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SBA Agency Financial Report FY 2009 — Financial Reporting, OIG Reports and Appendices

Summary

These pages of the SBA's Agency Financial Report FY 2009 carry financial reporting notes in dollars in thousands, among them credit program receivables, loans disbursed and outstanding loan obligations, subsidy cost allowance balances and credit program subsidy reestimates. The text states that the 7(a) Loan Guaranty program had the largest net upward reestimates for the guarantied business loan programs in FY 2009, at $2,030.2 million, and the 504 Certified Development Companies program $1,565.8 million. Total Guarantied Loan Program Subsidy Reestimates are $4,684,836 for 2009 and $424,817 for 2008. Note 7 covers general property and equipment, and the acknowledgments thank the Office of the Inspector General and KPMG, LLP for the audit of the FY 2009 financial statements.

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“SBA Agency Financial Report FY 2009 — Financial Reporting, OIG Reports and Appendices.” Original at legacy.sba.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sba-agency-financial-report-2009-finan-report-oig-report-append-0-d68350552e/, SHA-256 c6c9842d5dd847857b4e059d4c3c0a8ddec0164f2cca0d66f356089cf080d731.

Full text

               FIN AN C IAL RE PORTI N G



     SBA’s model varies in the specific methodologies employed to forecast future program cash flows. In
     general, however, models for all major credit programs use historical data as the basis for assumptions
     about future program performance and then translate these assumptions into nominal cash flow esti-
     mates by applying rules about program structure. Nominal cash flow forecasts are discounted using
     the Office of Management and Budget’s Credit Subsidy Calculator that has both forecasted and actual
     Treasury interest rates.
     Historical data used as the basis for program performance assumptions is drawn primarily from data
     systems maintained by the SBA and its contractors. The historical data undergoes quality review and
     analysis prior to its use in developing model assumptions.
     Key input to the subsidy models vary by program. Input includes items such as:
            • Contractual terms of the loan or guaranty such as loan amount, interest rate, maturity and
              grace period
            • Borrower characteristics
            • Loan origination methods
            • Economic indicators such as gross domestic product growth and unemployment rate
            • Loan performance assumptions, for example: conditional purchase and prepayment rates and
              recovery rates
            • Loan fee rates
     Valuation Methodology for Pre-1992 Direct Loans and Loan Guaranties
     The SBA values pre-credit reform direct and defaulted guarantied loans by estimating an allowance for
     loan losses. This allowance is offset against gross loan receivables to obtain SBA’s expected net collec-
     tions from these assets. The SBA establishes a 100 percent allowance for pre-credit reform direct and
     defaulted guarantied loans that are past due more that 180 days.
     A liability is also established for active pre-credit reform loan guaranties. The liability is estimated based
     on historical experience.




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B. Credit Program Receivables and Related Foreclosure Property, Net
(Dollars in Thousands)
As of September 30, 2009                                                       Pre-1992 Loans      Post-1991 Loans                   Total
Direct Business Loans
   Business Loans Receivable                                               $          22,865      $        111,870       $        134,735
   Interest Receivable                                                                  1,945                 1,196                  3,141
   Foreclosed Property                                                                  3,104                     –                  3,104
   Allowance                                                                           (1,924)              (28,445)               (30,369)
Total Direct Business Loans                                                           25,990                 84,621               110,611

Direct Disaster Loans
   Disaster Loans Receivable                                                          13,825             8,424,827               8,438,652
   Interest Receivable                                                                   103                29,501                  29,604
   Foreclosed Property                                                                     –                   933                     933
   Allowance                                                                            (980)           (1,597,336)             (1,598,316)
Total Direct Disaster Loans                                                           12,948             6,857,925               6,870,873

Defaulted Guarantied Business Loans & Other Loan Receivables
   Defaulted Guarantied Business Loans                                                 53,790            5,744,177               5,797,967
   Other Loans Receivable (see note below)                                                  –              655,911                 655,911
   Interest Receivable                                                                    655               25,754                  26,409
   Foreclosed Property                                                                  3,270               34,374                  37,644
   Allowance                                                                          (28,984)          (4,341,935)             (4,370,919)
Total Defaulted Guarantied Business Loans & Other Loan Receivables                     28,731            2,118,281               2,147,012
Total Credit Program Receivables & Related Foreclosed Property, Net                                                      $      9,128,496


As of September 30, 2008                                                       Pre-1992 Loans      Post-1991 Loans                   Total
Direct Business Loans
   Business Loans Receivable                                               $          28,253      $        114,620       $        142,873
   Interest Receivable                                                                  2,325                 1,299                  3,624
   Foreclosed Property                                                                  3,104                     –                  3,104
   Allowance                                                                           (1,741)              (26,378)               (28,119)
Total Direct Business Loans                                                           31,941                 89,541               121,482

Direct Disaster Loans
   Disaster Loans Receivable                                                          16,595             8,609,972               8,626,567
   Interest Receivable                                                                   121                35,649                  35,770
   Foreclosed Property                                                                     –                   999                     999
   Allowance                                                                            (978)           (1,574,082)             (1,575,060)
Total Direct Disaster Loans                                                           15,738             7,072,538               7,088,276

Defaulted Guarantied Business Loans & Other Loan Receivables
   Defaulted Guarantied Business Loans                                                 56,127            3,510,385               3,566,512
   Other Loans Receivable (see note below)                                                  –              627,007                 627,007
   Interest Receivable                                                                    458               14,453                  14,911
   Foreclosed Property                                                                  3,467               16,701                  20,168
   Allowance                                                                          (29,288)          (2,886,127)             (2,915,415)
Total Defaulted Guarantied Business Loans & Other Loan Receivables                     30,764            1,282,419               1,313,183
Total Credit Program Receivables & Related Foreclosed Property, Net                                                      $      8,522,941

Note: Other Loan Receivables include payments advanced by the SBA against future reimbursements in the SBIC and 504 Guaranty Programs.




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     C. Loans Disbursed and Outstanding Loan Obligations
     (Dollars in Thousands)


     Direct LOANS
     New Loans Disbursed During the Year Ending September 30,                                    2009               2008
     Business Direct Loan Program                                                       $       23,928      $      16,429
     Disaster Loan Program                                                                     725,405            860,629
     Total Direct Loans Disbursed                                                       $      749,333      $     877,058

     Outstanding Loan Obligations as of September 30,                                            2009               2008
     Business Direct Loan Program                                                       $       38,130      $      25,576
     Disaster Loan Program                                                                     211,128            468,200
     Total Direct Loan Obligations                                                      $      249,258      $     493,776

     Guarantied Loans
     New Loans Disbursed During the Year Ending September 30,                                      2009               2008
     Total Principal Disbursed at Face Value                                            $    12,728,017     $   18,152,218
     Total Principal Disbursed Guarantied by the SBA                                         10,665,284         14,685,373

     Outstanding Loan Obligations as of September 30,                                             2009               2008
     Business Guarantied Loan Programs                                                  $     9,717,347     $   11,335,863

     Loans Outstanding as of September 30,                                                         2009               2008
     Total Principal Outstanding at Face Value                                          $    74,856,050     $   75,088,280
     Total Principal Outstanding Guarantied by the SBA                                       62,203,856         61,709,613




     D. Subsidy Cost Allowance Balances
     (Dollars in Thousands)


     For the Years Ending September 30,                                                           2009               2008
     Post-1991 Business Direct and Purchased Guarantied Loans
     Beginning Balance of Allowance Account                                             $     2,912,506     $    3,246,479
      Current Year’s Subsidy (see 6G for breakdown by component)                                   2,518              1,579
      Loans Written Off                                                                      (1,486,461)        (1,420,426)
      Subsidy Amortization                                                                        (2,028)            (2,521)
     Allowance Related to Guarantied Loans Purchased This Year                                2,909,644          1,032,790
      Miscellaneous Recoveries and Costs                                                         29,531             42,351
      Balance of Subsidy Allowance Account before Reestimates                                 4,365,710          2,900,252
     Technical Assumptions/Default Reestimates                                                     4,670            12,253
     Ending Balance of Allowance Account                                                $     4,370,380     $    2,912,505

     Post-1991 Disaster Direct Loans
     Beginning Balance of Allowance Account                                             $     1,574,082     $    1,563,019
     Current Year’s Subsidy (see 6G for breakdown by component)                                 111,638            141,716
     Loans Written Off                                                                         (302,239)          (331,081)
     Subsidy Amortization                                                                       (62,462)           (37,692)
     Miscellaneous Recoveries and Costs                                                          33,008             28,020
     Balance of Subsidy Allowance Account before Reestimates                                  1,354,027          1,363,982
     Technical Assumptions/Default Reestimates                                                  243,309            210,100
     Ending Balance of Allowance Account                                                $     1,597,336     $    1,574,082




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E. Loan Guaranty Liability Balances
(Dollars in Thousands)


For the Years Ending September 30,                                                                2009                           2008
Pre-1992 Business Loan Guaranties
Beginning Balance of Liability for Loan Guaranties                                 $               816            $             1,113
Adjustment to Expected Losses, Guaranties Outstanding                                                (7)                         (297)
Ending Balance of Liability for Loan Guaranties                                                    809                            816

Post-1991 Business Loan Guaranties
Beginning Balance of Liability for Loan Guaranties                                          1,824,735                     1,736,747
Current Year’s Subsidy (see 6G for breakdown by component)                                      98,459                        3,270
Loan Modifications                                                                              13,216                            –
Fees                                                                                          402,711                       654,399
Interest Accumulation Factor                                                                   (59,446)                      (1,483)
Claim Payments to Lenders                                                                  (3,913,241)                   (2,111,223)
Adjustment Due to Reestimate & Guarantied Loan Purchases                                    1,003,597                     1,078,433
 Miscellaneous Recoveries and Costs                                                            (61,040)                      39,774
Balance of Liability for Loan Guaranties before Reestimates                                  (691,009)                    1,399,917
Technical Assumptions/Default Reestimates                                                   4,684,836                       424,818
Ending Balance of Liability for Loan Guaranties                                             3,993,827                     1,824,735

Total Ending Balance of Liability for Loan Guaranties                              $        3,994,636             $          1,825,551




F. 2009 Subsidy Rates By Program and Component
                                                    Total
Loan Programs                                                         Financing              Default          Other                  Fee
                                                  Subsidy
Guaranty
7(a)                                                0.00%                0.00%                3.42%           0.00%               -3.42%
504 CDC                                            -0.07%                0.00%                1.79%           0.34%               -2.20%
SBIC Debenture                                      0.00%                0.00%                5.38%           0.03%               -5.41%

Direct
Disaster                                           14.92%               12.43%                9.05%          -6.56%               0.00%
Microloan                                          11.66%                7.57%                0.37%           3.72%               0.00%

ARRA
7(a) (gty)                                          3.10%                0.00%                4.68%           0.00%               -1.58%
504 CDC (gty)                                       2.14%                0.00%                1.81%           0.34%               -0.01%
ARC (gty)                                          75.77%               20.16%               55.61%           0.00%                0.00%
7(a) Floor Plan (gty)                               0.20%                0.00%                0.28%           0.00%               -0.08%




The subsidy rates above pertain only to loans obligated in the current year. These rates cannot be ap-
plied to the loans disbursed during the current year to yield the subsidy expense because loans disbursed
during the current year include loans obligated in prior years. Subsidy expenses reported in Table G
result from the disbursement of loans obligated in the current year as well as in prior years, and includes
reestimates.




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     The 7(a) Dealer Floor Plan program is a revolving loan program in which borrowers may draw and repay
     against the approved loan amount several times over the loan term. Based on OMB guidance, the dis-
     bursements in the DFP program reflect this revolving activity and therefore, represent a multiple of the
     approved loan amount. The subsidy rate stated in the table is the “actual” modeled rate, which is subsidy
     dollars divided by the disbursement amount. However, for accounting purposes, the SBA also calculates
     an “execution” subsidy rate, which is applied to each approved DFP loan amount in SBA’s accounting
     system. The “execution” rate is 3.24 percent (Default 4.53 percent, Fee -1.30 percent), which is subsidy
     dollars divided by approved loan amount.

