SBA OIG Audit Report 25-23 — Collection Efforts on Delinquent COVID-19 EIDLs

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U.S. SMALL BUSINESS ADMINISTRATION 
OFFICE OF INSPECTOR GENERAL 
SBA's Collection Efforts on 
Delinquent COVID-19 EIDLs 
Audit Report 
Report 25-23 
August 12, 2025 
 

 
 
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NOTICE: 
Pursuant to the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, 
Public Law 117-263, Section 5274, any nongovernmental organizations and business entities 
identified in this report have the opportunity to submit a written response for the purpose of 
clarifying or providing additional context as it relates to any specific reference contained herein. 
Comments must be submitted to AIGA@sba.gov within 30 days of the final report issuance date. 
We request that any comments be no longer than two pages, Section 508 compliant, and free 
from any proprietary or otherwise sensitive information. The comments may be appended to 
this report and posted on our public website. 
 

 
 
U.S. Small Business Administration 
Office of Inspector General 
EXECUTIVE SUMMARY 
SBA's Collection Efforts on Delinquent COVID-19 EIDLs 
(Report 25-23) 
What OIG Reviewed 
This report presents the results of our audit 
to determine the U.S. Small Business 
Administration’s (SBA) efforts to collect 
on delinquent Coronavirus Disease 2019 
(COVID-19) Economic Injury Disaster Loans 
(EIDL) with collateral and personal guarantors. 
As of December 18, 2024, SBA charged off 
over $47 billion in delinquent COVID-19 EIDLs 
without suspected or confirmed fraud. Less than 
1 percent of the original loan amounts were 
recovered during SBA’s liquidation process. 
Recoveries included, but were not limited to, 
payments made by the borrower during the 
liquidation process or due to the borrower’s 
business closure, payments made due to the 
death of the borrower or personal guarantor, 
and recoveries from bankruptcy proceedings. 
What OIG Found 
Opportunities existed for SBA to implement 
strategies to collect on delinquent COVID-19 
EIDLs as outlined in federal laws, standards, and 
agency policies. Specifically, the agency did not 
perfect its security interest on borrower deposit 
accounts, conduct post-default site visits, report 
all delinquent obligors to credit bureaus, or refer 
debts to the U.S. Department of Justice for 
litigation. 
When borrowers defaulted on COVID-19 EIDLs, 
SBA sought recovery by attempting to contact 
them and personal guarantors via automated 
demand letters, telephone calls, and emails. If 
borrowers and personal guarantors did not 
answer or respond to these attempts, or if 
they did not provide a collateral list, SBA 
abandoned the collateral and then charged off 
and referred the loans to the U.S. Department of 
the Treasury. 
By not maximizing collection efforts early in 
the delinquency process, before referring the 
loans to the U.S. Department of the Treasury, 
SBA reduced the likelihood of recovering the 
$47 billion in charged-off COVID-19 EIDLs 
because the ability to collect delinquent debts 
generally decreases as the debts become older. 
What OIG Recommended 
We recommended SBA conduct a study to 
determine the minimum loan dollar thresholds 
for performing site visits, implement policies and 
procedures based the results of that study, and 
ensure post-default site visits are conducted and 
available collateral is liquidated on delinquent 
COVID-19 EIDLs; verify that all delinquent 
COVID-19 EIDL obligors are reported to credit 
bureaus in a timely manner; and confer with 
the U.S. Department of Justice to establish a 
reasonable standard for referring delinquent 
COVID-19 EIDLs for litigation. 
Agency Response 
SBA management agreed with one 
recommendation and disagreed with two. 
Management’s planned action to add 
functionality to the agency’s loan servicing 
system to allow for tracking of credit bureau 
submissions resolved Recommendation 2. 
Management’s response did not resolve 
Recommendations 1 and 3; therefore, we will 
seek resolution in accordance with our audit 
follow-up policy.

OFFICE OF INSPECTOR GENERAL 
U.S. SMALL BUSINESS ADMINISTRATION 
MEMORANDUM 
409 Third St. SW, Washington, DC 20416  •  (202) 205-6586  •  Fax (202) 205-7382 
Date: 
August 12, 2025 
To: 
Kelly Loeffler 
Administrator 
From: 
Sheldon Shoemaker 
Deputy Inspector General 
Subject: 
SBA’s Collection Efforts on Delinquent COVID-19 EIDLs (Report 25-23) 
This audit report presents the results and findings of our review of SBA’s collection efforts 
on delinquent Coronavirus Disease 2019 Economic Injury Disaster Loans. We considered 
management’s comments on the draft of this report when preparing the final report. SBA 
management agreed with Recommendation 2 and disagreed with Recommendations 1 and 3. 
We appreciate the cooperation and courtesies provided by your staff. If you have any questions 
or need additional information, please contact me or Andrea Deadwyler, Assistant Inspector 
General for Audits, at (202) 205-6586. 
 
 
cc: Bill Briggs, Deputy Administrator, Office of the Administrator 
 
Wesley Coopersmith, Chief of Staff, Office of the Administrator 
Ben Grayson, Deputy Chief of Staff, Office of the Administrator 
Robin Wright, Chief Operating Officer, Office of the Administrator 
Wendell Davis, General Counsel, Office of General Counsel 
Michael Simmons, Attorney Advisor, Office of General Counsel 
Nathan Davis, Chief Financial Officer and Chief Risk Officer, Office of Performance, Planning, 
and the Chief Financial Officer 
Deborah Chen, Deputy Chief Financial Officer, Office of Performance, Planning, and the 
Chief Financial Officer 
Sharon Kirkley, Accountant, Office of Performance, Planning, and the Chief Financial Officer 
Anna M. Calcagno, Director, Office of Strategic Management and Enterprise Integrity 
Alex H. Wilson, Senior Policy Advisor, Enterprise Risk Management 
Thomas Kimsey, Associate Administrator, Office of Capital Access 
Peter Meyers, Senior Advisor, Office of Capital Access 
Aaron Wright, Program Analyst, Office of Capital Access and Office of Financial Program 
Operations

