7(a) Loan Approval for Borrowers with Unresolved COVID-19 Pandemic Loan Compliance Issues

Summary

SBA Office of Inspector General Inspection Report 24-17, 7(a) Loan Approval for Borrowers with Unresolved COVID-19 Pandemic Loan Compliance Issues, dated May 21, 2024, from Inspector General Hannibal "Mike" Ware to Administrator Isabella Casillas Guzman. The report states that from October 1, 2019 through May 8, 2023 SBA approved and disbursed 172,598 7(a) loans totaling $83.4 billion. It states that SBA did not implement a screening process for PPP and COVID-19 EIDL hold codes before 7(a) loan approval until August 2023, and that there were 5,044 approved and disbursed 7(a) loans, totaling $4.5 billion, where the borrower had a PPP loan or COVID-19 EIDL with an unresolved eligibility or potential fraud issue. SBA management partially agreed with the recommendation.

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U.S. SMALL BUSINESS ADMINISTRATION
OFFICE OF INSPECTOR GENERAL
7(a) Loan Approval for Borrowers
with Unresolved COVID-19 Pandemic
Loan Compliance Issues
Inspection Report
Report 24-17
May 21, 2024

Make a Difference
To report fraud, waste, or mismanagement, contact the U.S. Small Business Administration’s
Office of Inspector General Hotline at https://www.sba.gov/oig/hotline. You can also write to the
U.S. Small Business Administration, Office of Inspector General, 409 Third Street, SW (5th Floor),
Washington, DC 20416. In accordance with the Inspector General Act of 1978, codified as
amended at 5 U.S.C. §§ 407(b) and 420(b)(2)(B), confidentiality of a complainant’s personally
identifying information is mandatory, absent express consent by the complainant authorizing the
release of such information.
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
7(a) Loan Approval for Borrowers with Unresolved COVID-19
Pandemic Loan Compliance Issues (Report 24-17)
What OIG Reviewed
The U.S. Small Business Administration (SBA) is
authorized under Section 7(a) of the Small
Business Act to provide financial assistance to
businesses in the form of guaranteed loans.
During the Coronavirus Disease 2019 (COVID-19)
pandemic, eligible businesses and entities had
access to over $1.2 trillion in the Paycheck
Protection Program (PPP) and COVID-19
Economic Injury Disaster Loan (EIDL) program.
Our prior reviews of these programs reported
systemic issues regarding borrowers’ eligibility
and potentially fraudulent loans.
From October 1, 2019 through May 8, 2023, SBA
approved and disbursed 172,598 7(a) loans,
totaling $83.4 billion. The 7(a) lenders who
have delegated approval authority approved
92 percent of these loans. SBA approved the
remaining 8 percent that non-delegated lenders
processed.
Our objective was to assess SBA’s process for
approving 7(a) loans for borrowers with
unresolved pandemic loan compliance issues. To
accomplish our objective, we analyzed loan
program data and interviewed SBA personnel.
What OIG Found
SBA implemented a process to screen 7(a) loan
applications for eligibility, which included
screening for PPP and COVID-19 EIDL hold codes
prior to loan approval. However, the process
was not implemented until August 2023, after
we initiated this review. Prior to August 2023,
neither SBA nor lenders reviewed approved 7(a)
loans to ensure borrowers did not have
unresolved compliance issues that could
negatively impact their eligibility for the 7(a)
loan.
As a result, there were 5,044 approved and
disbursed 7(a) loans, totaling $4.5 billion, where
the borrower had a PPP loan or COVID-19 EIDL
with an unresolved eligibility or potential fraud
issue.
SBA stated it resolved hold codes for 3,015 of
5,044 loans. We did not assess SBA’s
methodology or whether the hold codes were
appropriately removed. Our evaluation of SBA’s
Eligibility and Forgiveness Reviews of PPP Loans
Made to Borrowers With Treasury’s Do Not Pay
Data Matches, which documented the use of
similar hold codes, found that SBA did not
always appropriately review and resolve hold
codes. We will assess the appropriateness of
SBA’s removal of hold codes for the 3,015 loans
prior to closing the recommendation.
What OIG Recommended
We recommend SBA review and appropriately
resolve hold codes related to the 5,044 7(a)
loans to determine impact on 7(a) eligibility and
seek remedy or repayment of all 7(a) loans
deemed ineligible.
Agency Response
SBA management partially agreed with the
recommendation. Management stated they
already resolved 3,015 of the 5,044 7(a) loans
and plan to review the remaining 2,029 loans.
We consider the recommendation resolved and
will assess the appropriateness of SBA’s removal
of the hold codes for all 5,044 loans when SBA
provides clear and sufficient evidence to close
the recommendation.