     G. Subsidy Expense by Component
     (Dollars in Thousands)

     For the Years Ending September 30,                                                         2009            2008
     Business Loan Guaranties
      Interest                                                                        $         2,707    $          –
      Defaults                                                                               145,749           3,952
      Fees                                                                                    (52,746)          (679)
      Other                                                                                     2,749              (3)
      Subsidy Expense Before Reestimates and Loan Modifications                                98,459          3,270
      Loan Modifications                                                                       13,216               –
      Reestimates                                                                          4,684,836         424,817
     Total Guarantied Business Loan Subsidy Expense                                   $    4,796,511     $   428,087

     Business Direct Loans
      Interest                                                                        $        1,966     $     1,414
      Defaults                                                                                    22               6
      Other                                                                                      530             159
      Subsidy Expense Before Reestimates                                                       2,518           1,579
      Reestimates                                                                              4,670          12,253
     Total Business Direct Loan Subsidy Expense                                       $        7,188     $    13,832

     Disaster Direct Loans
      Interest                                                                        $       85,592     $     88,583
      Defaults                                                                                68,446           84,837
      Fees                                                                                         –                (5)
      Other                                                                                  (42,400)         (31,699)
      Subsidy Expense Before Reestimates                                                    111,638          141,716
      Reestimates                                                                           243,309          210,100
     Total Disaster Direct Loan Subsidy Expense                                       $     354,947      $   351,816




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H. Administrative Expense
The SBA received appropriations to administer its credit programs, including the making, servicing and
liquidation of its loans and guaranties. Amounts expensed in the Statement of Net Cost are:
(Dollars in Thousands)


For the Years Ending September 30,                                                      2009                          2008
 Disaster Direct Loan Programs                                           $          251,999             $          204,991
 Business Loan Programs                                                             138,601                        135,796
Total Administrative Expense                                             $          390,600             $          340,787




I. Credit Program Subsidy Reestimates
Reestimates are performed annually, on a cohort-by-cohort basis. The purpose of reestimates is to up-
date original program cost estimates to reflect actual cash flow experience as well as changes in forecasts
of future cash flows. Forecasts of future cash flows are updated based on additional information about
historical program performance, revised expectations for future economic conditions, and enhance-
ments to cash flow projection methods. Financial statement reestimates were performed using a full
year of performance data for FY 2009 for all of SBA’s large loan programs and with nine months of ac-
tual and three months of projected performance data for the Secondary Market Guaranty and the small
loan programs.
Business Guarantied Loan Programs
Net subsidy reestimates of business guarantied loan programs follows:
(Dollars in Thousands)


Guarantied Loan Program Subsidy Reestimates                                             2009                            2008
   7(a) Loan Guaranty                                                    $        2,030,243             $           574,840
   7(a) Star                                                                          17,924                           7,273
   504 CDC Debentures                                                             1,565,784                         484,921
   SBIC Debentures                                                                    66,598                       (158,402)
   SBIC Participating Securities                                                    960,151                        (492,386)
   Secondary Market Guaranty Program                                                 (50,803)                        10,196
   All Other Guaranty Loan Programs                                                    (2,730)                        (1,625)
   7(a) Loan Guaranty - ARRA                                                          72,430                               –
   504 CDC Debentures - ARRA                                                          25,239                               –
Total Guarantied Loan Program Subsidy Reestimates                        $        4,684,836             $           424,817



The 7(a) Loan Guaranty program, SBA’s flagship and largest program, had the largest net upward rees-
timates for the guarantied business loan programs in FY 2009 at $2,030.2 million. The 504 Certified
Development Companies program had net upward reestimates of $1,565.8 million. For both programs,
the net upward reestimates were mostly due to the downturn in the economy that resulted in higher
than projected purchases during FY 2009 and an increase in projected purchases for the remaining years
within the cohorts.




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     The SBIC Debentures program had net upward reestimates of $66.6 million. The reestimates were
     mostly due to lower than projected recoveries during FY 2009 and a decrease in projected recoveries for
     the remaining years within the cohorts.
     The SBIC Participating Securities program had a net upward reestimate of $960.2 million. The reesti-
     mates were mostly due to the downturn in the economy that resulted in lower than projected recover-
     ies and higher than projected purchases during FY 2009 and an increase in projected purchases for the
     remaining years within the cohorts.
     The Secondary Market Guaranty program had a net downward reestimate of $50.8 million. This downward
     reestimate was due in part to the lower than projected interest rate paid to investors during FY 2009 and a
     decrease in the projected interest rate paid to investors for the remaining years within the cohorts.
     The 7(a) ARRA and 504 ARRA programs had net upward reestimates of $72.4 million and $25.2 mil-
     lion respectively. These upward reestimates are mostly due to updated model and economic assumptions
     since the original budget estimates. The updated assumptions result in an increase in projected purchases
     for the remaining years within the cohorts.
     Business Direct Loan Programs
     Net subsidy reestimates for business direct loan programs follows:
     (Dollars in Thousands)


     Business Direct Loan Program Subsidy Reestimates                                    2009             2008
        7(m) Microloan                                                           $      4,507     $     13,199
        SBIC Preferred Stock                                                               344             (944)
        All Other Direct Loan Programs                                                    (181)               (2)
     Total Direct Loan Program Subsidy Reestimates                               $      4,670     $     12,253



     The 7(m) Direct Microloan program had net upward reestimates of $4.5 million. These reestimates
     in large part are due to the 2008 cohort that was reestimated for the first time this year. The projected
     defaulted loans for the 2008 cohort are greater than the original budget estimates.
     Disaster Direct Loan Program
     Subsidy reestimates for Disaster direct loan programs follow:
     (Dollars in Thousands)


     Disaster Direct Loan Program Subsidy Reestimates                                    2009             2008
        Disaster                                                                 $    231,117     $    208,430
        World Trade Center Disaster                                                    12,192            1,670
     Total Disaster Direct Loan Program Subsidy Reestimates                      $    243,309     $    210,100



     The Disaster program had net upward reestimates of $231.1 million primarily in the 2006 cohort that
     mostly consists of loans for the Gulf Coast hurricanes in 2005. Those loans currently account for about
     55 percent of the outstanding portfolio of direct Disaster loans. The upward reestimates are primarily
     the result of performance probabilities being updated with actual performance during FY 2009 that
     resulted in an increase in projected defaults.




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 Note 7. General Property and Equipment, Net
Equipment with a cost of $50,000 or more per unit and a useful life of 2 years or more is capitalized at
full cost and depreciated using the straight-line method over the useful life. Other equipment items not
meeting the capitalization criteria are expensed when purchased.
Leasehold improvements with modifications of $50,000 or more and a useful life of 2 years or more are
capitalized and amortized using the straight-line method over the useful life of the improvement or the
lease term, whichever is shorter. Other leasehold improvement expenditures not meeting the capitaliza-
tion criteria are expensed.
Software intended for internal use, whether internally developed, contractor developed or purchased,
is capitalized at cost if the initial unit acquisition cost is $250,000 or more and service life is at least 2
years. Costs that do not meet the capitalization criteria are expensed when incurred.
Capitalized software costs include all direct and indirect costs incurred, including overhead to develop
the software. Software for internal use is amortized using the straight-line method over its useful life,
not to exceed 5 years. Amortization begins when the system is put into operation. The costs of enhance-
ments are capitalized when it is more likely than not that the enhancements will result in significant
additional capabilities.
Assets meeting the capitalization thresholds established, at September 30, 2009 and 2008 are detailed
below.
(Dollars in Thousands)
                                                                                           2009                         2008
  Equipment                                                               $               1,787           $            1,787
  Accumulated Depreciation                                                                  (703)                        (357)
    Net                                                                                   1,084                        1,430


  Leasehold Improvements - Construction in Progress                                          75                            –
  Leasehold Improvements                                                                  1,496                        1,496
  Amortization of Leasehold Improvements                                                   (125)                           –
    Net                                                                                   1,446                        1,496

   Software in Development                                                              4,970                          1,491
   Software in Use                                                                     30,546                         28,994
   Amortization of Software in Use                                                    (29,511)                       (28,994)
      Net                                                                               6,005                          1,491
Total General Property and Equipment, Net                                 $             8,535             $            4,417




 Note 8.         Liabilities Not Covered by Budgetary Resources
Liabilities not covered by budgetary resources are liabilities for which congressional action is needed
before budgetary resources can be provided. These unfunded liabilities at September 30, 2009 and 2008
consisted of:




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     (Dollars in Thousands)
                                                                                               2009               2008
       Intragovernmental Liabilities - Other
        Employment Taxes Payable                                                    $         2,870     $        4,117
        Federal Employee Compensation Act Payable                                             5,843              6,005
       Total Intragovernmental Liabilities - Other                                            8,713             10,122

       Federal Employee Compensation Act Actuarial Liability                                 29,640             27,061

       Surety Bond Guarantee Program Future Claims                                           20,817             24,764

       Other Liabilities
        Prior Liens on Real Estate Payable                                                      409                424
        Accrued Unfunded Annual Leave                                                        25,314             24,547
       Total Other Liabilities                                                               25,723             24,971

       Total Liabilities Not Covered by Budgetary Resources                         $        84,893     $       86,918



     The liability for Surety Bond Guarantees is an estimate of future claims in the SBG Program for guaran-
     ties outstanding at year-end.



      Note 9.          Debt
     Borrowings payable to the Treasury result from loans provided by the Treasury to fund the portion of
     direct loans not covered by subsidy appropriations and to fund the payment of downward subsidy reesti-
     mates and other credit program disbursements (see Note 15). The SBA makes periodic principal repay-
     ments to the Treasury based on the analysis of its cash balances and future disbursement needs.
     Borrowings payable to the Federal Financing Bank are the result of its financing of SBA Section 503
     Debentures issued prior to 1988.
     All debt is intragovernmental and covered by budgetary resources. Debt transactions for the periods
     ending September 30, 2009 and 2008 and resulting balances are:

     Intragovernmental Debt
     (Dollars in Thousands)


     Department of Treasury                                                                     2009               2008
      Beginning Balance                                                             $      9,462,882    $   11,365,675
     New Borrowing                                                                         2,594,270            865,663
     Repayments                                                                           (1,184,398)        (2,768,456)
     Ending Balance                                                                 $    10,872,754     $     9,462,882


     Federal Financing Bank                                                                    2009               2008
      Beginning Balance                                                             $        10,345     $       17,513
      Repayments                                                                              (4,667)            (6,943)
      Change in Interest Payable                                                                (149)              (225)
     Ending Balance                                                                 $          5,529    $       10,345
     Total Debt                                                                     $    10,878,283     $    9,473,227




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 Note 10.          Net Assets of Liquidating Funds Due to Treasury
Net Assets of Liquidating Funds Due to Treasury is the residual of the book value of assets less liability
in the Liquidating Funds for loans made prior to FY 1992. Subsequent to the issuance of its audited
financial statements each year, the SBA returns to the Treasury the portion of this balance that is consid-
ered to be the unobligated balance for budgetary reporting at fiscal year-end.
(Dollars in Thousands)


As of September 30,                                                                    2009                        2008
 Pollution Control Equipment Guaranty Fund                             $               5,052          $            5,272
 Disaster Loan Fund                                                                   18,489                      24,419
 Business Loan and Investment Fund                                                    55,043                      75,098
Total Due Treasury                                                     $              78,584          $          104,789




 Note 11.          Other Liabilities
Other liabilities at September 30th were:
(Dollars in Thousands)
                                                                                       2009                        2008
Other Liabilities - Intragovermental
Entity
   Current
      Employment Taxes Payable                                         $               3,457          $            3,167
      Advances from Other Agencies                                                     3,580                       5,823
   Total Current                                                                       7,037                       8,990
   Non-current
      Employment Taxes Payable                                                         2,870                       4,117
      Federal Employee Compensation Act Payable                                        5,843                       6,005
      Payable to Federal Financing Bank                                                  305                         435
   Total Non-current                                                                   9,018                      10,557
Total Entity                                                                          16,055                      19,547
Non-entity
   Current
      Payable to Treasury                                                                 7                           7
Total Other Liabilities - Intragovernmental                            $              16,062          $           19,554
Other Liabilities - Public
Entity
   Current
      Accrued Funded Payroll and Benefits                              $              15,158          $           14,209
      Accrued Unfunded Annual Leave                                                   25,314                      24,547
      Suspense Accounts                                                                  327                         454
   Total Current                                                                      40,799                      39,210
   Non-current
      Prior Liens on Real Estate Payable                                                 409                         424
   Total Non-current                                                                     409                         424
Total Entity                                                                          41,208                      39,634
Non-entity
   Current
     Non-entity Current Payable                                                           4                           4
Total Other Liabilities - Public                                       $              41,212          $           39,638


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      Note 12.          Leases
     The SBA leases all facilities from the General Services Administration. The SBA enters into an Occupancy
     Agreement with GSA for each facility. GSA, in turn, leases commercial facilities or provides space in
     federal buildings. Agreements for space in federal buildings can be vacated with 120 to 180 days notice.
     However, the SBA anticipates continuing the same or similar facilities leases in the future. These leases
     with GSA are operating leases and are expensed in the Statement of Net Cost when incurred. FY 2009
     and 2008 facilities lease costs were $42.7 million and $41.5 million. Future lease payments shown below
     assume a 3 percent inflation factor from the following years’ projected totals as estimated by GSA.