 
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Contents 
Introduction .................................................................................................................................... 1 
Background ............................................................................................................................... 1 
Borrower Security and Personal Guaranties ....................................................................... 2 
Liquidation ........................................................................................................................... 3 
Collection Requirements ..................................................................................................... 3 
Objective ................................................................................................................................... 4 
Results ............................................................................................................................................. 4 
Finding: SBA Could Have Employed Additional Tools to Maximize Collections on 
COVID-19 EIDLs ...................................................................................................................... 5 
Perfecting Security Interest in Borrower Deposit Accounts ................................................ 7 
Conducting Post-Default Site Visits ..................................................................................... 8 
Recommendation ...................................................................................................................... 9 
Reporting Delinquent Obligors to Credit Bureaus ............................................................... 9 
Recommendation .................................................................................................................... 10 
Referring Delinquent Loans to the U.S. Department of Justice for Litigation ................... 11 
Recommendation .................................................................................................................... 12 
Evaluation of Agency Response ..................................................................................................... 12 
Summary of Actions Necessary to Close the Recommendations ............................................ 12 
Appendices 
1 Scope and Methodology ................................................................................................ 1-1 
2 Additional Information ................................................................................................... 2-1 
3 Agency Response ............................................................................................................ 3-1 

 
1 
Introduction 
This report presents the results of our audit to determine the U.S. Small Business 
Administration’s (SBA) efforts to collect on delinquent Coronavirus Disease 2019 (COVID-19) 
Economic Injury Disaster Loans (EIDL) with collateral and personal guarantors. Collateral is 
defined as item(s) pledged by a borrower as security for repayment of a loan, subject to possible 
collection in the event of default. A personal guarantor is one who assumes responsibility for 
payment of a debt if the person(s) or concern primarily liable fails to pay. 
Background 
In March 2020, the Coronavirus Preparedness and Response Supplemental Appropriations Act 
deemed the COVID-19 pandemic a disaster under section 7(b) of the Small Business Act and 
authorized SBA to issue COVID-19 EIDLs to affected businesses. The Coronavirus Aid, Relief, 
and Economic Security Act subsequently established criteria for small businesses to obtain 
COVID-19 EIDLs and provided initial funding for these loans. From March 2020 to May 2022, 
SBA approved nearly 4 million COVID-19 EIDLs totaling almost $387 billion. 
As of December 18, 2024, SBA charged off 369,588 COVID-19 EIDLs with original loan 
balances exceeding $25,000, totaling over $47 billion, and is attempting to collect on an 
additional 96,745 COVID-19 EIDLs, totaling $14.7 billion, that have been delinquent for 
90 days or more.1 Charge-off is an administrative action taken by SBA after all reasonable 
efforts to achieve recovery have been exhausted, thus ending active collection. After 
charge off, the loan and remaining obligors must be referred to the U.S. Department of the 
Treasury (Treasury) for inclusion in the Cross-Servicing program unless further collection is 
barred by a valid legal defense such as compromise, discharge in bankruptcy, or the statute of 
limitations. 
 
 
 
1 These figures exclude loans with confirmed or suspected fraud. 

 
2 
Borrower Security and Personal Guaranties 
Depending on the loan amount, SBA required borrowers to pledge collateral and sign personal 
guaranties to secure COVID-19 EIDLs as follows: 
• $0–$25,000: No collateral or personal guaranty required 
• $25,001–$200,000: Blanket lien on business assets 
• $200,001–$500,000: Blanket lien on business assets and a personal guaranty2 
• $500,001–$2,000,000: Blanket lien on business assets, a personal guaranty, and a best 
available mortgage on real estate owned by the applicant business if available 
SBA policy states that collateral requirements are established based on a balance between 
protection of the agency’s interest as a creditor and as a provider of disaster assistance. Further, 
SBA will not decline a loan for lack of collateral but requires the applicant to pledge the collateral 
the agency has determined is available. 
Additionally, SBA required personal guaranties from individuals or entities owning 20 percent or 
more of the applicant’s business for all COVID-19 EIDLs exceeding $200,000. Personal guaranties 
are an unconditional obligation to pay the full amount of the loan upon the agency’s written 
demand for payment. Because the guaranties were not secured with collateral, SBA was limited 
in its ability to collect from personal guarantors and could only pursue them for repayment of 
the delinquent loan. SBA cannot file litigation activities independent of the U.S. Department of 
Justice (DOJ). 
Blanket Liens 
Instead of taking out liens on specific assets owned by a business, SBA chose to use blanket liens 
on COVID-19 EIDLs over $25,000. The blanket liens provided the agency the right to take 
possession of the borrower’s assets upon default, such as inventory, equipment, and any other 
tangible or intangible property owned by a business. To create the blanket lien, SBA and the 
borrower signed a security agreement that granted the agency a security interest in all the 
property described in that agreement. SBA perfected these blanket liens by filing a Uniform 
Commercial Code (UCC) financing statement in the relevant state offices. However, in cases in 
which the debtor disputed the default, SBA may have had to file a suit to gain possession of the 
collateral. 
 
2 No personal guaranty is required for nonprofit organizations or employee stock ownership plans. 

 
3 
Real Estate 
SBA required real estate as collateral, if available, on COVID-19 EIDLs over $500,000. If a business 
did not own real estate, the agency would not decline the loan for that reason alone. Of the 
58,024 COVID-19 EIDLs exceeding $500,000, only 4,718 were secured with real estate. These 
loans had a much lower default rate than loans not secured with real estate. As of July 2024, 
only five loans secured with real estate have defaulted, and there have been no completed 
foreclosures of real estate used as collateral for COVID-19 EIDLs. 
Liquidation 
Liquidation is the process of converting collateral to cash to pay all or a portion of a debt. Once 
all reasonable efforts have been exhausted to achieve recovery from liquidation, loans are 
charged off. According to SBA policy, loans should be placed in liquidation status or charged off 
at 90–110 days past due. However, according to SBA officials, that policy was updated beginning 
on September 11, 2023, and COVID-19 EIDLs in liquidation were charged off at or approximately 
120 days past due. This policy was again changed on March 11, 2024, when COVID-19 EIDLs in 
liquidation were charged off at, or approximately, 180 days past due. 
Collection Requirements 
The Debt Collection Improvement Act of 1996 (DCIA) requires agencies to maximize collections 
of delinquent debt by ensuring quick action to enforce recovery of debts and use of all 
appropriate collection tools. The DCIA also requires Treasury to pursue delinquent debts that 
are not actively being collected by federal agencies. Further, the DCIA and Digital Accountability 
and Transparency Act of 2014 require agencies to refer debts no later than 120 days delinquent 
to the Treasury Offset Program (TOP) and debts 180 days or more delinquent to the Treasury 
Cross-Servicing program. 
TOP is a centralized offset program that withholds money payable by the federal government to 
a person or entity to satisfy a debt the person or entity owes. The types of federal payments 
eligible for offset include, but are not limited to, Internal Revenue Service tax refunds, 
retirement payments issued by the Office of Personnel Management, and federal salary 
payments. The Cross-Servicing program uses a variety of tools to collect debts, including but 
not limited to, sending demand letters, calling debtors, referring debts to the DOJ for litigation, 
reporting debts to credit bureaus, and referring debts to private collection agencies. 