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:
May 21, 2024
To:
Isabella Casillas Guzman
Administrator
From:        Hannibal “Mike” Ware

 Inspector General

Subject:
7(a) Loan Approval for Borrowers with Unresolved COVID-19 Pandemic Loan
Compliance Issues (Report 24-17)
This report presents the results of our inspection of 7(a) Loan Approval for Borrowers with
Unresolved COVID-19 Pandemic Loan Compliance Issues. We considered management comments
on the draft of this report when preparing the final report. SBA management partially agreed
with the recommendation.
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.

409 Third St. SW, Washington, DC 20416  •  (202) 205-6586  •  Fax (202) 205-7382
cc:
Dilawar Syed, Deputy Administrator

Arthur Plews, Chief of Staff

Isabelle James, Deputy Chief of Staff

Therese Meers, General Counsel, Office of General Counsel

Kathryn Frost, Associate Administrator, Office of Capital Access

John Miller, Deputy Associate Administrator, Office of Capital Access

Michael Simmons, Attorney Advisor, Office of General Counsel

Anna Maria Calcagno, Director, Office of Performance, Analysis, and Evaluation

Walter B. Hill Jr. Chief Risk Officer, Office of Performance, Planning, and Chief Financial
   Officer

Deborah Chen, Deputy Chief Financial Officer, Office of Performance, Planning, and Chief
   Financial Officer

Katherine Aaby, Associate Administrator, Office of Performance, Planning, and Chief
   Financial Officer

Tonia Butler, Director, Office of Internal Controls

Peter Meyers, Senior Advisor, Office of Capital Access

Rachel Wilson, Program Analyst, Office of Capital Access

i
Contents
Introduction ........................................................................................................................................ 1
Background .................................................................................................................................. 1
COVID-19 Pandemic Loan Programs ..................................................................................... 1
7(a) Loans and Hold Codes .................................................................................................... 2
Objective ...................................................................................................................................... 2
Results ................................................................................................................................................ 2
Finding 1: 7(a) Loans Approved Without Review of Potential Risks ........................................... 3
Recommendations ....................................................................................................................... 6
Evaluation of Agency Response ......................................................................................................... 6
Appendices
Appendix 1: Scope and Methodology ............................................................................................. 1-1
Appendix 2: Agency Response ........................................................................................................ 1-3

1
Introduction
This report presents the results of our inspection of the U.S. Small Business Administration’s
(SBA) process for approving 7(a) loans with related, unresolved Coronavirus Disease 2019
(COVID-19) pandemic loan compliance issues. The Office of Inspector General (OIG) conducted
this inspection to identify potential risks for SBA’s 7(a) loan program.
Background
SBA is authorized under Section 7(a) of the Small Business Act to provide financial assistance to
small businesses in the form of government-guaranteed loans. Participating lenders enter into an
agreement with SBA to make loans to small businesses in accordance with SBA rules, regulations,
policies, and procedures. From October 1, 2019 through May 8, 2023, SBA approved and
disbursed 172,598 7(a) loans, totaling $83.4 billion.
COVID-19 Pandemic Loan Programs
The Coronavirus Aid, Relief, and Economic Security (CARES) Act was enacted on March 27, 2020,
to provide economic relief to borrowers impacted by the COVID-19 pandemic. Section 1102 of
the CARES Act established the Paycheck Protection Program (PPP) with $349 billion to provide
fully guaranteed loans under section 7(a) of the Small Business Act. The PPP provided loans for
certain eligible borrowers that can be fully forgiven if loan proceeds were used as required by
the law. Through additional legislation, total program funding increased to $813.7 billion.
Under the Coronavirus Preparedness and Response Act, Paycheck Protection Program and
Health Care Enhancement Act, and administrative actions taken by SBA, SBA also offered a
special COVID-19 Economic Injury Disaster Loans (EIDL) program to help small businesses and
other entities. SBA was authorized to administer $373 billion for its EIDL program.
SBA’s administration of the PPP and COVID-19 EIDL program included identifying issues with
eligibility requirements and potential fraud. For example, SBA screened for disqualifying factors,
such as criminal history and bankruptcy. When identified, SBA placed hold codes on these
pandemic-related loans with the intent of reviewing and resolving the issues before further
processing of the loan.