     (Dollars in Thousands)
     Future Facilities Operating Lease Payments
     FY                                            Lease Pmts
     2010                                   $          41,134
     2011                                              42,369
     2012                                              43,640
     2013                                              44,949
     2014                                              46,298
     After 2014                                        51,353
     Total                                  $         269,743




      Note 13.          Non-entity Reporting
     Non-entity Assets are assets held by the SBA but not available to the SBA. The primary non-entity asset
     held by the SBA is Fund Balance with the Treasury held in the Treasury general fund accounts specifi-
     cally established for SBA’s downward subsidy reestimates for its discretionary loan programs. Because
     the loan programs are discretionary, the downward reestimates are not available to the SBA and they are
     returned to the Treasury in the fiscal year following the accrual of the reestimates. During the year, these
     general fund accounts contain SBA’s prior year reestimates. At year-end, the funds are swept by the
     Treasury with the exception of one deposit fund. Also at year-end, the SBA accrues the current year’s
     reestimates, including downward reestimates as applicable. For the downward reestimates, in the loan
     financing funds, the SBA records an accrual adjustment that records a transfer out to the non-entity
     fund, a reduction of subsidy allowance or loan guarantee liability, and an account payable to the non-
     entity fund. In the loan program funds the SBA records a reduction of loan subsidy expense and the
     associated impact on the net cost. The non-entity Treasury general funds contain a corresponding ac-
     count receivable in anticipation of the receipt of the downward reestimates in the following year and a
     Downward Reestimate Payable to Treasury.
     For consolidated financial statement presentation, the SBA eliminates the payable to the non-entity
     fund and the non-entity Treasury general fund receivable from the financing funds; since both are
     included in SBA’s reporting entity. The Downward Reestimate Payable to Treasury in the non-entity
     Treasury general fund is not eliminated and is reflected on the Balance Sheet as a liability line item.




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(Dollars in Thousands)

                                                                                 2009                          2008
Entity
Financing Fund Payable                                           $           (64,875)            $          (466,887)

Non-entity
Miscellaneous Receipts Fund Receivable                                        64,875                         466,887
Downward Reestimate Payable to Treasury                                      (64,875)                       (466,887)

Balance Sheet Reported Payable                                   $           (64,875)            $          (466,887)




 Note 14. Consolidated Statement of Net Cost
Federal cost accounting standards require the SBA to report operating costs by strategic goal activity.
Full costs include all direct and indirect costs for a strategic goal. Full costs are reduced by exchange
(earned) revenues to arrive at net operating cost.

Operating Cost
The full and net operating costs of SBA’s major strategic goals are presented in the Consolidated
Statement of Net Cost. Full costs are comprised of all direct costs for the strategic goals and those
indirect costs which can be reasonably assigned or allocated to the strategic goals, including employee
pension and other retirement benefit costs paid by the OPM and charged to the SBA.

Earned Revenue
Earned revenues arise from exchange transactions, and are deducted from the full cost of SBA’s major
strategic goals to arrive at net strategic goals costs. The SBA recognizes earned revenues when reimburse-
ments are payable from other federal agencies and the public, as a result of costs incurred or services
performed. A major source of earned revenue include: interest earned on SBA’s outstanding Business and
Disaster loan portfolios and interest earned on uninvested funds in the credit reform financing accounts.

Reporting by Strategic Goal
The SBA reports costs consistent with its three strategic goals. The costs of Goal 4 “ensure that all SBA
strategic goals operate at maximum efficiency and effectiveness by providing them with high quality ex-
ecutive leadership and support services” are fully allocated to the other three strategic goals. Goal 4 costs
are estimated at $121.5 million and $117.8 million for FY 2009 and FY 2008. Costs Not Assigned to
Strategic Goals on the Statement of Net Cost includes costs of congressionally mandated grant pro-
grams and the Office of the Inspector General.
Intragovernmental Gross Cost is cost incurred by the SBA in exchange transactions with other fed-
eral agencies. Gross Cost with the Public is cost incurred by the SBA in exchange transactions.
Intragovernmental Earned Revenue is revenue earned by the SBA in exchange transactions with other
federal agencies. Earned Revenue from the Public is revenue earned by the SBA in exchange transactions.
The classification as Intragovernmental Costs or Gross Cost with the Public relate to source of the goods
and services received by the SBA and not to the classification of related revenue. The classification of
revenue or cost being defined as “intragovernmental” or “public” is defined on a transaction by transac-

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     tion basis. The purpose of this classification is to enable the federal government to provide consolidated
     financial statements, and not to match the public and intragovernmental revenue with costs that are
     incurred to produce public and intragovernmental revenue.
     (Dollars in Thousands)
     Intragovermental costs and exchange revenue
     For the Years ending September 30                                                          2009            2008
     Strategic Goal 1:
       Expand America’s Ownership Society, Particularly in Underserved Markets
       Intragovernmental Gross Cost                                                     $     237,923   $    161,121
       Gross Cost with the Public                                                           5,172,008        834,610
       Total Strategic Goal 1 Gross Cost                                                    5,409,931        995,731

       Intragovernmental Earned Revenue                                                      113,832          79,491
       Earned Revenue from the Public                                                         52,511          69,831
       Total Earned Revenue Strategic Goal 1                                                 166,343         149,322

     Strategic Goal 2:
       Provide Timely Financial Assistance to Homeowners, Renters, Nonprofit
       Organizations and Businesses Affected by Disaster
       Intragovernmental Gross Cost                                                           479,914         522,532
       Gross Cost with the Public                                                             601,318         530,498
       Total Strategic Goal 2 Gross Cost                                                    1,081,232       1,053,030

       Intragovernmental Earned Revenue                                                       74,732         128,459
       Earned Revenue from the Public                                                        331,172         339,709
       Total Earned Revenue Strategic Goal 2                                                 405,904         468,168

     Strategic Goal 3:
       Improve Economic Environment for Small Business
       Intragovernmental Gross Cost                                                            3,348           3,294
       Gross Cost with the Public                                                             11,158          10,820
       Total Strategic Goal 3 Gross Cost                                                      14,506          14,114

     Cost Not Assigned to Strategic Goals
       Intragovernmental Gross Cost                                                           14,375          27,991
       Gross Cost with the Public                                                             47,919          91,940
       Total Gross Cost Not Assigned to Strategic Goal                                        62,294         119,931

     Net Cost of Operations                                                             $   5,995,716   $   1,565,316




      Note 15.          Statement of Budgetary Resources
     The Statement of Budgetary Resources presents information about total budgetary resources available
     to the SBA and the status of those resources, as of September 30, 2009 and 2008. SBA’s total budget-
     ary resources were $5.0 billion and $3.0 billion for the years ended September 30, 2009 and 2008.
     Additionally, $7.4 billion and $6.1 billion of nonbudgetary resources including borrowing authority
     and collections of loan principal, interest and fees, in financing funds were reported for the years ended
     September 30, 2009 and 2008.


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Adjustments to Beginning Balance of Budgetary Resources
The SBA made no adjustments to the beginning budgetary resources during the years ended September
30, 2009 and 2008.

Permanent Indefinite Appropriations
The SBA receives permanent indefinite appropriations annually to fund increases in the projected
subsidy costs of loan programs as determined by the reestimation process required by the Federal Credit
Reform Act of 1990. The appropriations are received initially in the SBA Program Funds and then
transferred to the Financing Funds where they are used to fund obligations. SBA’s Liquidating Funds
also receive permanent indefinite appropriations to fund obligations. The Financing Funds are used to
account for credit program obligations made subsequent to FY 1991; Liquidating Funds are used to ac-
count for credit program obligations made prior to FY 1992.
Decreases in projected subsidy costs in the Financing Funds are returned to the Treasury through SBA’s
annual reestimation process. The prior year’s ending unobligated balances in SBA’s Liquidating Funds
are also transferred to the Treasury annually.

Borrowing Authority and Terms of Borrowing
The SBA is authorized to borrow from the Treasury’s Bureau of Public Debt when funds needed to
disburse direct loans and purchase guarantied loans exceed subsidy costs and collections in the non-
budgetary loan financing funds. In FY 2009 and 2008, the SBA received $3.5 billion and $1.3 billion
of borrowing authority from the OMB. The SBA pays interest to the Treasury based on Treasury’s cost
of funds. The rate at which interest is paid to the Treasury on the amounts borrowed (or received from
the Treasury on uninvested cash balances) in a loan financing fund for a particular cohort is a disburse-
ment-weighted average discount rate for cohorts prior to FY 2001 and a single effective rate for cohorts
beginning with FY 2001. The SBA calculates and repays borrowings not needed for working capital
at midyear for prior year cohorts. The SBA uses the loan principal, interest and fees collected from the
public in its loan financing funds to repay its borrowings. The repayment maturity dates for the borrow-
ing from the Treasury are based on the loan maturities used in the subsidy calculation. The maturities
range from 16 years for Direct Business loans, 25 years for Guarantied Business loans and 30 years for
Disaster loans.

Apportionment Categories of Obligations Incurred
During FY 2009 and FY 2008, the SBA incurred $9.6 billion and $6.1 billion of direct and reimburs-
able obligations of which $0.7 billion and $0.6 billion was apportioned in category A; $8.9 billion and
$5.5 billion was apportioned in category B. Category A apportionments are restricted by quarter and
program, Category B apportionments are restricted by purpose and program.




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     Unobligated Balances
     Unobligated balances at September 30, 2009 and 2008 are $2.7 billion and $3.0 billion which include
     $1.3 billion and $1.6 billion of unavailable unobligated balances. These balances are unavailable primar-
     ily because they are unapportioned by OMB. The SBA accumulates the majority of these unobligated
     balances in its nonbudgetary financing accounts during the fiscal year ($1.2 billion in FY 2009 and $1.5
     billion in FY 2008) from program collections that are used primarily to repay the Treasury borrowings
     in the following fiscal year. In addition, unobligated balances are accumulated in budgetary accounts
     from appropriations ($1.5 billion in FY 2009 and $1.4 billion in FY 2008) that are used to finance
     SBA’s ongoing program operations.

     Undelivered Orders
     Undelivered orders for the periods ended September 30, 2009 and 2008 were $0.8 billion and
     $0.8 billion.

     Differences between the Statement of Budgetary Resources
     and the Budget of the U. S. Government
     There was a $619 million difference between the FY 2008 Statement of Budgetary Resources and the
     President’s FY 2010 budget submission in the Beginning Adjusted Unobligated Balance line of the
     business Guaranteed Loan Financing Fund. The SBA carried forward unused borrowing authority into
     FY2008 in this Fund. For FACTS II and MAX reporting, the SBA cancelled this unused borrowing au-
     thority and reclassified to the beginning unobligated balance line. For financial statement reporting the
     SBA cancelled this unused borrowing authority during FY 2008 and this action was treated as current
     year activity on the Permanently Not Available line on the SBR.
     The President’s Budget with actual numbers for FY 2011 has not yet been published. The SBA expects
     no material differences between the President’s Budget “actual” column and the FY 2009 reported re-
     sults when the budget becomes available in February 2010.



      Note 16. Reconciliation of Budgetary Obligations
     Incurred to Net Cost of Operations
     The SBA presents the Statement of Net Cost using the accrual basis of accounting. This differs from the
     obligation-based measurement of total resources supplied, both budgetary and from other sources, on
     the Statement of Budgetary Resources.