 
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Federal Claims Collection Standards, 31 Code of Federal Regulations (CFR) Chapter IX, § 901.1, 
also requires federal agencies to promptly and aggressively collect all debts arising out of 
activities of that agency. Office of Management and Budget Circular No. A-129, “Policies for 
Federal Credit Programs and Non-Tax Receivables,” states that agencies shall promptly act 
on the collection of delinquent debts by using all available collection tools to maximize 
collections. Also, according to Treasury’s “Managing Federal Receivables” guide, an agency 
has the affirmative responsibility to try to collect delinquent debts that are owed to the 
agency or referred to the agency for collection. Further, an agency fulfills its affirmative 
responsibility to try to collect delinquent debts by engaging in active collection. Active 
collection means that the debt is being collected using all appropriate debt collection 
remedies including, but not limited to, sending written demand letters, reporting debts to 
credit bureaus, offset, garnishment, foreclosure, litigation, and referral to the Treasury 
Cross-Servicing program. 
Federal law exempts agencies from the obligation to refer debts to Treasury for offset 
and cross-servicing when the debt is in litigation or foreclosure. However, in April 2024, 
Treasury granted SBA a 2-year exemption from referring all delinquent COVID-19 EIDLs to 
cross-servicing regardless of dollar value or litigation status. Due to this exemption, all 
delinquent COVID-19 EIDLs that SBA had already sent to Treasury for cross-servicing were 
returned for SBA to service through March 31, 2026. Notwithstanding the exemption from 
referring delinquent COVID-19 EIDLs to cross-servicing, SBA must still refer these debts to TOP 
for offset. 
Objective 
Our objective was to determine SBA’s efforts to collect on delinquent COVID-19 EIDLs with 
collateral and personal guarantors. 
Results 
We found that SBA could have maximized collections and more aggressively collected on 
delinquent COVID-19 EIDLs by employing appropriate debt collection tools prescribed by 
federal laws, standards, and agency policies. Specifically, the agency did not perfect its security 
interest on borrower deposit accounts, conduct post-default site visits, report all delinquent  
 
 

 
5 
obligors to credit bureaus, or refer debts to the DOJ for litigation. As a result, SBA charged off 
369,588 COVID-19 EIDLs totaling over $47 billion, which is 98 percent of the original loan 
amounts. 
Finding: SBA Could Have Employed Additional Tools to 
Maximize Collections on COVID-19 EIDLs 
SBA did not maximize collections by using all appropriate collection tools to aggressively collect 
delinquent COVID-19 EIDL debt from borrowers and personal guarantors before referring 
loans to Treasury. According to the DCIA Federal Claims Collection Standards and Treasury’s 
“Managing Federal Receivables” guide, collection activities include, but are not limited to, 
sending written demand letters, liquidating collateral, reporting debts to credit bureaus, 
litigation, and after charge off, referring defaulted debts to two programs at Treasury: Cross-
Servicing and TOP. Further, Treasury’s guide also states that agencies’ debt collection strategies 
should promote the resolution of delinquencies as quickly as possible because the ability to 
collect delinquent debts generally decreases as the debts become older. Therefore, SBA is 
missing opportunities to maximize collection efforts by not exhausting all collection efforts 
available before referring delinquent loans to Treasury. 
In general, when borrowers defaulted on COVID-19 EIDLs, SBA sought recovery by attempting to 
contact borrowers and personal guarantors via automated demand letters, telephone calls, and 
emails. If SBA was unable to contact the borrower, or if they contacted the borrower but the 
borrower stated they did not have any collateral, the agency added a note in the loan file 
stating that the borrower failed to respond to all collection efforts. Thus, all collateral would be 
abandoned or acknowledged as lost, all liquidation efforts would be exhausted, and the loan 
would be charged off and referred to Treasury. 
If the borrower did have collateral to be liquidated, SBA stated the agency would pursue the 
collateral if its recoverable value was greater than $100,000. However, if the borrower provided 
a list of available business assets that SBA determined was valued at $100,000 or less, the agency 
would subsequently charge off the delinquent COVID-19 EIDL before referring it to Treasury. 
According to SBA Standard Operating Procedure 50 52 2, “Disaster Loan Servicing and 
Liquidation,” liquidation activities include, among other potential actions, voluntary sale of 
collateral by the borrower, UCC sale by SBA, judicial foreclosure of personal property, voluntary 
payments, and litigation. However, it appears the agency is bypassing its responsibility to 
perform these liquidation activities on a majority of delinquent COVID-19 EIDLs before referring 