2
7(a) Loans and Hold Codes
From October 1, 2019, through May 8, 2023, SBA approved and disbursed 172,598 7(a) loans,
totaling $83.4 billion. Of these loans, there were 5,044, totaling $4.5 billion, with borrowers
and/or principals who also had a PPP loan or COVID-19 EIDL with an unresolved hold code
(compliance issue) at the time of their 7(a) loan approval.
SBA assigned the Loan Guaranty Processing Center (LGPC) the responsibility of determining
whether hold codes on related pandemic loans were resolved prior to approving 7(a) loans. The
LGPC is responsible for approving all 7(a) loans processed by non-delegated lenders, which
accounted for approximately 8 percent of the 7(a) portfolio since fiscal year (FY) 2020. Non-
delegated lenders do not have authority to approve 7(a) loans. The 7(a) lenders who have
delegated approval authority approved the remaining 92 percent of the loans.
Objective
Our objective was to assess SBA’s process for approving 7(a) loans for borrowers with unresolved
COVID-19 pandemic loan compliance issues.
Results
SBA implemented a process to screen 7(a) loan applications for eligibility, which included
screening for PPP and COVID-19 EIDL hold codes prior to loan approval. However, the process
was not implemented until August 2023, after OIG initiated this review. We found that neither
SBA nor the lenders reviewed 7(a) loans made from FY 2020 to May 8, 2023 to ensure borrowers
did not have unresolved compliance issues with PPP loans or EIDLs that could negatively impact
their eligibility. In addition, prior to August 2023, SBA did not have any automated controls in its
loan application system to screen for the unresolved issues during the 7(a) loan approval
process. The absence of such controls increased the risk that ineligible or fraudulent borrowers
could obtain 7(a) loans and hindered SBA’s ability to mitigate potential fraud and financial loss in
its programs.
SBA’s corrective actions taken during our review to implement the screening process for 7(a)
loan applications addressed our concerns and should help ensure that, moving forward, only
eligible borrowers are approved for 7(a) loans. However, to reduce the impact of potential fraud

3
and promote program integrity, SBA should take immediate action to address the
5,044 approved and disbursed 7(a) loans identified in this report that were not reviewed under
the new screening process.
Finding 1: 7(a) Loans Approved Without Review of Potential
Risks
Prior to August 2023, SBA did not, nor did it require, delegated lenders to review hold codes on
pandemic loans to ensure borrowers met eligibility requirements. Additionally, SBA did not have
any controls in its loan application system (ETran) to screen for the unresolved hold codes during
the 7(a) loan approval process.
Not all hold codes on related pandemic loans pose a risk to 7(a) loan approvals. This is because
some hold codes were specific to pandemic loan requirements that would not impact the 7(a)
loan. For example, SBA used multiple hold codes on pandemic loans for borrowers exceeding the
allowed loan amount; therefore, our analysis excluded hold codes that did not impact 7(a)
eligibility requirements. We focused on hold codes that could impact eligibility in the 7(a) loan
program, such as those related to criminal records, bankruptcy, potential fraud, and the U.S.
Department of Treasury’s Do Not Pay (DNP) list. The absence of sufficient controls to review
borrowers’ applicable unresolved compliance issues with PPP loans and COVID-19 EIDLs exposed
the 7(a) loan program to increased financial risk from potentially ineligible or fraudulent
borrowers.
Beginning FY 2020 through May
8, 2023, there were 5,044
approved and disbursed 7(a)
loans totaling approximately
$4.5 billion with related PPP
loans or COVID-19 EIDLs with
unresolved hold codes. SBA
stated it resolved the applicable
hold codes for 3,015 of these
loans after the 7(a) loan was
approved and disbursed. We
sampled 133 of the 3,015 loans
and found that the hold codes were removed for 132 loans. We did not assess the methodology
SBA used or the appropriateness of its decision to resolve and remove these hold codes.