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The Federal Financial Accounting Standard No. 7 requires “a reconciliation of proprietary and budget-
ary information in a way that helps users relate the two.” The focus of this presentation is to reconcile
budgetary net obligations to the net cost of operations. The objective of this information is to categorize
the differences between budgetary and financial (proprietary) accounting.
Consolidated Reconciliation of Budgetary Obligations to Net Cost
For the years ended September 30, 2009 and 2008

(Dollars in Thousands)
                                                                                                             2009                     2008
Resources Used to Finance Activities
Budgetary Resources Obligated
   Obligations Incurred                                                                      $         9,635,132       $          6,133,235
   Less: Spending Authority from Offsetting Collections and Recoveries                                 4,946,652                  4,333,868
   Obligations Net of Offsetting Collections and Recoveries                                            4,688,480                  1,799,367
   Less: Offsetting Receipts                                                                             489,395                    742,578
Net Obligations                                                                                        4,199,085                  1,056,789
Other Resources
   Imputed Financing                                                                                       25,549                   24,014
   Other Financing Sources                                                                                (88,187)                (567,900)
Net Other Resources Used to Finance Activities                                                           (62,638)                 (543,886)
Total Resources Used to Finance Activities                                                             4,136,447                   512,903

Resources that Do Not Finance Net Cost of Operations
   (Increase) Decrease in Budgetary Resources Obligated for Goods, Services,
       and Benefits Ordered But Not Yet Provided                                                          193,832                   561,903
   Resources that Fund Expenses Recognized in Prior Periods                                            (1,313,301)                 (518,200)
   Budgetary Offsetting Collections and Receipts that Do Not Affect Net Cost of Operations
       Credit Program Collections                                                                        4,042,182             3,558,121
       Offsetting Receipts                                                                                 489,395               742,578
   Resources that Finance the Acquisition of Assets or Liquidation of Liabilities                       (6,189,101)           (4,621,804)
   Other - Current Year Liquidating Equity Activity                                                            863                 4,502
   Other Resources that Do Not Affect Net Cost of Operations                                                  (100)                 (399)
Total Resources that Do Not Finance Net Cost of Operations                                             (2,776,230)              (273,299)
Total Resources Used to Finance the Net Cost of Operations                                               1,360,217               239,604

Components of the Net Cost of Operations that Will Not
Require or Generate Resources in the Current Period
Components Requiring or Generating Resources in Future Periods
   Change in Annual Leave Liability                                                                           767                     1,639
   Upward Reestimates of Credit Subsidy Expense                                                        4,637,148                  1,316,143
   Change in Revenue Receivable from Public                                                                (3,623)                    1,869
   Provision for Losses on Estimated Guaranties                                                            (3,947)                    1,176
   Change in Unfunded Employee Benefits                                                                     2,579                       740
Total Components Requiring or Generating Resources in Future Periods                                   4,632,924                  1,321,567

Components Not Requiring or Generating Resources
   Depreciation or Amortization                                                                               987                    1,110
   Change in Bad Debt Expense - Pre-1992 Loans                                                              2,094                    3,241
   Other (Income) Expenses Not Requiring Budgetary Resources                                                 (507)                    (206)
Total Components Not Requiring or Generating Resources                                                      2,574                    4,145
Total Components of the Net Cost of Operations that Will Not
Require or Generate Resources in the Current Period                                                    4,635,499                  1,325,712
Net Cost of Operations                                                                       $         5,995,716       $          1,565,316



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     Liabilities Not Covered by Budgetary Resources on the Balance Sheet (Note 8) differs from
     Components Requiring or Generating Resources in Future Periods in this reconciliation primarily due
     to reestimated subsidy costs of loan programs. The subsidy costs are shown in the Statement of Net
     Cost and are to be covered by budgetary resources but these resources, while available under permanent
     and indefinite authority, were not provided by year-end. Additionally, there will always be a difference
     for existing liabilities because the Reconciliation of Budgetary Obligations Incurred to Net Cost of
     Operations reports only current year changes, not balances.
     The table below details these differences:
     (Dollars in Thousands)


     As of September 30,                                                                         2009             2008
     Current Year Liabilities Not Covered By Budgetary Resources                       $      84,893     $      86,918
     Less: Prior Year                                                                         86,918            85,534
     Change in Liabilities Not Covered By Budgetary Resources                                  (2,025)           1,384
     Upward Reestimates of Credit Subsidy Expense                                          4,637,148         1,316,143
     Change in Revenue Receivable from Public                                                  (3,623)           1,869
     All Other                                                                                  1,424            2,171
     Components (of Net Cost) Generating Resources in Future Periods
         (Per Reconciliation Above)                                                    $   4,632,924     $   1,321,567




      Note 17. Significant Events

     Recovery Act
     The American Recovery and Reinvestment Act was signed by the President on February 17, 2009. The
     Recovery Act provided $730 million to the SBA to alleviate the effect of the current economic recession
     on American small business. These funds were allocated to SBA as follows:
     • $636 million for loan program credit subsidies
     • $45 million for administrative expense
     • $24 million for microloan technical assistance grants
     • $15 million for surety bond guaranty cost
     • $10 million for Inspector General oversight and audit
     On March 16, 2009 the SBA implemented Sections 501 and 502 of the Recovery Act. Section 501
     provided for the reduction or elimination of guaranty fees for 7(a) loan guaranties and for the payment
     by SBA of the 1.5 percent processing fee to 504 lenders previously due from 504 program borrowers. The
     SBA also implemented a small Dealer Floor Plan pilot program to make loans to retail dealerships includ-
     ing auto dealers that began in July 2009 and qualified for Section 501 provisions. Section 502 provided
     for the increase of the SBA guaranty percent on 7(a) guaranties to 90 percent. Loan program credit
     subsidies of $375 million were provided for Section 501 and Section 502 for use by September 30,


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2010. The SBA made Section 501 of the Recovery Act retroactive to February 17, 2009. As a result,
the SBA rebated upfront 7(a) guaranty fees collected during the interim between February 17th and the
implementation of Section 501. Also, the SBA paid the 1.5 percent processing fee on 504 loan guaran-
ties approved beginning February 17, 2009. The $13.2 million cost of the retroactive implementation
of Section 501 was a “modification” under Federal Credit Reform requirements. The Recovery Act
Sections 501 and 502 supported $8.7 billion of guaranties, and increased bank participation in SBA
programs during FY 2009.
On June 15, 2009 the SBA began taking applications for the America’s Recovery Capital Loan Program
authorized by Section 506 of the Recovery Act. ARC Loans are made by participating 7(a) program
lenders to borrowers that need short term help to make their principal and interest payments on existing
qualifying loans. ARC Loans can cover up to six monthly installments (or a maximum of $35,000) and
no-interest deferred-payment loans, have no fees on them and are 100 percent guaranteed by the SBA. The
SBA pays the borrower’s interest to the 7(a) lender based on reports provided retroactively by the lender.
Loan program credit subsidies of $255 million were provided in the Recovery Act for ARC Loans that can
be approved until September 30, 2010. During FY 2009 $94 million of ARC Loans were approved.

Economic Conditions
The economic downturn continued in FY 2009 as indicated by lower GDP and increased unemploy-
ment. These macroeconomic factors had an impact on the FY 2009 performance of SBA’s loan portfolio.
Purchases of defaulted guaranties increased 85 percent over FY 2008. Projections for future purchases
are also higher primarily due to higher unemployment forecasts as indicated by the FY 2010 President’s
Economic Assumptions. In fact, projected quarterly unemployment rates for FY 2010 are 88 percent
higher (and 40 percent higher on average through FY 2018) in the current PEA as compared to this
time last year. All of these factors combined caused the upward reestimate in SBA loan programs (as dis-
cussed in Note 61). Under the Federal Credit Reform Act, upward reestimates are automatically covered
by permanent indefinite budget authority. Such authority provides the SBA resources to address losses
incurred in its existing portfolio without further action by Congress.
The Recovery Act programs that were implemented in FY 2009 contributed to an increase in monthly
lending activity. Nevertheless, it is too early to fully evaluate the ultimate impact of the economy and
the Recovery Act programs on SBA’s portfolio risk and performance. There continues to be volatility
and uncertainty in the financial markets and the Recovery Act programs are not yet seasoned enough to
measure their ultimate performance.



  Did
  you                             In FY 2009 85 percent of disaster assistance loans approved were for
  know                            homeowners and renters to repair or replace disaster-damaged primary
                                  residences and personal property.




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     Required Supplementary Information
                                                 Combining Statement of Budgetary Resources
                                                                  For the year ended September 30, 2009

     (Dollars in Thousands)
                                                                  BLIF                                    DLF                              SBGRF          PCECGF
                                                                               Nonbudgetary                         Nonbudgetary
     BUDGETARY RESOURCES                                      Budgetary           Financing        Budgetary           Financing         Budgetary    Budgetary
     Unobligated Balance
       Brought Forward October 1                         $      29,458     $       678,312     $ 1,217,311      $       868,753      $     30,371     $    3,220
     Recoveries of Prior Year Obligations                          467               1,221          35,538              219,431                 –              –

     Budget Authority
        Appropriations Received                              2,292,609                   –          189,159                   –            17,000          3,000
        Borrowing Authority                                          –           2,067,084                –           1,388,482                 –              –
        Spending Authority from Offsetting Collections
            Earned                                             10,652            2,745,872            5,113            1,296,311            8,048             195
            Change in Unfilled Customer Orders                      –              201,125                –               (44,114)              –               –
     Total Budget Authority                                2,303,261             5,014,081         194,272             2,640,679           25,048           3,195
     Nonexpenditure Transfers, Net Budget Authority                 –                     –               –                     –               –               –
     Permanently Not Available                                (25,847)              (84,521)         (9,934)          (1,961,180)               –          (3,220)
     Total Budgetary Resources                           $ 2,307,339       $     5,609,093     $ 1,437,187      $      1,767,683     $     55,419     $     3,195

     STATUS OF BUDGETARY RESOURCES
     Obligations Incurred, Net
        Direct                                           $ 1,832,115       $     5,053,057     $    290,413     $     1,128,408      $          –     $        –
        Reimbursable                                         139,075                     –          288,000                   –             6,023              –
     Total Obligations Incurred, Net                       1,971,190             5,053,057          578,413           1,128,408             6,023              –

     Unobligated Balances, Available                         233,485               250,391          73,004              639,275             6,054          3,195
     Unobligated Balances, Not Available                     102,664               305,645         785,770                    –            43,342              –
     Total Status of Budgetary Resources                 $ 2,307,339       $     5,609,093     $ 1,437,187      $     1,767,683      $     55,419     $    3,195

     CHANGE IN OBLIGATED BALANCES
     Obligated Balance Brought Forward, Net October 1
        Unpaid Obligations Brought Forward               $       7,287     $        88,859     $     77,111     $       472,306      $        622     $        –
        Uncollected Customer Payments from Federal
            Sources Brought Forward                                  –               (2,778)              –              (76,085)               –              –
     Total Obligated Balance Brought Forward, Net                7,287              86,081           77,111             396,221               622              –

     Obligations Incurred                                    1,971,190           5,053,057          578,413           1,128,408             6,023              –
     Gross Outlays                                           (1,771,524)         (4,965,735)       (587,343)          (1,166,309)           (6,627)            –
     Recoveries of Prior Year Unpaid Obligations                   (467)             (1,221)         (35,538)           (219,431)               –              –
     Change in Uncollected Customer Payments from
      Federal Sources                                                 –           (201,125)                –             44,114                 –              –
     Obligated Balance, Net, End of Period
        Unpaid Obligations                                     206,486             174,960           32,643             214,974                18              –
        Uncollected Customer Payments from Federal
          Sources                                                    –            (203,903)               –              (31,971)               –              –
     Total Obligated Balance, Net, End of Period         $     206,486     $      (28,943)     $     32,643     $       183,003      $         18     $        –

     Net Outlays
        Gross Outlays                                    $ 1,771,524       $      4,965,735    $    587,343     $      1,166,309     $      6,627              –
        Offsetting Collections                                (10,652)           (2,745,872)          (5,113)         (1,296,311)          (8,048)          (195)
     Net Outlays Before Offsetting Receipts                1,760,872              2,219,863         582,230             (130,002)          (1,421)          (195)
        Offsetting Receipts                                         –              (462,135)               –              (27,201)              –              –
     Net Outlays                                         $ 1,760,872       $      1,757,728    $    582,230     $       (157,203)    $     (1,421)    $     (195)




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                                              Combining Statement of Budgetary Resources
                                                            For the year ended September 30, 2009

(Dollars in Thousands)
                                                              SE                 OIG            BATF               TOTAL               TOTAL
                                                                                                                                  Nonbudgetary
BUDGETARY RESOURCES                                     Budgetary           Budgetary        Budgetary          Budgetary            Financing              Total
Unobligated Balance
  Brought Forward October 1                         $    141,833        $      7,287     $        274      $   1,429,754      $     1,547,065     $    2,976,819
Recoveries of Prior Year Obligations                      28,404                 228                2             64,639             220,652            285,291

Budget Authority
   Appropriations Received                               521,550              26,750                 –         3,050,068                    –          3,050,068
   Borrowing Authority                                         –                   –                 –                 –            3,455,566          3,455,566
   Spending Authority from Offsetting Collections
       Earned                                            404,738                 641               25            429,412             4,042,183         4,471,595
       Change in Unfilled Customer Orders                 33,423                (668)               –             32,755               157,011           189,766
Total Budget Authority                                   959,711              26,723               25          3,512,235             7,654,760        11.166,995
Nonexpenditure Transfers, Net Budget Authority             2,953                    –               –              2,953                     –            2,953
Permanently Not Available                                (10,232)                 (69)              –             (49,302)          (2,045,701)      (2,095,003)
Total Budgetary Resources                           $ 1,122,669         $     34,169     $        301      $   4,960,279      $      7,376,776    $ 12,337,055