 
6 
the loans to Treasury, as 88 percent of the 369,588 charged-off loans totaling more than 
$47 billion were in liquidation status for an average of only 3 days (see Appendix 2, Table 2-1). 
For example, we identified two loans, one totaling $2 million and another totaling $500,000, that 
each entered and exited the liquidation stage on the same day and had no documentation to 
indicate that liquidation activities were performed other than automated telephone calls and 
demand letters. In contrast, loans that were paid in full through collection (usually borrower or 
estate voluntary actions) were in liquidation an average of 67 days. 
Generally, we found SBA has primarily recovered on delinquent loans when: 
• The agency filed probate claims after being notified of a deceased obligor, 
• Borrowers initiated contact with the agency to request a release of collateral due to the 
sale of their business, 
• Borrowers informed the agency of a business closure, or 
• Borrowers notified the agency that they were in litigation, primarily bankruptcy. 
To illustrate SBA’s lack of aggressive debt collection, we identified a $2 million COVID-19 EIDL 
the agency charged off. A note in the loan file stated, “Borrower has failed to respond to all 
collection efforts (including telephone calls and demand letters), and no further collection effort 
is possible. UCC shows SBA as lienholder. With approval of this action, all collateral will be 
abandoned or acknowledged as lost, and all liquidation efforts toward maximum recovery will 
be exhausted.” SBA charged off and referred this loan to Treasury even though the agency had in 
fact been in contact with the borrower that same day. There was no evidence in the loan file 
to indicate the agency inquired about available collateral, the borrower stated there was no 
available collateral, or that SBA referred this $2 million debt to the DOJ for litigation. Further, 
there are many discussions on public forums regarding SBA’s collection efforts or the lack 
thereof. These discussions highlight the agency’s inaction on debt collection and can be 
influential in encouraging borrowers not to pay COVID-19 EIDLs. 
When compared to commercial banks, COVID-19 EIDLs have a delinquency rate that is almost 
five times higher than the industry norm. As of December 18, 2024, SBA charged off and did 
not recover more than $47 billion of COVID-19 EIDLs. Less than 1 percent of the original 
loan amounts that were recovered by SBA during liquidation included, but were not limited 
to, payments made by the borrower during the liquidation process or due to the borrower’s 
business closure, payments made due to the death of the borrower or personal guarantor, and 
recoveries from bankruptcy proceedings. 

 
7 
Through debt collection tools cited in laws, regulations, and agency policies, SBA could have 
better protected taxpayers’ interests and maximized collections before referring delinquent 
COVID-19 EIDLs to Treasury by: 
• Perfecting its security interest on borrower deposit accounts, 
• Conducting post-default site visits, 
• Reporting all delinquent obligors to credit bureaus, and 
• Referring debts to the DOJ for litigation. 
Perfecting Security Interest in Borrower Deposit Accounts 
While SBA filed UCC financing statements with the appropriate Secretary of State that listed 
borrower deposit accounts as collateral, the agency did not perfect its security interest in those 
accounts. Perfection of a security interest involves the secured party taking additional steps 
to ensure priority over other parties who have not yet perfected their interests regarding 
collateral. By not perfecting its security interest in borrower deposit accounts at the time of 
loan origination, SBA was unable to instruct banks to apply funds in borrower deposit accounts 
to the COVID-19 EIDL loan balance upon borrower default. 
SBA Standard Operating Procedure 50 52 2 states that cash in a borrower’s deposit account 
should be applied to their disaster loan balance in compliance with UCC § 9-607, “Collection and 
Enforcement by Secured Party,” and the terms of any applicable control agreement. However, 
according to UCC provisions, perfecting SBA’s security interest in borrower deposit accounts 
requires an additional step the agency did not perform. That step was for SBA to execute a 
written control agreement among the borrower, bank, and SBA to ensure the bank would 
comply with SBA’s instructions to direct disposition of the funds in the account without further 
consent by the debtor. 
SBA stated that obtaining a control agreement would have greatly increased the time it took to 
close and disburse COVID-19 EIDLs, conflicting with the intent and spirit of the statutory and 
policy changes made to the EIDL program. The agency also stated that, in many cases, depository 
institutions were reluctant to execute a control agreement because it required extensive legal 
review and back-and-forth discussions on a case-by-case basis. Furthermore, the agency 
speculated that when a borrower defaulted on a loan, there would be no cash left in the deposit 
account. SBA did not provide any documentation supporting these assertions. 
 
 

 
8 
Had SBA perfected its security interest in borrower deposit accounts, the agency might have 
recovered some of the loan debt. However, because the agency’s practice was to not perfect its 
security interest in borrowers bank accounts, SBA was unable to apply cash in borrower deposit 
accounts to the delinquent loan balance. As a result of not utilizing this as a tool to maximize 
collections, SBA was not protecting the taxpayers’ interests. 
SBA is no longer accepting new applications, requests for increases, or reconsiderations of 
denied loan applications for the COVID-19 EIDL program. Therefore, borrowers and banks 
would have little incentive to sign an agreement to perfect the security interest on the deposit 
accounts because the borrowers have already received loan proceeds. Consequently, the Office 
of Inspector General is not recommending SBA pursue perfection of its security interest on 
borrower deposit accounts for COVID-19 EIDLs. 
Conducting Post-Default Site Visits 
According to SBA policy that was in effect during the scope of our review, once a loan 
was classified as being in liquidation, prudent action should have been taken to avoid loss or 
dissipation of collateral. While not explicitly required by agency policy, a post-default site 
visit was suggested as an example of such an action. A post-default site visit is a personal visit 
to inspect and verify the current condition and use of collateral and should be made when 
warranted by prudent lending practices. A prudent lending practice is based on sound 
judgment to protect federal and lender interests. SBA policy also provides that circumstances 
prompting a post-default site visit may include situations in which the agency received notice 
of any matter that may affect the value of the collateral and SBA’s ability to maximize 
recovery. 
SBA did not conduct post-default site visits for COVID-19 EIDLs to inspect and appraise collateral 
available for liquidation to recover the debt. Agency officials stated that, in most cases, a blanket 
lien on business assets has little value, and the cost of selling the assets outweighs the cost of 
recovery. As a result, when borrowers defaulted on COVID-19 EIDLs, the agency did not conduct 
post-default site visits to identify available collateral and its value for liquidation. Rather, SBA 
tried to contact borrowers and personal guarantors via automated telephone calls, demand 
letters, and emails. If borrowers did not answer or respond to the agency’s contact attempts or, 
if contacted, provided a list of assets that SBA valued at $100,000 or less, the agency abandoned 
the collateral and charged off the loan before referral to Treasury. 
This approach differs from SBA’s 7(a) loan program, which provides loan guaranties to lenders 
for small business loans. For the 7(a) loan program, the agency requires lenders to perform  