4
However, our evaluation of SBA’s Eligibility and Forgiveness Reviews of Paycheck Protection
Program Loans Made to Borrowers With Treasury’s Do Not Pay Data Matches (Report Number
24-06), which documented the use of similar hold codes, found that SBA did not always
appropriately resolve the hold codes. We will assess the appropriateness of SBA’s removal of
hold codes for the 3,015 loans when SBA provides sufficient evidence to close the
recommendation in this report.
Beginning in August 2020, SBA
used a new automated screening
process to identify potential PPP
non-compliance issues with
eligibility and fraud. The
automated screening used 19
rules that reflect known and
suspected fraud and abuse
patterns to identify issues, such
as fictitious or inactive
businesses. This process included
steps to screen loan information provided by lenders through ETran against the entire loan
database and publicly available information. This process flagged 348,494 PPP applications that
SBA ultimately did not approve.
Although SBA’s automated screening process identified potential PPP issues, SBA did not fully
leverage that information to reduce the risk of potentially ineligible and fraudulent borrowers
obtaining 7(a) loans. This occurred because SBA did not implement policies and procedures to
identify issues across its various loan programs. In addition, SBA did not implement an
automated screening process for 7(a) because SBA viewed the unresolved COVID-19 loan
compliance issues as low risk for the 7(a) loan program. According to SBA:
• The 7(a) program has more controls in place than PPP and COVID-19 EIDL,
• Lenders have more at stake due to the lower guaranty percentages on 7(a) loan
programs, and
• Lenders are required to adhere to Know Your Customer and Bank Secrecy Act
requirements.

5
According to the U.S. Government Accountability Office, federal program managers should
design and implement a strategy with specific control activities to mitigate assessed fraud
risks and collaborate to help ensure effective implementation.1 These control activities
could include the use of data analytics to identify potential fraud through data mining and
data matching techniques. In addition, effective internal controls require that quality
information is communicated across all levels of the entity to achieve objectives and address
risks.2
We discussed the 7(a) loan program and COVID-19 related hold codes with SBA’s Fraud Risk
Management Board, which serves as the designated anti-fraud entity responsible for
oversight and coordination of SBA’s fraud risk prevention, detection, and response activities.
The board identified hold codes and identity theft as prevalent fraud risks for the 7(a) loan
program.
Because SBA did not review all instances of potential fraud across the 7(a) loan program and
related pandemic loans, it missed opportunities to mitigate fraud risk and promote program
integrity. In addition, SBA reduced its ability to hold fraudulent borrowers accountable and
increased the risk that fraudulent or ineligible borrowers could obtain loans and assistance from
various other loan programs. If SBA leveraged data across loan programs, it could have further
ensured that borrowers for the 5,044 loans totaling approximately $4.5 billion met eligibility
requirements, thereby reducing the risk of potential fraud and financial loss.
During our review on August 1, 2023, SBA implemented a screening process through ETran to
check 7(a) loan applications for eligibility, which included screening for PPP and COVID-19 EIDL
hold codes prior to loan approval. The screening occurs when lenders enter borrower
information into ETran. SBA then uses third-party databases to validate eligibility information.
If the screening returns an error code for eligibility, the lender must work with SBA to clear the
code by providing support documentation. Once the code is cleared, the lender can continue
processing the 7(a) loan.
If implemented effectively, SBA’s screening process through ETran should reduce the risk of
ineligible borrowers receiving 7(a) loans. We will continue to monitor the capabilities of this
screening process. However, to reduce the impact of potential fraud and promote program

1 GAO-15-593SP, A Framework for Managing Fraud Risks in Federal Programs (July 2015).
2 GAO-14-704G, Standards for Internal Controls in the Federal Government (September 2014).