STATUS OF BUDGETARY RESOURCES
Obligations Incurred, Net
   Direct                                           $    461,659        $     18,520     $         38      $   2,602,745      $     6,181,465     $    8,784,210
   Reimbursable                                          417,538                 286                –            850,922                    –            850,922
Total Obligations Incurred, Net                          879,197              18,806               38          3,453,667            6,181,465          9,635,132

Unobligated Balances, Available                         206,333               15,055              263            537,389              889,666        1,427,055
Unobligated Balances, Not Available                      37,139                  308                –            969,223              305,645        1,274,868
Total Status of Budgetary Resources                 $ 1,122,669         $     34,169     $        301      $   4,960,279      $     7,376,776     $ 12,337,055

CHANGE IN OBLIGATED BALANCES
Obligated Balance Brought Forward, Net October 1
   Unpaid Obligations Brought Forward               $    334,457        $      2,148     $           5     $     421,630      $       561,165     $     982,795
   Uncollected Customer Payments from
       Federal Sources Brought Forward                         –                   –                 –                 –               (78,863)          (78,863)
Total Obligated Balance Brought Forward, Net             334,457               2,148                 5           421,630              482,302           903,932

Obligations Incurred                                     879,197              18,806                38          3,453,667            6,181,465         9,635,132
Gross Outlays                                           (814,264)            (17,408)              (14)        (3,197,180)          (6,132,044)       (9,329,224)
Recoveries of Prior Year Unpaid Obligations               (28,404)              (228)                (2)           (64,639)           (220,652)         (285,291)
Change in Uncollected Customer Payments from
 Federal Sources                                               –                   –                 –                  –            (157,011)         (157,011)
Obligated Balance, Net, End of Period
   Unpaid Obligations                                    370,986               3,318               27            613,478              389,934          1,003,412
   Uncollected Customer Payments from Federal
    Sources                                                    –                   –                –                  –             (235,874)          (235,874)
Total Obligated Balance, Net, End of Period         $    370,986        $      3,318     $         27      $     613,478      $       154,060     $      767,538

Net Outlays
   Gross Outlays                                    $    814,264        $     17,408     $          14     $   3,197,180      $      6,132,044    $    9,329,224
   Offsetting Collections                               (438,161)                 27               (25)         (462,167)           (4,042,183)       (4,504,350)
Net Outlays Before Offsetting Receipts                   376,103              17,435               (11)        2,735,013             2,089,861         4,824,874
   Offsetting Receipts                                        (59)                 –                 –                (59)            (489,336)         (489,395)
Net Outlays                                         $    376,044        $     17,435     $        (11)     $   2,734,954      $      1,600,525    $    4,335,479




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                    FIN AN C IAL RE PORTI N G




     Required Supplementary Stewardship Information
     Stewardship Investments in Human Capital for the
     Five Years Ending September 30, 2009
     Human Capital investments are expenses included in net cost for education and training programs that
     are intended to increase or maintain national economic productive capacity and that produce outputs
     and outcomes that provide evidence of maintaining or increasing national productive capacity. The
     definition excludes education and training expenses for Federal personnel.
     Small Business Development Centers deliver management and technical assistance, economic develop-
     ment and management training to existing and prospective small businesses through cooperative agree-
     ments with universities and colleges and government organizations.
     SCORE is a nonprofit organization which provides small business counseling and training under a grant
     from the SBA. SCORE members are successful business men and women who volunteer their time to
     assist aspiring entrepreneurs and small business owners. There are SCORE chapters in every state.
     Women’s Business Centers provide assistance to women business owners and acts as their advocate in
     the public and private sectors in a number of locations around the U.S.
     All Other Training and Assistance Programs includes primarily Small Business Training provided by a
     counselor from a resource partner, district office, or SBA sponsor who delivers a structured program
     of knowledge, information or experience on a business-related subject. The training lasts for one or
     more hours and includes an agenda, attendee list, and a trainer evaluation. The session may be for
     an individual or a class. Training is also available online on a number of subjects of interest to the
     small business person. Other programs not separately detailed include Native American Outreach
     and Drug Free Work Place. As additional years of data accumulate, the investments will be presented
     separately.
     Performance results are discussed in the Management Discussion and Analysis (MD&A) section of
     SBA’s annual Agency Financial Report in the Programs results section of the Executive Summary.
     Significant Human Capital investments occur within the following programs:
     (Dollars in Thousands)
                                                         2009               2008                 2007          2006          2005
     Small Business Development Centers           $   116,909        $    98,484          $    99,748   $   105,743   $   104,075
     SCORE                                              9,899             10,960               12,267        15,285        18,669
     Women’s Business Centers                          21,504             23,655               16,382        10,382        11,172
     All Other Training and Assistance Programs        61,356             41,318               62,787        24,513        46,598

     Total                                        $   209,668        $   174,417          $   191,184   $   155,923   $   180,514




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office of the
inspector general
reports
OFFICE OF THE INSPECTOR GENERAL REPORTS




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Summary of OIG Audit Follow-Up

Summary                                                                   report these to management, the OCFO main-
Throughout the year, the OIG conducts audits of                           tains a database and provides a status report avail-
SBA’s processes, procedures and programs, and                             able on the SBA intranet page. This is updated as
makes recommendations for improvement. Many                               corrective actions are completed. Program offices
of these recommendations are not material, rela-                          also provide regular updates on final action status
tive to their dollar impact on SBA’s financial and                        that are used to update the database.
administrative operation, but are very beneficial                         The OCFO continues to take aggressive steps to
to management. Program management has the                                 improve management’s attention to these issues,
option to agree or disagree with OIG recom-                               resulting in 133 final actions during FY 2009. Of
mendations. If agreement cannot be reached, the                           these final actions, 12 were monetary and 121
issue can be raised to a higher level by the OIG.                         were non-monetary.
Once both management and the OIG agree with
a recommendation, it becomes a “management                                The following two charts depict SBA’s monetary
decision.” The manager develops a specific action                         final action activity: audit recommendations
plan and provides a target date for completion as                         with disallowed or questioned costs, and audit
part of the “management decision.” The corrective                         recommendations with funds put to better use.
action is referred to as a “final action.”                                The status of all audit recommendations is recon-
                                                                          ciled with the OIG to ensure actions are posted
The Office of the Chief Financial Officer is                              promptly and accomplished in accordance with
responsible for monitoring the final actions and                          the agreed-upon target dates.
reporting on their implementation. To track and


TABLE I

             Final Action On Audit Recommendations With Disallowed / Questioned Costs
                                                October 1, 2008 – September 30, 2009
                                                                                                                   Disallowed Costs
                                                                                                    Number of
                                                                                                                      (Rounded to
                                                                                                 Recommendations
                                                                                                                      Thousands)
  A. Recommendations with management decisions on which final action had not been taken at the               7       $       7,429
     beginning of the period.

  B. Recommendations on which management decisions were made during the period.                             10       $       1,840
  C. Total recommendations pending final action during period.                                              17       $       9,269
  D. Recommendations on which final action was taken during the period.
       1. Recoveries:
            (a) Collections and Offsets                                                                      7       $       1,281
            (b) Property                                                                                     0       $           0
            (c) Other                                                                                        0       $           0
       2. Write-Offs                                                                                         4       $       5,479
       3. Total                                                                                             11       $       6,760
  E. Recommendations needing final action at the end of the period.                                          6       $       2,509




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           TABLE II


                                Final Action On Audit Recommendations With Funds Put To Better Use
                                                             October 1, 2008 – September 30, 2009
                                                                                                                                     Funds to be
                                                                                                                    Number of      Put to Better Use
                                                                                                                 Recommendations     (Rounded to
                                                                                                                                      Thousands)
             A. Recommendations with management decisions on which final action had not been taken at the                    2       $        7,200
                beginning of the period.
             B. Recommendations on which management decisions were made during the period.                                   3       $   1,555,152
             C. Total recommendations pending final action during period.                                                    5       $   1,562,352
            D. Recommendations on which final action was taken during the period.
                  1. Value of recommendations implemented (completed).                                                       1       $      12,700
                  2. Value of recommendations that management concluded should not or could not be implemented               0       $            0
                     or completed.
                  3. Total                                                                                                   1       $      12,700
             E. Recommendations needing final action at the end of the period.                                               4       $   1,549,652




               Success Story

                                                               Recovery Loan Helps Hammer Thru Defeat
                                                               ACE Hardware, Silver Lake, Washington
                                                               Ace Hardware of Silver Lake, Washington opened its doors in July 2009 thanks
                                                               to SBA’s 7(a) loan program. Gary Skrla was laid off from his corporate job
                                                               and headed to the SBA office in Seattle to discuss his business ideas with Ed
                                                               Milan, a SCORE representative. After a few counseling sessions, he decided
                                                               to follow his dream and open a hardware store. His past hardware industry
                                                               experience helped him decide the ACE Hardware franchise would be a good fit.

                                                        Skrla took advantage of the new lending incentives of increased guaran-
                                                        ties and reduced fees. He worked out the details in his loan application and
                                                        received financing through Seattle-based Fortune Bank and the SBA 7(a)
                                                        loan program. Lisa Forrest, vice president with Fortune Bank said, “Gary is a
                perfect example of what can be done with an SBA loan. The Silver Lake area is growing and was ready for additional
                services; and the 20 jobs the new store will generate are welcome, too.”

                As part of the Recovery Act, the SBA temporarily eliminated fees paid by the borrowers in the 7(a) program. The bank
                decision to provide an SBA 7(a) loan for $879,000 resulted in a savings of $19,777 in waived fees. This helped to get
                the inventory needed and provided the working capital to have the store open on time. Hard work and perseverance
                paid off for Skrla. He did his research, knew the industry, hired experienced staff, and sought out business assistance.




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                                        OFFICE OF THE INSPECTOR GENERAL REPORTS




U.S. SMALL BUSINESS ADMINISTRATION

   OFFICE OF INSPECTOR GENERAL




          Report No. 10-02




        Fiscal Year 2010 Report
 on the Most Serious Management and
  Performance Challenges Facing the
     Small Business Administration




           October 16, 2009




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OFFICE OF THE INSPECTOR GENERAL REPORTS




                                        U.S. SMALL BUSINESS ADMINISTRATION
                                           OFFICE OF INSPECTOR GENERAL
                                               WASHINGTON, D.C. 20416




                                                      October 16, 2009

              MEMORANDUM

              TO:           Karen G. Mills
                            Administrator

              FROM:         Peggy E. Gustafson
                            Inspector General

              SUBJECT:      Fiscal Year 2010 Report on the Most Serious Management and
                            Performance Challenges Facing the Small Business Administration

              In accordance with the Reports Consolidation Act of 2000, we are providing you with the
              Office of Inspector General’s (OIG) Fiscal Year (FY) 2010 Report on the Most Serious
              Management and Performance Challenges Facing the Small Business Administration
              (SBA). This report represents our current assessment of Agency programs and/or
              activities that pose significant risks, including those that are particularly vulnerable to
              fraud, waste, error, mismanagement or inefficiencies. The Challenges are not
              presented in order of priority, as we believe that all are critical management or
              performance issues.

              Our report is based on specific OIG, Government Accountability Office (GAO), and
              other official reports, as well as our general knowledge of SBA’s programs and
              operations. Our analysis generally considers those accomplishments that SBA reported
              as of September 30, 2009.

              Within each Management Challenge there are a series of ―recommended actions‖ to
              resolve the Challenge. Each recommended action is assigned a color ―status‖ score.
              The scores are as follows: Green for Implemented; Yellow for Substantial Progress;
              Orange for Some Progress; and Red for No Progress. An upwards arrow in the color
              box indicates that the color score improved over last year’s report. As part of the OIG’s
              continuing evaluation of the Management Challenges, certain Challenges have been
              updated or revised. In addition, actions that were scored Green last year, and which
              remained Green this year, have been moved up to the ―history bar‖ above the
              recommended actions. The history bar highlights any progress that the Agency has
              made on a Challenge over the past four FYs (or as long as the Challenge has existed, if
              shorter) by showing the number of actions that have moved to Green each year.

              This year’s report contains two new Management Challenges dealing with (1) SBA’s
              Loan Management and Accounting System (LMAS) project, and (2) improper payments


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in the Disaster and 7(a) loan programs. Since these two Management Challenges are
new, no color scores have been assigned; the Agency’s progress in resolving them will
be assessed during FY 2010 and color scores will be assigned in next year’s report.

Following is a summary of the FY 2010 report on the Agency’s Most Serious
Management and Performance Challenges.