 
9 
site visits within 15 to 60 calendar days depending on the type of default. This requirement 
reflects prudent lending practices. SBA does not have an established site visit timeline for 
COVID-19 EIDLs. 
Because SBA did not obtain a list of available assets at loan origination on the blanket liens, 
the agency did not know what assets, if any, the borrower had to liquidate. In some cases, 
the delinquent borrower sold assets without SBA’s knowledge or approval. In other cases, if 
landlords contacted SBA about assets abandoned by their tenant/SBA loan borrower, the agency 
did not conduct a site visit. Instead, SBA disclaimed all interest in the assets if the landlord was 
willing to provide a description, value, and find a buyer of the tangible assets. 
Had the agency conducted post-default site visits, unapproved sales of assets could have 
been prevented; borrower-abandoned assets could have been liquidated; existing assets for 
delinquent borrowers could have been identified, appraised, and liquidated as appropriate; and 
proceeds could have been applied to the delinquent loan balance. 
Recommendation 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to: 
Recommendation 1: Conduct a study to establish minimum loan thresholds for performing site 
visits, implement policies and procedures based the results of that study, and perform site visits 
to help facilitate appropriate liquidation of collateral on defaulted COVID-19 EIDLs in an effort to 
maximize collections. 
Reporting Delinquent Obligors to Credit Bureaus 
SBA did not provide evidence that it had reported all delinquent COVID-19 EIDL obligors to 
credit bureaus. Treasury’s “Managing Federal Receivables” guide requires agencies to report 
delinquent borrowers and personal guarantors to credit bureaus. DCIA and Federal Claims 
Collection Standards also state the agency shall report delinquent debts to credit bureaus. In 
addition, the DCIA states that a person may not obtain any federal financial assistance in the 
form of a loan (other than a disaster loan) or loan insurance or guarantee if that person has an 
outstanding debt that is in delinquent status with any federal agency. 
SBA guidance states that the agency’s collection efforts are subject to the requirements of the 
DCIA. Further, Office of Management and Budget Circular A-129 states that agency servicing 

 
10 
systems must be able to identify and refer debts to credit bureaus in accordance with the 
requirements of 31 U.S.C. § 3711 and that there is no minimum dollar threshold for such 
reporting. 
SBA takes steps to meet these requirements by submitting commercial (i.e., business) and 
consumer (i.e., individual) reports to credit bureaus monthly. Whether a delinquent obligor gets 
reported on the commercial or consumer report is determined based on the business structure. 
If the obligor is a business or sole proprietor with an Employer Identification Number (EIN),3 they 
would be reported on the commercial report. If the obligor is a sole proprietor with no EIN, 
an individual contractor, a self-employed individual, or is a personal guarantor on a loan of 
$200,000 or more, they would be reported on the consumer report. As of December 2024, SBA 
did not provide evidence that it had reported 832,930 (or 95 percent) obligors on delinquent 
COVID-19 EIDLs to credit bureaus. SBA relied on an automated system to report delinquent loans 
to credit bureaus but did not prove the agency had procedures to verify all delinquent borrowers 
and personal guarantors were reported. By not ensuring proper credit bureau reporting of 
delinquent COVID-19 EIDL debt, SBA is not providing potential lenders, including federal 
agencies, critical information needed to assess borrower and personal guarantor eligibility and 
creditworthiness for future loans. 
Recommendation 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to: 
Recommendation 2: Verify all delinquent COVID-19 EIDL obligors are reported to credit bureaus 
in a timely manner. 
 
 
 
3 An EIN is a federal tax identification number for businesses, tax-exempt organizations, and other entities that have 
employees; will need to pay employment, excise or alcohol, tobacco, and firearms taxes; or withhold taxes on 
income, other than wages, paid to a nonresident alien. A sole proprietor may have an EIN even though they do not 
have any employees; however, sole proprietors with EINs are treated as businesses rather than individuals for credit 
bureau reporting purposes. 

 
11 
Referring Delinquent Loans to the U.S. Department of Justice for Litigation 
SBA did not refer delinquent COVID-19 EIDLs, regardless of amount, to the DOJ for litigation to 
collect against borrowers and personal guarantors as required by the Federal Claims Collection 
Standards. Instead, the agency relied on the Treasury Cross-Servicing program to refer these 
loans to the DOJ, thereby missing a vital opportunity to recover funds. 
31 CFR Part 904, “Referrals to the Department of Justice,” requires agencies to promptly refer 
delinquent debts on which aggressive collection activity has been taken and that cannot be 
compromised, or on which collection activity cannot be suspended or terminated, to the DOJ for 
litigation. Further, these standards state that agencies shall make every effort to refer delinquent 
debts to the DOJ for litigation within 1 year of the date such debts last became delinquent. 
Treasury’s “Managing Federal Receivables” guide states that only in limited circumstances 
should the agency delay referral to a time when less than 1 year remains on the applicable 
statute of limitations for litigation. The guide also states that the agency may elect to refer a 
delinquent debt to the DOJ for litigation before referring the debt to cross-servicing or pursuing 
other administrative debt collection activities. 
According to SBA, the agency does not pursue litigation unless it is cost effective and necessary 
to enforce collection. SBA cannot file litigation activities against borrowers and/or personal 
guarantors independent of the DOJ because SBA does not have litigating authority. Further, SBA 
stated it does not refer delinquent loans to the DOJ because Treasury’s Cross-Servicing program 
does. However, in fiscal year 2023, Treasury only sent 8654 debts to the DOJ for litigation. 
As previously stated, Treasury’s guide states that agencies should promote the resolution of 
delinquencies as quickly as possible because the ability to collect delinquent debts generally 
decreases as the debts becomes older. It is in the taxpayers’ best interest for SBA to refer 
delinquent debts to the DOJ rather than wait for Treasury to do so. Because Treasury has 
returned delinquent COVID-19 EIDLs from Cross-Servicing to SBA for servicing until March 31, 
2026, SBA has an opportunity to refer delinquent COVID-19 EIDLs to the DOJ for litigation. 
By not referring any COVID-19 EIDL debt to the DOJ for litigation, SBA is not exhausting all 
collection strategies to minimize delays and maximize recovery from borrowers and personal 
guarantors before referring the delinquent loans to Treasury. 
 
4 This figure was reported in the DOJ’s Fiscal Year 2023 Annual Civil Debt Collection Activity Report to Congress and 
includes all debts referred from the entire Treasury, not just the Cross-Servicing program, and it is also not limited to 
COVID-19 EIDLs. 