6
integrity, SBA should take immediate action to address the identified 5,044 approved and
disbursed 7(a) loans, totaling approximately $4.5 billion where the borrowers had related PPP
loans or COVID-19 EIDLs with an applicable unresolved hold code.3
Recommendations
To ensure eligibility requirements were met and reduce the risk of potential fraud, we
recommend the Administrator direct the Associate Administrator for the Office of Capital Access
to:
Recommendation 1: Review and appropriately resolve hold codes related to the 5,044 7(a) loans
to determine impact on 7(a) eligibility and seek remedy or repayment of all 7(a) loans deemed
ineligible.
Evaluation of Agency Response
SBA management provided formal comments to the draft report, which we considered when
preparing this final report. Management partially agreed with the recommendation, stating they
have already resolved hold codes related to 3,015 of the 5,044 loans and they will review hold
codes related to the remaining 2,029 7(a) loans. See Appendix 2 for management’s comments in
their entirety.
Summary of Actions Necessary to Close the Recommendation
The following section summarizes the status of our recommendation and the actions necessary
to close it.
Recommendation 1
To ensure eligibility requirements were met and reduce the risk of potential fraud, we
recommend the Administrator direct the Associate Administrator for the Office of Capital Access
to review and appropriately resolve hold codes related to the 5,044 7(a) loans to determine
impact on 7(a) eligibility and seek remedy or repayment of all 7(a) loans deemed ineligible.

3 SBA stated it resolved hold codes for 3,015 of the 5,044 7(a) loans. We will assess the appropriateness of SBA’s removal of
these hold codes prior to closing the recommendation.

7
Status: Resolved
SBA management partially agreed with the recommendation, stating they already resolved hold
codes for 3,015 of the 5,044 loans. Management stated they will review open and unresolved
hold codes related to the remaining 2,029 7(a) loans to determine if the potential issue identified
by the open hold code impacts 7(a) eligibility. If there is a potential impact to 7(a) eligibility,
management will ensure they address the potential issue. In subsequent correspondence, SBA
provided a target completion date of May 1, 2025.
We recognized in the report that SBA stated it resolved applicable hold codes for 3,015 of the
5,044 7(a) loans after they were approved and disbursed. We sampled 133 of the 3,015 loans
and found that the hold codes were removed for 132 of them. However, we did not assess the
appropriateness of SBA’s decision to resolve and remove these hold codes because the related
information was not readily available in SBA’s systems.
We stated in the report that we will assess the appropriateness of SBA’s removal of hold codes
for the 3,015 loans during the audit follow-up process. To satisfy the intent of this
recommendation, SBA should provide clear and sufficient evidence to show it appropriately
resolved hold codes related to the 3,015 7(a) loans and this had no impact on 7(a) eligibility.
Management must also review the remaining 2,029 loans to ensure eligibility requirements were
met and provide clear and sufficient evidence to support its review decisions.
We consider this recommendation resolved and will close it when management provides clear
and sufficient evidence they have reviewed and appropriately resolved hold codes related to the
5,044 7(a) loans to determine impact on 7(a) eligibility and seek remedy or repayment of all 7(a)
loans deemed ineligible.