                                                        Status Score
                           Topic                 Green Yellow Orange                  Red   Improved1
                  Small Business
           1                                                      2               1               1
                  Contracts
           2      IT Security                                     4                               0
           3      Human Capital                                   3                               0
                  Loan Guaranty
           4                                                      1               1               0
                  Purchase
           5      Lender Oversight                                2               4               0
           6      8(a) BD Program                    1            4                               3
           7      SBIC Program                       2            2                               2
           8      Loan Agent Fraud                                                2              --2
                  Loan Management and
           9                                                                                    New
                  Accounting System
          10      Improper Payments                                                             New
                     TOTAL                           3           18               8    0          6

We would like to thank SBA’s management and staff for their cooperation in providing
us with information needed to prepare this report. We look forward to working with
SBA’s new leadership team in addressing the Agency’s Management Challenges.

Attachment




1
  “Improved” refers to a recommended action that showed progress this year over last year’s score (as denoted by an
“up” arrow).
2
  Management Challenge 8, Loan Agent Fraud, was revised in FY 2009 to include two new recommended actions.
Consequently, no color scores were shown for these two remaining recommended in last year’s report against which
to measure progress.




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                                                Table of Contents



            Challenge 1. Procurement flaws allow large firms to obtain small business awards and
            agencies to count contracts performed by large firms towards their small business
            goals.

            Challenge 2. Weaknesses in information systems security controls pose significant
            risks to the Agency.

            Challenge 3. Effective human capital strategies are needed to enable SBA to
            successfully carry out its mission and become a high-performing organization.

            Challenge 4. SBA needs better controls over loan purchase and liquidation processes.

            Challenge 5. SBA needs to further strengthen its oversight of lending participants.

            Challenge 6. The Section 8(a) Business Development program needs to be modified so
            more firms receive business development assistance, standards for determining
            economic disadvantage are clear and objective, and SBA ensures that firms follow 8(a)
            regulations when completing contracts.

            Challenge 7. Insufficient and outdated SBA controls contribute to excessive risk of the
            SBIC program.

            Challenge 8. Effective tracking and enforcement would reduce financial losses from
            loan agent fraud.

            Challenge 9. SBA needs to modernize its Loan Accounting System and migrate it off
            the mainframe.

            Challenge 10. SBA needs to accurately report, significantly reduce, and strengthen
            efforts to recover improper payments in the Disaster and 7(a) loan programs.


            Appendix: Relevant Reports




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Challenge 1. Procurement flaws allow large firms to obtain small business
awards and agencies to count contracts performed by large firms towards their
small business goals.

The Small Business Act establishes a Government wide goal that 23 percent of the total value of all prime
contract awards for each fiscal year (FY) be awarded to small businesses. As the advocate for small
business, the Small Business Administration (SBA) should strive to ensure that only small firms obtain
small business awards and that procuring agencies accurately report contracts awarded to small
businesses when representing its progress in meeting small business contracting goals.

Office of Inspector General (OIG) audits and other governmental studies have shown widespread
misreporting by procuring agencies; many contract awards recorded as going to small firms have actually
been performed by larger companies. While some contractors may misrepresent or erroneously calculate
their size, most incorrect reporting results from errors made by government contracting personnel. Noted
errors include acceptance of questionable size self-certifications and misapplication of small business
contracting rules. Also, it is unclear whether contracting officers always review the on-line certifications
that contractors enter into the governmental Online Representations and Certifications Application
(ORCA) prior to awarding contracts. SBA needs to do more to ensure that contracting personnel are
adequately trained on small business procurement procedures and are reviewing ORCA data prior to
awarding contracts.

The Agency also needs to address a loophole within General Services Administration Multiple Awards
Schedule (MAS) contracts that contain multiple industrial codes. Currently, a company awarded such a
contract can identify itself as small on individual task orders awarded under that contract even though it
does not meet the size criteria for the applicable task. Thus, agencies may obtain small business credit
for using a firm classified as small, when the firm is not small for specific orders under such a MAS
contract.

While more remains to be done, SBA made some progress on this challenge as it: (1) developed a
strategy for promoting and encouraging procurement officials to be trained on small business contracting
procedures; (2) conducted surveillance reviews to assess whether procurement officials confirmed the
small business size status prior to contract award, and (3) provided anomaly reports to Federal agencies
procurement officials that identified potentially miscoded business size status for correction.

 Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
 Fiscal Year (FY) Issued:
                                        N/A                    06-0               07-0          08-1
 2005
                                                                                            Status at end
                   Remaining Recommended Actions for FY 2010
                                                                                             of FY 2009
 1. Develop and take steps to provide reasonable assurance that agencies are
    providing adequate basic and continuing education training to contracting         Yellow 
    personnel on small business contracting procedures.
 2. Develop and implement a program that promotes accurate contractor
    certifications and ensures that contracting personnel review contractor            Yellow
    certifications.
 3. Issue regulations that require firms to meet the size standard for each specific
    order they receive under a GSA schedule and Government-wide Acquisition
                                                                                      Orange
    Contract (GWAC) and show that the regulations are being followed. (Previously
    action # 4)
       Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




                                                        1


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             Challenge 2. Weaknesses in information systems security controls pose
             significant risks to the Agency.

             The confidentiality, integrity, and availability of SBA’s information systems are vital to the continued
             successful operation of the Agency. While information technology (IT) can result in a number of benefits,
             such as information being processed more quickly and communicated almost instantaneously, it can also
             increase the risk of fraud, inappropriate disclosure of sensitive data, and disruption of critical operations
             and services. SBA’s computer security program operates in a dynamic and highly decentralized
             environment and requires management attention and resources as weaknesses are identified.

             SBA continued to improve information system security in several critical areas during FY 2009. The
             Agency established a vulnerability assessment team (VAT) which performs monthly scans of network
             attached devices to identify and remediate network vulnerabilities; implemented procedures for
             requesting and granting remote access and for sanitization of used media prior to disposal; made
             progress documenting LAS and DCMS configuration baselines and implementing segregation of duties
             controls in LAS; and developed guidance on how contractor access vulnerabilities should be reported in
             the Plan of Actions and Milestones (POA&M) and now requires documentation justifying removal of prior
             vulnerabilities from the POA&M. To show further progress, SBA needs to address both known and
             newly-reported information security issues. For example, SBA needs to implement a process to more
             timely mitigate system risks that are identified as ―medium‖ and ―high‖ and ensure that all security
             weaknesses identified in risk assessments as ―high‖ are included in the POA&M; further implement
             enterprise-wide and application level change control controls for both emergency and normal system
             changes; and ensure that critical controls such as patch management are addressed in service level
             agreements with contractors and hosting sites.

              Challenge History                       Actions Accomplished (Green Status) during Past 4 FYs
              Fiscal Year (FY) Issued:                05-2           06-2             07-2             08-2
              1999
                                                                                                          Status at end
                                Remaining Recommended Actions for FY 2010
                                                                                                           of FY 2009
              1. Access controls are in place and operating effectively, and contractors are not
                 granted system access until they have obtained the required background                       Yellow
                 investigations and/or security clearances.
              2. System software controls are in place and operating effectively.                             Yellow

              3. Segregation of duty controls are in place and operating effectively.                         Yellow
              4. The POA&M accurately reports all computer security weaknesses and corrective
                                                                                                   Yellow
                 actions. (Previously action #5)
                   Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




                                                                      2


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Challenge 3. Effective human capital strategies are needed to enable SBA to
successfully carry out its mission and become a high-performing organization.

Between 2001 and 2006, SBA’s staffing (excluding Disaster) decreased by more than 25 percent while
virtually all of its programs grew significantly. For example, the number of loans made to small
businesses doubled and the Agency’s oversight responsibilities over government contracting to small
businesses increased as the value of these Federal contracts rose by more than 50 percent. In response
to budget constraints, SBA restructured key Agency operations, reengineered its largest loan programs,
and downsized personnel through attrition and directed transfers. While these actions transformed the
way SBA does business, the Agency did not adequately analyze priorities and allocate resources
consistent with those priorities and its new business processes. As a result, there was no assurance that
sufficient resources—in terms of both number of staff and the knowledge and skills possessed by staff—
were available and appropriately deployed to perform critical functions. For example, audits showed that
inadequate staffing of key functions resulted in limited oversight of lenders and inadequate monitoring of
8(a) program requirements.

The results of the 2002, 2004 and 2006 Federal Human Capital Surveys (FHCS) illustrated SBA’s serious
human capital challenges. For example, in 2006 SBA ranked near the bottom on all four human capital
indices—Leadership and Knowledge Management, Results-Oriented Performance Culture, Talent
Management, and Job Satisfaction. SBA’s scores were particularly low related to the adequacy of job-
related knowledge and skills, the reasonableness of workload, sufficiency of information needed to go a
good job, and employee morale.

SBA was proactive in addressing the results of the 2006 FHCS. As a result, the 2008 survey showed
significant improvement. For example, on the four indices identified above, SBA’s rankings moved from
33rd to 22nd, 32nd to 26th, 35th to 31st, and 34th to 27th, respectively. In addition, the Partnership for
Public Service, in its 2009 rankings of the best places to work in the Federal Government, recognized
SBA as the most improved agency, although SBA still ranked 26 out of 30 large agencies. SBA has also
focused considerable attention on improving workforce planning and employee development. Human
capital management continues to be a significant challenge, however, requiring continued attention to
ensure that qualified staff is available and appropriately allocated toward SBA’s mission-critical functions
and identified priorities.

 Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
 Fiscal Year (FY) Issued:
                                        05-0                  06-0               07-0            08-0
 2001 (Revised 2007)
                                                                                            Status at end
                   Remaining Recommended Actions for FY 2010
                                                                                             of FY 2009
 1. Allocate appropriate staffing toward Agency priorities – perform an analysis of
    Agency priorities and develop, communicate, and implement a comprehensive
    plan (including responsibilities, metrics, and timeframes) for allocating appropriate Yellow
    staffing (in terms of staffing levels and requisite knowledge, skills, and abilities)
    toward those priorities.
 2. Take steps to correct problems identified by the Federal Human Capital Survey
    (FHCS) – develop, communicate, and implement a corrective action plan
                                                                                          Yellow
    (including priorities, responsibilities, metrics, and timeframes) to address the
    underlying causes of SBA’s poor results on the FHCS.
 3. Plan for the future of SBA – develop and implement an effective succession
    planning program to ensure that there is qualified staff available to perform SBA’s   Yellow
    mission-critical functions and meet identified priorities for the foreseeable future.
       Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




                                                       3


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OFFICE OF THE INSPECTOR GENERAL REPORTS




             Challenge 4. SBA needs better controls over loan purchase and liquidation
             processes.

             The majority of loans under the 7(a) loan-guaranty program are made with little or no review by SBA prior
             to loan approval because SBA has delegated most of the credit decisions to lenders originating these
             loans. SBA’s review of lender requests for guaranty purchases on defaulted loans is, therefore, the
             Agency's primary tool for assessing lender compliance on individual loans and protecting SBA from
             making erroneous purchase payments. Furthermore, as lenders are delegated the responsibility for
             servicing and liquidating SBA loans, SBA’s liquidation process, including the comprehensive charge-off
             review, is the last opportunity to identify lender noncompliance. However, OIG audits of defaulted loans
             and SBA’s guaranty purchase and liquidation processes have shown that reviews performed by the loan
             centers have not consistently detected failures by lenders to administer loans in full compliance with SBA
             requirements and prudent lending practices, resulting in improper payments.

             SBA has taken actions to correct many of the deficiencies identified by the OIG. SBA reengineered the
             7(a) loan guaranty purchase processes at the National Guaranty Purchase Center (NGPC) and the Little
             Rock and Fresno Service Centers to improve the efficiency and consistency of the process; increased
             staffing levels at the centers; developed a comprehensive operations manual for the NGPC; trained
             individuals responsible for making purchase decisions; and made significant progress in developing a
             quality assurance program. While improvements have been made, additional actions are needed to
             strengthen guaranty purchase and liquidation decisions to effectively reduce improper payments, such as
             implementing effective policies and procedures governing the guaranty purchase and liquidation
             processes and fully implementing the quality assurance program at the centers.

              Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
              Fiscal Year (FY) Issued:
                                                     05-2                    06-0        07-0               08-2
              2001
                                                                                                       Status at end
                               Remaining Recommended Actions for FY 2010
                                                                                                        of FY 2009
              1. Implement a Quality Assurance Program for all SBA loan centers. (Previously
                                                                                                   Orange
                 action #3)
              2. Implement policies and procedures governing the guaranty purchase and
                 liquidation processes to ensure lender compliance before honoring SBA loan         Yellow
                 guaranties. (Previously action #4)
                    Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




                                                                      4


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Challenge 5. SBA needs to further strengthen its oversight of lending
participants.