 
12 
Recommendation 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to: 
Recommendation 3: Confer with the DOJ to establish a reasonable standard for referral of 
delinquent COVID-19 EIDLs to the DOJ for litigation. 
Evaluation of Agency Response 
SBA management provided formal written comments that are included in their entirety 
in Appendix 3. Management agreed with Recommendation 2 and disagreed with 
Recommendations 1 and 3. 
Summary of Actions Necessary to Close the Recommendations 
The following section summarizes the status of our recommendations and the actions necessary 
to close them. 
Recommendation 1 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to conduct a study to establish minimum loan thresholds for performing site visits, 
implement policies and procedures based on the results of that study, and perform site visits to 
help facilitate appropriate liquidation of collateral on defaulted COVID-19 EIDLs in an effort to 
maximize collections. 
Status: Unresolved 
SBA management disagreed with this recommendation, stating that the UCC liens on disaster 
loans are not purchase money liens, so the agency takes a best available on the business assets. 
Further, since SBA UCC liens, in most cases, are subordinate to existing and future purchase 
money and blanket UCC liens, the liquidated value of property other than real estate for a 
subordinate creditor would be negligible or nonexistent. Also, the inherent value in taking a 
general best available security interest in these circumstances is for the debt to be on record 
such that it will require SBA to be notified regarding sale, transfer, or bankruptcy/reorganization 
of the business, which may allow for future recoveries without requiring SBA to bear the cost of 
a foreclosure/liquidation of assets. Moreover, conducting site visits across the COVID-19 EIDL 

 
13 
portfolio is a manual, resource-intensive process and does not generally establish data 
relevant to determining recovery. Therefore, SBA does not consider the cost of a site visit to 
beneficially impact liquidation outcomes. According to SBA management, SBA Standard 
Operating Procedure 50 52 does not require a site visit for every loan classified in liquidation 
but may be required if SBA determines real estate foreclosure is appropriate. 
This recommendation is unresolved. SBA management’s response does not specifically address 
the recommendation to conduct a study to establish minimum thresholds for performing site 
visits. The agency has not provided evidence to support the assertion that the liquidated value of 
non-real estate property is negligible or nonexistent, site visits do not establish data relevant to 
determining recovery, or that the cost of a site visit is not beneficial to liquidation outcomes. 
Further, while Standard Operating Procedure 50 52 2 does not require a site visit, it does state 
that conducting site visits is a prudent lending practice. Additionally, SBA’s 7(a) loan program 
requires lenders to perform site visits within 15 to 60 calendar days depending on the type of 
default. 
The intent of this recommendation was not to require post-default site visits for every defaulted 
COVID-19 EIDL, but for SBA to conduct a study to determine the point at which performing a site 
visit becomes cost beneficial, and to implement policies to ensure site visits are completed to 
maximize collections. We will continue to seek resolution of this recommendation in accordance 
with our audit follow-up policy. 
Recommendation 2 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to verify all delinquent COVID-19 EIDL obligors are reported to credit bureaus in a timely 
manner. 
Status: Resolved 
SBA management agreed with the recommendation, stating that the agency will add 
functionality to the ETRAN system to log time/date entries for credit bureau submissions to 
allow for tracking of these submissions. 
This recommendation will be closed once management provides evidence that they 
implemented the changes to the ETRAN system and appropriately reported all delinquent 
COVID-19 EIDL obligors to credit bureaus. 
 
 

 
14 
Recommendation 3 
We recommend the Administrator direct the Associate Administrator for the Office of Capital 
Access to confer with the DOJ to establish a reasonable standard for referral of delinquent 
COVID-19 EIDLs to the DOJ for litigation. 
Status: Unresolved 
SBA management disagreed with the recommendation, stating that the DCIA requires SBA to 
refer delinquent debts to Treasury for collection on delinquent debts. Also, SBA management 
states that referrals to the DOJ for collection require filing a lawsuit, which is time consuming 
and resource intensive, and not as effective as referral to Treasury. However, SBA will work with 
DOJ on loans that cannot be referred to Treasury because they involve fraud. 
This recommendation is unresolved. SBA management’s response does not address the 
recommendation as intended. Management cited that SBA refers delinquent debts to Treasury 
for collection and that referral to the DOJ is not as effective as referral to Treasury. However, as 
discussed in this report, Treasury returned delinquent COVID-19 EIDLs back to SBA from cross-
servicing, and SBA is responsible for continuing collection efforts through March 31, 2026. 
Further, not only is referral to the DOJ a requirement of Federal Claims Collection Standards, it is 
also in the best interest of taxpayers for SBA to refer delinquent loans to the DOJ, rather than 
wait for Treasury to do so, because the ability to collect delinquent debts generally decreases 
as the debts become older. Lastly, management stated SBA will work with the DOJ on loans 
involving fraud; however, it is important to note that our review excluded loans flagged for 
potential or confirmed fraud. 
The intent of this recommendation was not for SBA to refer every delinquent COVID-19 EIDL to 
the DOJ but to coordinate with the DOJ and determine what loans would be appropriate for 
referral. We will continue to seek resolution of this recommendation in accordance with our 
audit follow-up policy. 

