from a borrower or lender as the size and/or complexity of a loan increases?
   a. Yes _____
   b. No _____
   Please explain why or why not.
   
   

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4. Please provide any additional comments.
   
   

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