Since its inception in 1953, SBA has loaned or guaranteed billions of dollars to finance and spur
investment in small businesses. Over the years, SBA has shifted from processing loans to overseeing
lenders originate, service, and liquidate loans. This requires an effective oversight program to: (1)
monitor lender compliance with SBA policies and procedures, and (2) take corrective actions when
material noncompliance are detected.

The Agency has made substantial progress in its oversight of lenders in the 7(a) and 504 loan programs,
reducing action items within this Management Challenge from 8 in FY 2006 to 3 in FY 2009. With
authority to charge fees to cover the cost of on-site lender reviews, SBA expanded the scope of its
oversight by more than doubling the number of on-site reviews of large high-risk lenders. It also issued a
Lender Review Standard Operating Procedure (SOP) to guide the on-site review process and modified
the Lender Risk Rating System to further strengthen lender risk assessments. In January 2009, SBA
published an Interim Final Rule that outlined its policy on enforcement actions against nonperforming
lenders. This rule identified the types of enforcement actions that could be exercised, grounds for
enforcement action, and processes for implementing such actions. Subsequent to publishing the rule, the
Agency drafted, but did not finalize, a Lender Enforcement SOP, which contains guidance for
implementing enforcement actions. Finally, in FY 2009, SBA evaluated the sufficiency of over 180
corrective actions proposed by lenders and developed guidelines for establishing lender performance
measures that will be incorporated into the Lender Enforcement SOP. The guidelines will assist the
Office of Credit Risk Management (OCRM) in establishing lender performance goals and target dates for
inclusion in lender corrective action plans.

To progress further, SBA will need to conduct agreed-upon-procedure reviews of medium-sized, high-risk
lenders and ensure that its on-site reviews are based on statistically-valid samples of lender loan files.
While OCRM has drafted agreed-upon-procedures for the reviews of medium-sized lenders and has
developed possible statistical approaches for reviewing loan files, it has not finalized its plans in either
area. SBA will also need to finalize the Lender Enforcement SOP so that it can establish performance
measures in lender corrective action plans.

                                          Actions Accomplished (Green Status) during Past 4 FYs
 Challenge History
 Fiscal Year (FY) Issued: 2001         05-7(A)-0        06-7(a)-2         07-7(a)-0        08-7(a)-2
                                       05-504-3         06-504-1          07-504-1         08-504-2
                                                                                     Status at end of
                 Remaining Recommended Actions for FY 2010                               FY 2009
                                                                                     7(a)        504
 1. Expand the scope of lender oversight and improve the process for reviewing
    lenders and Certified Development Companies (CDCs) for compliance risks.        Yellow     Yellow
    (Previously action #2)
 2. Implement guidance providing for effective oversight of lending programs.
                                                                                    Orange     Orange
    (Previously action #4)
 3. Ensure that effective corrective actions are implemented, monitored, and
    result in improvement in the performance of participants with unacceptable      Orange     Orange
    performance. (Previously action #5)
       Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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             Challenge 6. The Section 8(a) Business Development program needs to be
             modified so more firms receive business development assistance, standards for
             determining economic disadvantage are clear and objective, and SBA ensures
             that firms follow 8(a) regulations when completing contracts.

             The SBA 8(a) Business Development (BD) program was created to assist eligible small disadvantaged
             business concerns to compete in the American economy through business development.

             Previously, the Agency did not place adequate emphasis on business development to enhance the ability
             of 8(a) firms to compete, and did not adequately ensure that only 8(a) firms with economically
             disadvantaged owners in need of business development remained in the program. Companies that were
             ―business successes‖ were allowed to remain in the program and continue to receive 8(a) contracts,
             causing fewer companies to receive most of the 8(a) contract dollars and many to receive none.

             The Agency has made considerable progress in addressing issues that challenge its ability to deliver an
             effective 8(a) program. The Office of Business Development has developed a Business Development
             Assessment Tool, as well as a plan to provide 8(a) firms with individualized business development
             assistance. In addition, the Office of Business Development has strengthened its policies and procedures
             and revised its regulations to ensure that companies that are ―business successes‖ are graduated from
             the program. Further, the Agency has issued proposed regulations establishing objective standards to
             address the definition of ―economic disadvantage,‖ and has addressed the need to identify the skills
             necessary for Business Development Specialists to adequately evaluate a company’s business plan and
             assess a participant’s competitive potential. The Agency needs to ensure that procuring agencies
             enforce contractors’ compliance with 8(a) BD program regulations and finalize regulations to complete the
             recommended actions.

              Challenge History                     Actions Accomplished (Green Status) during Past 4 FYs
              Fiscal Year (FY) Issued:
                                                    05-0                    06-1        07-1              08-1
              2003
                                                                                                      Status at end
                               Remaining Recommended Actions for FY 2010
                                                                                                       of FY 2009
              1. Develop and implement a plan, including SOP provisions, which ensures that the
                 8(a) BD program identifies and addresses the business development needs of        Yellow 
                 program participants on an individualized basis.
              2. Develop and implement Regulations and SOP provisions to ensure that
                 participants are graduated once they reach the levels defined as business          Yellow
                 success.
              3. Establish objective criteria that reasonably measures ―economic disadvantage‖
                                                                                                   Yellow 
                 and implement the new criteria.
              4. Provide sufficient financial and analytical training to business development
                 specialists to enable them to evaluate a company’s business profile and           Green 
                 competitive potential.
              5. On a regular basis, conduct surveillance reviews of procuring agencies to ensure
                 they are effectively monitoring and enforcing compliance with specified 8(a) BD    Yellow
                 regulations on the contracts they administer. (Previously action #6)
                   Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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Challenge 7. Insufficient and outdated SBA controls contribute to excessive risk
of the SBIC program.

The Small Business Investment Company (SBIC) program is designed to stimulate and supplement the
flow of private equity capital and long-term debt to small business concerns. SBA uses both guaranteed
debt (debentures) and equity interest (participating securities) to provide government-backed financing to
SBICs. As of September 30, 2009, SBA had about $8.2 billion of such financings at risk. From FY 1993
to FY 2004, program costs were about $2 billion more than anticipated. Prior audits performed by the
Government Accountability Office (GAO) and the OIG attributed the unanticipated costs to the structure of
the program, the funding process, and the lack of focus on limiting costs when liquidating SBICs. The
audits determined that: (1) the subsidy model underestimated the cost of the program; (2) SBA’s profits
were not proportional to its investments in the participating security SBICs; (3) insufficient incentives
existed to encourage participating security SBICs to repay principal debt as quickly as possible; (4) SBA
allowed too much time for financially troubled SBICs to attempt rehabilitation; (5) better performance
goals and indicators were needed to show how well and how timely recoveries were maximized for
liquidated SBICs; (6) SOPs for SBIC operations and liquidations were outdated; and (7) existing guidance
did not provide a systemic approach for estimating the level of financial risk, implementing transfers to
restrictive operation status, transferring capitally-impaired SBICs to liquidation status, liquidating SBICs
with participating securities, and monitoring the liquidation of SBIC receiverships.

From FY 2005 to FY 2009, however, the program has been self-sustaining, with fees covering all losses.
SBA has also demonstrated that it transferred 30 of 33 SBICs into restrictive operations in a timely
manner, that self-liquidation procedures for participating security SBICs were followed, and that effective
monitoring of SBIC receiverships was accomplished through oversight reports and documented quarterly
meetings with receivership personnel. These actions are sufficient to elevate to green the scores for two
of the four remaining recommended actions for this Management Challenge.

To further reduce risk in the program, SBA needs to more timely transfer debenture funded SBICs into
liquidation and implement performance goals and indicators that address the efficiency, cost-
effectiveness, and timeliness of the SBIC liquidation process. An analysis of 12 debenture funded SBICs
transferred into liquidation status between September 2007 and 2009 showed that the majority of these
transfers were not timely; the OIG found that at least 7 were transferred into liquidation status 12 months
or more after exceeding their maximum capital impairment percentage. Also, after establishing goals and
performance indicators to evaluate the liquidation of SBICs, SBA must demonstrate their effectiveness.

 Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
 Fiscal Year (FY) Issued:               05-0           06-1             07-1             08-1
 2004
                                                                                           Status at end
                   Remaining Recommended Actions for FY 2010
                                                                                            of FY 2009
 1. Develop systematic criteria and implement a timely approach for transferring
                                                                                       Yellow
    SBICs to liquidation status.
 2. Incorporate into SOP 10 06 a requirement for the timely and consistent
                                                                                       Green
    implementation of restrictive operations. (Previously action #3)
 3. Develop and implement performance goals and indicators that address the
    efficiency, cost-effectiveness, and timeliness of the SBIC liquidation process.    Yellow
    (Previously action #4)
 4. Develop and implement procedures, to be included in a revised version of SOP 10
    07 that address the liquidation of participating security SBICs and SBA monitoring Green
    of the liquidation of SBICs in receivership. (Previously action #5)
      Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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            Challenge 8. Effective tracking and enforcement would reduce financial losses
            from loan agent fraud.

            For years, OIG investigations have revealed a pattern of fraud in the 7(a) business loan guaranty program
            by loan packagers and other for-fee agents. Fraudulent schemes have involved hundreds of millions of
            dollars, yet SBA oversight of loan agents has been limited, putting taxpayer dollars at risk. The Agency
            could reduce this risk by establishing effective loan agent disclosure requirements, a database or
            equivalent means to track loan agent involvement with its loans, and a more effective agent enforcement
            program.

            In response to this Management Challenge, SBA had proposed to revise its E-Tran system (which is
            designed to collect loan data electronically from participating lenders) to collect information on loan agent
            involvement. The Agency concluded, however, that this would not address the problem due to limitations
            in the E-Tran system and communication issues between lender personnel involved in loan decisions and
            those performing E-Tran data entry. In addition, many lenders were not using E-Tran. In late FY 2007,
            SBA proposed a new approach. The Agency intends to integrate the collection of data from the Form 159
            (which asks for information about loan agents) into the Form 1502 process. The Form 1502 is an
            electronically-submitted report that lenders submit to SBA’s Fiscal and Transfer Agent (FTA) to describe
            the status of all SBA-guaranteed loans in their portfolios. This method of capturing the data is superior to
            using the E-Tran system because: (1) the 1502 is first submitted after the initial loan disbursement, so a
            lender should be aware of and able to report on loan agent activity, and (2) the 1502 is submitted by all
            7(a) lenders. Accordingly, in FY 2008, the OIG issued the revised recommended action #1 below. SBA
            made no progress on this action during FY 2008, in part due to a protest of the award of the FTA contract
            to what would have been a new vendor. At the end of FY 2009, SBA devised a succinct plan for
            implementing the 1502 approach.

            In FY 2007, the Agency made progress by issuing its Lender Oversight SOP and by previously revising
            the guaranty purchase checklist (which lists the records that lenders need to provide when requesting
            SBA to pay a guaranty) to include the submission of the Form 159. However, the Agency also needs to
            establish a more effective enforcement program to deter fraudulent loan agent activity. As a first step,
            SBA issued for clearance at the end of FY 2009 a draft SOP revision with loan agent enforcement
            procedures.

             Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
             Fiscal Year (FY) Issued:
                                                     05-0                   06-0          07-1               08-1
             2000
                                                                                                        Status at end
                               Remaining Recommended Actions for FY 2010
                                                                                                         of FY 2009
             1. Develop an effective method of disclosing and tracking loan agent involvement in
                                                                                                 Orange
                the SBA business loan programs.
             2. Implement procedures for enforcement actions against loan agents for improper
                                                                                                 Orange
                and fraudulent conduct. (Previously action #3)
                  Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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Challenge 9. SBA needs to modernize its Loan Accounting System and migrate
it off the mainframe.

In November 2005, SBA initiated the Loan Management and Accounting System (LMAS) project, which is
the latest in a series of attempts to update the Agency’s Loan Accounting System (LAS) and migrate it off
of the mainframe. With an estimated cost of over $250 million, LMAS is SBA’s largest IT project. When
completed, it will increase functionality, reduce data entry redundancies, and allow real-time updates and
inquiry of loan data. Previous OIG reports have stressed the urgency of replacing the current loan
accounting system, which presents substantial risk to SBA. The system is dangerously close to the end
of its expected useful life, relies on obsolete technology, contains major security vulnerabilities that
cannot be addressed until the system is moved to a new operating platform, and is costly to operate.