 
1-1 
Appendix 1: Scope and Methodology 
This report presents the results of our audit to determine the U.S. Small Business 
Administration’s (SBA) efforts to collect on delinquent Coronavirus Disease 2019 (COVID-19) 
Economic Injury Disaster Loans (EIDL). Our scope of work covered delinquent COVID-19 EIDLs 
that did not have suspected or confirmed fraud hold codes from March 2020 through July 2024. 
To accomplish our objective, we reviewed relevant federal laws, regulations, other federal 
guidance, and information about the COVID-19 EIDL program found on the SBA website. We 
also reviewed SBA policies, standard operating procedures, and other guidance pertaining to 
SBA’s modified processes to approve COVID-19 EIDL applications and to liquidate delinquent 
COVID-19 EIDLs. 
We selected a judgmental sample of 15 charged-off COVID-19 EIDLs to identify SBA’s processes 
and procedures associated with charging off delinquent debt and reviewed loan liquidation data 
from the agency’s Capital Access Financial System. We interviewed SBA personnel from various 
offices in the Office of Capital Access, primarily from the COVID-19 EIDL Servicing Center, and 
from the Office of Performance and Systems Management responsible for the management, 
oversight, and execution of the COVID-19 EIDL liquidation process to gain an understanding of 
related procedures, practices, and system controls. 
We conducted this performance audit in accordance with the Government Accountability 
Office’s Generally Accepted Government Auditing Standards. These standards require that we 
plan and perform audits to obtain sufficient and appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. We believe the evidence 
obtained provides a reasonable basis for our findings and conclusions based on our objective. 
Use of Computer-Processed Data 
We obtained and analyzed COVID-19 EIDL data for loans delinquent 90 days or more and 
charged off as of June 11, 2024. We performed limited testing on data extracts to ensure 
the data was complete, reliable, and met the scope parameters of this evaluation. We also 
performed a data reliability assessment to ensure the data materially supported the findings, 
conclusions, and recommendations. We believe the data was sufficiently reliable to support the 
findings in this report. 
 
 

 
1-2 
Assessment of Internal Controls 
Internal controls comprise the plans, methods, policies, and procedures used to fulfill the 
mission, strategic plan, goals, and objectives of the entity. The controls include the systems 
designed to provide reasonable assurance of achieving effective and efficient operations, 
reliability of reporting for internal and external use, and compliance with provisions of applicable 
laws and regulations. Internal controls serve to prevent and detect inconsistencies, significant 
errors, fraud, and noncompliance with provisions of laws and regulations. 
We assessed SBA policies and procedures, applicable to the scope of this audit, to determine the 
internal controls used for compliance with laws and regulations to the extent necessary to satisfy 
the audit objective. We obtained and reviewed information and data from an SBA management 
official in the Office of Capital Access regarding SBA’s procedures to assess COVID-19 EIDL 
liquidation processes and risks through the Quality Improvement Program. 
We reviewed the United States Government Accountability Office’s (GAO) Standards for Internal 
Control in the Federal Government, GAO-14-704G, which provides guidance to federal managers 
on designing, implementing, and operating an effective internal control system. 
The internal control deficiencies we found are discussed in the “Results” section of this report. 
However, because our review was limited to those internal control components and underlying 
principles that we found significant to the audit objective, all internal control deficiencies that 
may have existed at the time of this audit may not have been disclosed. See Table 1-1 for the key 
internal control components and principles significant to the audit objectives. 
Table 1-1: Internal Controls 
Internal Control 
Component 
Internal Control Principle 
Risk assessment 
Identify, analyze, and respond to risk (inherent) and assess fraud risk 
Control activities 
Design control activities and design activities for the information system 
Source: Office of Inspector General analysis 
 
 

 
1-3 
Prior Audit Coverage 
The following lists the Office of Inspector General’s previous audit coverage related to the 
objective of this report: 
Report 
Number 
Report Title 
Report Date 
23-16 
Ending Active Collections on Delinquent COVID-19 Economic 
Injury Disaster Loans 
September 29, 2023 
20-20 
Audit of SBA’s Compliance with the Debt Collection 
Improvement Act, as Amended 
September 30, 2020 
13-18 
The SBA Did Not Effectively Manage Defaulted Disaster Loans 
to Maximize Recovery from 2006 to 2011 
September 27, 2013 
12-17 
The Small Business Administration Risks Loss of Collateral for 
Four Disaster Loans Totaling $5.6 Million 
July 31, 2012 
12-14 
The Small Business Administration Did Not Maximize 
Recovery for $171.1 Million in Delinquent Disaster Loans in 
Liquidation 
July 9, 2012 
 

2-1
Appendix 2: Additional Information 
We grouped the Coronavirus Disease 2019 (COVID-19) Economic Injury Disaster Loan (EIDL) data 
by loan value based on collateral and/or guaranty requirements for loans that were charged off 
as of December 18, 2024. We excluded loans that were less than $25,000 and did not require 
collateral; had suspected or confirmed fraud; went through probate due to obligor death, 
bankruptcy, or business closure; and loans that were in, or went through, workout. A workout 
is an agreement between the U.S. Small Business Administration (SBA) and the borrower that 
restructures the material terms and conditions of the delinquent loan to enable the borrower 
to cure the default and improve repayment ability. As indicated in Table 2-1, we identified 
369,588 loans that were in charge-off status. We also calculated the number of days each loan 
was in liquidation using the dates the loan entered and went out of liquidation. See Table 2-1 for 
the average number of days loans were in liquidation. 
Table 2-1: Charged-Off Loans and Average Days in Liquidation 
Loan Value 
Number of 
Loans 
Original Loan 
Amount 
Charged-Off 
Amount 
Recovery 
Amount 
Average 
Number of 
Days in 
Liquidation 
$25,001–200,000 
325,428 
$27,812,506,169 $26,964,000,262 
$6,432,697 
3 
$200,001–500,000 
39,555 
$14,923,683,329 $14,843,066,343 $21,322,406 
26 
$500,001–2,000,000 
4,605 
$5,402,953,462 
$5,379,448,225 
$7,239,196 
26 
Total 
369,588 
$48,139,142,960 $47,186,514,830 $34,994,299 
5 
Note: Charged-off COVID-19 EIDLs as of December 18, 2024. 
To ensure delinquent loans were properly reported to credit bureaus, we obtained the 
commercial and consumer credit bureau reports that SBA submitted in December 2024. 
Depending on the type of obligor(s) (e.g., limited liability company, self-employed, personal 
guarantor) responsible for repayment of the loan, SBA may make a commercial credit bureau 
report, consumer credit bureau report, or both. The agency reports delinquent loans to credit 
bureaus at charge off, which occurs at 180 days delinquent. 
Accordingly, we refined our universe of charged-off loans in Table 2-1 to include loans 
delinquent 180 days or more to conduct this analysis. Further, we expanded our universe by 