1-1
Appendix 1: Scope and Methodology
This report presents the results of our inspection of the U.S. Small Business Administration’s
(SBA) process for approving 7(a) loans. The SBA’s Office of Inspector General (SBA OIG)
conducted this inspection to assess SBA’s process for approving 7(a) loans with related
unresolved Coronavirus Disease 2019 (COVID-19) pandemic loan compliance issues. Our scope of
work included approved and disbursed 7(a) loans for borrowers who had approved Paycheck
Protection Program (PPP) and COVID-19 Economic Injury Disaster Loans (EIDL) with unresolved
hold codes during the 7(a) loan approval process.
To answer our objective, we reviewed policies, procedures, and guidance related the approval of
7(a) loans with related unresolved COVID-19 pandemic loan compliance issues.
We interviewed SBA personnel from various offices in the Office of Capital Access, including the
Office of Financial Program Operations, and the Office of Performance and Systems
Management, to gain an understanding of related processes, procedures, and system controls.
Further, we analyzed data for the 7(a), PPP, and COVID-19 EIDL programs from October 1, 2019
to May 2023 to identify the number and amount of 7(a) loans with related unresolved COVID-19
pandemic loan compliance issues. We also analyzed the PPP and COVID-19 EIDL data to identify
loans with unresolved hold codes.
We statistically sampled 133 of 3,015 7(a) loans that SBA indicated had the related PPP and
COVID-19 EIDL hold codes resolved after the 7(a) loan was approved and disbursed. We
reviewed whether hold codes were resolved after the 7(a) loan was approved and disbursed and
projected our results using a 95 percent confidence level.
We conducted this inspection in accordance with the Council of the Inspectors General on
Integrity and Efficiency’s Quality Standards for Inspection and Evaluation. These standards
require that we adequately plan and perform the evaluation to obtain sufficient and appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our objective.
We believe that the evidence provides a reasonable basis for our conclusions based on our
objective.

1-2
Use of Computer-Processed Data
We relied on data from SBA’s electronic loan application system (ETran). We performed limited
testing on data extracts to ensure the data was complete and met the scope parameters of this
inspection. We also reviewed a data reliability assessment from a recent prior audit that used
ETran data. As a result, we believe that the data are sufficiently reliable to support our findings.
Prior Audit Coverage
Report Number
Report Title
Date
SBA OIG Report 23-09
COVID-19 Pandemic EIDL and PPP Loan
Fraud Landscape
June 27, 2023
SBA OIG Report 23-05
White Paper 7(a) Loan Program During SBA’s
Response to the Covid-19 Pandemic
March 21, 2023
SBA OIG Report 22-13
SBA’s Handling of Potentially Fraudulent
Paycheck Protection Program Loans
May 26, 2022

1-3
Appendix 2: Agency Response
SBA RESPONSE TO THE INSPECTION REPORT

U.S. SMALL BUSINESS ADMINISTRATION
WASHINGTON, DC 20416
To:
Hannibal “Mike” Ware
Inspector General
U.S. Small Business Administration
From:
Jihoon Kim
Director
Office of Financial Program Operations
Office of Capital Access

Date:
May 1, 2024
Subject:
Response to OIG Draft Report - 7(a) Loan Approval for Borrowers with
Unresolved COVID-19 Pandemic Loan Compliance Issues – Project 23011
We appreciate the role the Office of Inspector General (OIG) plays in working with management
in ensuring that our programs are effectively managed, and for the feedback provided in this
draft report. We offer the following comments to the draft and Recommendations:
SBA acknowledges the importance of determining whether a 7(a) applicant is eligible. In an
effort to ensure eligibility, as well as in response to lessons learned from the Paycheck Protection
Program (PPP), SBA implemented a new preapproval screening process utilizing SBA’s Risk
Mitigation Framework for all 7(a) loan applications, both delegated and non-delegated, as of
August 1, 2023. This is the first time in the Agency’s history that SBA has instituted such a
review on 7(a) loans. As a part of this process, SBA is screening 7(a) loan applications to
identify Borrowers with unresolved hold codes on COVID-19 Pandemic loans to prevent 7(a)
loan approval until all COVID-19 hold codes are resolved.
Recommendation 1 – Review and appropriately resolve hold codes related to the 5,044 7(a)
loans to determine impact on 7(a) eligibility and seek remedy or repayment of all 7(a) loans
deemed ineligible.
SBA Response: SBA partially agrees. SBA has already resolved hold codes on COVID-19
Pandemic loans related to 3,015 of these loans and will review hold codes related to the
remaining 2,029 7(a) loans. Where hold codes remain open and unresolved, SBA will review
those loans to determine if the potential issue identified by the open hold code impacts 7(a)

eligibility. If there is a potential impact to 7(a) eligibility, SBA will enter a Chron comment to
ensure the potential issue is addressed.

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