 
2-2 
adding back in loans that went through probate due to obligor death, bankruptcy, or business 
closure and loans that were in, or went through, workout since those loans were also required to 
be reported to the credit bureaus. Loans that had a suspected or confirmed fraud indicator 
remained excluded. We then matched these loans to the credit bureau reports and identified 
that: 
• Over 94 percent of businesses with loans delinquent 180 days or more were not 
reported to commercial credit bureaus, 
• Nearly 95 percent of sole proprietors with loans delinquent 180 days or more were not 
reported to commercial or consumer credit bureaus, 
• One hundred percent of self-employed individuals and independent contractors with 
loans delinquent 180 days or more were not reported to consumer credit bureau, and, 
• Over 94 percent of personal guarantors with loans delinquent 180 days or more were 
not reported to consumer credit bureaus (see Table 2-2). 
Table 2-2: Charged-Off Loans Reported to Credit Bureaus 
Loan Value 
Businesses 
Reported to 
Commercial Credit 
Bureaus 
Sole Proprietors 
Reported to 
Commercial or 
Consumer Credit 
Bureaus 
Self-employed 
Individuals and 
Contractors 
Reported to 
Consumer Credit 
Bureaus 
Personal 
Guarantors 
Reported to 
Consumer Credit 
Bureaus 
Required 
Actual Required Actual Required Actual Required Actual 
$1–25,000 
169,063 
8,828 
163,699 
8,512 
103,972 
0 
N/A 
N/A 
$25,001–200,000 
221,930 
12,200 
83,697 
4,483 
29,948 
0 
N/A 
N/A 
$200,001–500,000 
33,067 
2,666 
6,622 
427 
1,539 
0 
47,802 
2,725 
$500,001–2,000,000 
4,981 
403 
298 
18 
17 
0 
6,972 
415 
Total 
429,041 
24,097 
254,316 13,440 
135,476 
0 
54,774 
3,140 
Note: Charged-off COVID-19 EIDLs as of December 18, 2024, and consumer and commercial credit bureau reports 
for December 2024. 

 
3-1 
Appendix 3: Agency Response 
U.S. Small Business Administration 
Response to Draft Report 

U.S. SMALL BUSINESS ADMINISTRATION 
WASHINGTON, DC 20416 
To: 
Sheldon Shoemaker 
Deputy Inspector General 
U.S. Small Business Administration 
From: 
Jihoon Kim 
Office of Financial Program Operations, Director 
Office of Capital Access 
Date: 
August 1, 2025 
Subject: 
Response to OIG Draft Report – SBA’s Collection Efforts on Delinquent 
COVID-19 EIDLs (Project 24804) 
This report presents the results of our audit to determine the U.S. Small Business 
Administration’s (SBA) efforts to collect on delinquent Coronavirus Disease 2019 (COVID- 
19) Economic Injury Disaster Loans (EIDL) with collateral and personal guarantors.
As of December 18, 2024, SBA charged off over $47 billion in delinquent COVID-19 EIDLs 
without suspected or confirmed fraud. Less than 1 percent of the original loan amounts were 
recovered during SBA’s liquidation process. Recoveries included, but were not limited to, 
payments made by the borrower during the liquidation process or due to the borrower’s 
business closure, payments made due to the death of the borrower or personal guarantor, and 
recoveries from bankruptcy proceedings. 
Recommendation 1 – We recommend the Administrator direct the Associate Administrator for 
the Office of Capital Access to conduct a study to establish minimum loan thresholds for 
performing site visits, implement policies and procedures based the results of that study, and 
perform site visits to help facilitate appropriate liquidation of collateral on defaulted COVID-19 
EIDLs in an effort to maximize collections. 
SBA Response: SBA disagrees with this recommendation to conduct a study to establish 
minimum loan thresholds for performing site visits; implement policies and procedures based on 
the results of that study; and perform site visits to help facilitate liquidation of collateral on 
defaulted COVID-19 EIDLs to maximize collection. Below are the reasons for SBA’s 
disagreement. 

• Since UCC liens on disaster loans are not purchase money liens, SBA takes a best 
available on the business assets. 
• From a collateral standpoint, SBA UCC lien in most cases is subordinate to existing and 
future purchase money and blanket UCC liens. The liquidated value of chattel that have 
priority liens is in the majority of cases negligible or non existent for subordinate 
creditors. The inherent value in taking a general best available security interest in these 
circumstances is for SBA debt to be on record such that it will require notice to SBA 
regarding sale, transfer or bankruptcy/reorganization of the business which may allow for 
future recoveries without requiring SBA to bear the cost of a foreclosure/liquidation of 
assets that don’t support the action. 
• Conducting site visits across the COVID EIDL portfolio is a manual, resource-intensive 
process. A site visit does not generally establish data relevant to determining recovery, 
such as owned vs. leased property, current lien priority, intangible, or recoverable value 
of on-site assets. As such, SBA does not consider the logistics and costs associated with 
site visits to beneficially impact liquidation outcomes. Site visits would require 
cooperation from an obligor who already has been uncooperative and may require 
consent from a landlord. 
• SBA SOP 50 52 does not require a site visit for every loan classified in liquidation. 
Under established guidelines, a site visit may be required if SBA determines that real 
estate foreclosure is the appropriate collection method. For loans with real estate, a lien 
search will be performed and an independent appraisal is obtained which covers site 
information, and is used by SBA to determine whether it is appropriate to proceed. 
 
Recommendation 2 – We recommend the Administrator direct the Associate Administrator for 
the Office of Capital Access to verify all delinquent COVID-19 EIDL obligors are reported to 
credit bureaus in a timely manner. 
 
SBA Response: SBA agrees with this recommendation. SBA will add functionality to SBA’s 
ETRAN system to log time/date entries for credit bureau submissions to allow for tracking of 
these submissions. 
 
Final Action Target Date: June 30, 2026 
 
Recommendation 3 – We recommend the Administrator direct the Associate Administrator for 
the Office of Capital Access to confer with the DOJ to establish a reasonable standard for referral 
of delinquent COVID-19 EIDLs to the DOJ for litigation. 
 
SBA Response: SBA disagrees with this recommendation. As noted in the report, the DCIA 
requires SBA to refer delinquent debts to Treasury. Treasury successfully collects on delinquent 
debts, including through the use of administrative offset. Referrals to the Department of Justice 
for collection require the filing of a lawsuit, which is very time-consuming and resource- 
intensive, and not as effective as referral to Treasury. However, SBA will work with DOJ on 
loans that cannot be referred to Treasury because they involve fraud.

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