Despite the cost and risks associated with the current system, SBA was unable to replace LAS prior to
the expiration of the mainframe contract in February 2007, and subsequently extended the contract to
2012. SBA also revised its acquisition strategy in May 2008 from a requirements-based approach to one
that relies on a provider to design a system that best meets SBA’s business objectives. Consequently,
the project is still in the planning phase. Additionally, recent OIG reports have raised concerns about how
the project was being managed. The OIG reported that the project did not comply with SBA’s System
Development Methodology in key quality assurance and earned value management areas, which
threatened SBA’s ability to control LMAS costs and quality. The OIG also reported that SBA had not
established either an enterprise-wide or project-level Quality Assurance (QA) function to ensure that
project deliverables meet SBA’s requirements and quality standards. Finally, the OIG reported that the
project lacked a defined process for reviewing and accepting deliverables that complied with SBA’s
Systems Development Methodology.

 Challenge History                      Actions Accomplished (Green Status) during Past 4 FYs
 Fiscal Year (FY) Issued:
                                        N/A                     N/A               N/A           N/A
 2010
                                                                                          Status at end
                         Recommended Actions for FY 2010
                                                                                           of FY 2009
 1. Migrate LAS to a new operating platform before the current mainframe contract
                                                                                        New
    expires in 2012.
 2. Modify the LMAS QA/IV&V contract to require the contractor to report all findings
    and recommendations to the Program Manager and an independent QA                    New
    manager.
 3. Establish a process for reviewing and accepting LMAS deliverables that complies
                                                                                        New
    with SDM requirements.
       Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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           Challenge 10. SBA needs to accurately report, significantly reduce, and
           strengthen efforts to recover improper payments in the Disaster and 7(a) loan
           programs.

           Recent OIG audits of SBA’s Disaster and 7(a) Loan Programs determined that the improper payment
           rates reported for these programs were significantly understated. SBA estimated that improper payments
           in the Disaster Loan Program were about $4.5 million, or 0.55 percent of the $819.7 million in loans
           approved in FY 2007, while the OIG reported that it was at least 46 percent, or approximately $1.5 billion.
           SBA also reported that the improper payment rate for the 7(a) program was 0.53 percent of FY 2008
           program outlays, although the OIG estimated the rate to be 27 percent, or approximately $234 million.
           SBA’s improper payment rates were understated because the Agency did not adequately review sampled
           loans, used flawed sampling methodologies, and did not accurately project review findings for both
           programs. Additionally, the Office of Financial Assistance inappropriately overturned improper payments
           identified by reviewers.

           OIG audits in prior years have also identified high percentages of disaster and business loans that were
           made to borrowers who were ineligible, lacked repayment ability, or did not provide the required
           supporting documentation required for loan disbursement. In 2008, we reported that 63 percent of early
           defaulted Gulf Coast loans reviewed went to individuals who lacked repayment ability, and that half of the
           loans reviewed in another audit were disbursed without securing all the documentation needed to secure
           SBA’s interest in the property. In 2009, we   reported that over 30 percent of reviewed disaster loans were
           disbursed for properties that were not the applicant’s primary residence. Further, audits in 2009 of SBA’s
           post purchase and liquidation processes for 7(a) loans identified an estimated $30 million in improper
           loan guaranty purchases. Finally, SBA has not aggressively pursued recovery of improper payments,
           recovering only about 1 percent of the improper payments identified during its FY 2007 and FY 2008
           improper payment reviews.

            Challenge History                     Actions Accomplished (Green Status) during Past 4 FYs
            Fiscal Year (FY) Issued:
                                                   N/A                      N/A          N/A                N/A
            2010
                                                                                                  Status at end of
                                                                                                      FY 2009
                                  Recommended Actions for FY 2010
                                                                                                 Disaster      7(a)
            1. Ensure that processes used to calculate the improper payment rate for
               disaster and 7(a) loans are designed to identify all potential improper
                                                                                                   New        New
               payments as defined by Office of Management and Budget (OMB) Circular A-
               123.
            2. Reassign responsibility for final approval of disputed denial, repair, and
               improper payment decisions from the Office of Financial Assistance to the           New        New
               Office of Risk Management.
            3. Develop a process to ensure that reviewers are properly trained to perform
                                                                                                   New        New
               improper payment reviews.
            4. Develop and implement corrective action plans to reduce improper payments
                                                                                                   New        New
               in the 7(a) and Disaster Loan programs.
            5. Establish a process and time standards to expeditiously recover improper
                                                                                           New       New
               payments identified during Agency reviews and OIG audits.
                 Green-Implemented Yellow-Substantial progress Orange-Limited Progress Red-No progress




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                                 Appendix: Relevant Reports


                           Most of the SBA OIG reports listed can be found at
                        http://www.sba.gov/ig/onlinelibrary/oigreports/index.html
                                                    .
Challenge 1:

•   SBA Advocacy, Analysis of Type of Business Coding for the Top 1,000 Contractors Receiving Small
    Business Awards in FY 2002, December 2004.
•   The Center for Public Integrity, The Big Business of Small Business: Top defense contracting
    companies reap the benefits meant for small businesses, September 29, 2004.
•   The Center for Public Integrity, The Pentagon’s $200 Million Shingle: Defense data shows billions in
    mistakes and mislabeled contracts, September 29, 2004.
•   SBA OIG, Audit of SBA's Administration of the Procurement Activities of Asset Sale Due Diligence
    Contracts and Task Orders, Report #4-16, March 17, 2004, pp. 8-9.
•   GAO, Contract Management: Reporting of Small Business Contract Awards Does Not Reflect Current
    Business Size, GAO-03-704T, May 7, 2003.
•   The Small Business Committee, U.S. House of Representatives Hearing, Are Big Businesses Being
    Awarded Contracts Intended for Small Businesses? Testimony of Mr. Fred C. Armendariz, Associate
    Deputy Administrator, SBA, May 7, 2003.
•   The Small Business Committee, U.S. House of Representatives Hearing, Are Big Businesses Being
    Awarded Contracts Intended for Small Businesses? Testimony of Mr. Felipe Mendoza, Associate
    Administrator, Office of Small Business Utilization, U.S. General Services Administration, May 7,
    2003.
•   SBA OIG, SBA Small Business Procurement Awards Are Not Always Going to Small Businesses,
    Report #5-14, February 24, 2005.
•   SBA OIG, Review of Selected Small Business Procurements, Report #5-16, March 8, 2005.

Challenge 2:

•   SBA OIG, Review of Allegations Concerning How the LMAS Modernization Project is Being
    Managed, Report #9-17, July 30, 2009
•   SBA OIG, System Access By Contractors Without Security Clearances, Report #9-07, January 26,
    2009
•   SBA OIG, SBA’s FY2008 Financial Statements-Management Letter, Report #9-05, December 17,
    2008
•   SBA OIG, SBA’s FY2008 Financial Statements, Report #9-03, November 14, 2008
•   SBA OIG, SBA’s Implementation of an HSPD-12 Card Issuance System, Report #9-01, October 6,
    2008
•   SBA OIG, Planning for the Loan Management and Accounting System Modernization and
    Development Effort, Report #8-13, May 14, 2008
•   SBA OIG Audit of SBA’s FY 2007 Financial Statements, Report #8-03, November 15, 2007.
•   SBA OIG, Audit of Controls Over Access to Employee Emails by SBA Managers, Report #8-02,
    October 19, 2007.
•   SBA OIG, Results of KPMG Vulnerability Assessment, Report #7-16, March 6, 2007.
•   SBA OIG, FISMA Independent Evaluation for FY 2006, Report #7-14, February 9, 2007.
•   SBA OIG, Memorandum Advisory Report on SBA’s Protection of Sensitive Information, Report #7-13,
    February 9, 2007.
•   Audit of SBA OIG, Audit of SBA’s Financial Statements for FY 2006, Report #7-03, November 15,
    2006.
•   SBA OIG, FISMA Independent Evaluation for FY 2005, Report #6-01, October 7, 2005.
•   SBA OIG, Memorandum Advisory Report on SBA Needs to Implement a Viable Solution to its Loan
    Accounting System Migration Problem, Report #5-29, September 30, 2005.


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          •   SBA OIG, Audit of SBA’s Information System Controls for FY 2004, Report #5-12, February 24, 2005.
          •   SBA OIG, Audit of SBA’s Exchange Email System, Report #4-42, September 10, 2004.
          •   SBA OIG, Audit of Selected SBA General Support Computer Operating Systems, Report #4-41,
              September 10, 2004.
          •   SBA OIG, Audit of SBA’s Information System Controls for FY 2003, Report #4-19, April 29, 2004.
          •   SBA OIG, Audit of SBA’s Information System Controls for FY 2002, Report #3-20, March 31, 2003.

          Challenge 3:

          •   Partnership for Public Service, Best Places to Work in the Federal Government 2009,
              http://data.bestplacestowork.org/bptw/index
          •   OPM, 2008 Federal Human Capital Survey (FHCS), http://www.fhcs.opm.gov/
          •   GAO, Opportunities Exist to Build on Leadership’s Efforts to Improve Agency Performance and
              Employee Morale, GAO-08-995, September 2008
          •   SBA OIG, Non-Native Managers Secured Millions of Dollars from 8(a) Firms Owned by Alaska Native
              Corporations through Unapproved Agreements that Jeopardize the Firms’ Program Eligibility, Report
              #8-14, August 7, 2008
          •   SBA OIG, Audit of Two 8(a) Sole-Source Contracts Awarded to Contractors in SBA’s Mentor
              Protégé Program, Report #7-19, March 30, 2007
          •   SBA OIG, Management Advisory Report on the Transfer of Operations to the National Guaranty
              Purchase Center, Report #4-39, August 31, 2004
          •   GAO, Small Business Administration: Progress Made, but Transformation Could Benefit from
              Practices Emphasizing Transparency and Communication, GAO-04-076, October 2003
          •   GAO, Results Oriented Cultures: Implementation Steps to Assist Mergers and Organizational
              Transformations, GAO-03-699, July 2003
          •   GAO, Small Business Administration: Workforce Transformation Plan is Evolving, GAO-02-931T, July
              16, 2002
          •   SBA OIG, Modernizing Human Capital Management, Report #2-20, May 31, 2002
          •   GAO, Small Business Administration: Current Structure Presents Challenges for Service Delivery,
              GAO-02-17, October 2001
          •   GAO, Small Business Administration: Steps Taken to Better Manage its Human Capital, but More
              Needs to be Done, GAO/T-GGD/AIMD-00-256, July 20, 2000
          •   SBA OIG, A Framework for Considering the Centralization of SBA Functions, November 1996

          Challenge 4:

          •   SBA OIG, SBA’s Management of the Backlog of Post-purchase Reviews at the National Guaranty
              Purchase Center, #9-18, August 25, 2009
          •   SBA OIG, , The Small Business Administration’s Fiscal Year 2008 Improper Payment Rate for the
              7(a) Guaranty Loan Program #9-16, July 10, 2009
          •   SBA OIG, Review of Key Unresolved OIG Audit Recommendations in Program Areas Funded by the
              American Recovery and Reinvestment Act and Related Activities Need to Safeguard Funds, #ROM
              09-1, April 30, 2009
          •   SBA OIG, Audit of the Liquidation Process at the National Guaranty Purchase Center, #9-08, January
              30, 2009
          •   SBA OIG, Audit of Six SBA Guaranteed Loans, #8-18, September 8, 2008
          •   SBA OIG, Audit of Loan Classifications and Overpayments on Secondary Market Loans, #8-09,
              March 26, 2008
          •   SBA OIG, Audit of UPS Capital Business Credit’s Compliance with Selected 7(a) Lending
              Requirements, #8-08, March 21, 2008
          •   SBA OIG, Audit of the Guarantee Purchase Process for Section 7(a) Loans at the National Guaranty
              Purchase Center, Report #7-23, May 8, 2007
          •   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-17, March 12, 2007
          •   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-15, February 12, 2007



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•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-10, January 16, 2007
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-09, January 9, 2007
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-07, December 29, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-06, December 28, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-05, December 20, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #7-02, October 23, 2006
•   SBA OIG, Audit of Deficiencies in OFA’s Purchase Review Process for Backlogged Loans,
    Report #6-35, September 29, 2006
•   SBA OIG, Survey of the Quality Assurance Review Process, Report #6-26, July 12, 2006
•   SBA OIG, Audit of SBA’s Implementation of the Improper Payments Information Act, Report #6-25,
    June 21, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #6-22, May 17, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #6-17, March 20, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #6-16, March 20, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #6-14, March 2, 2006
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #5-26, September 28, 2005
•   SBA OIG, Audit of an SBA Guaranteed Loan, Report #5-21, July 15, 2005
•   SBA OIG, Management Advisory Report on the Transfer of Operations to the National Guaranty
    Purchase Center, Report #4-39, August 31, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #4-38, August 24, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #4-33, July 30, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #4-28, July, 9, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #4-25, June 22, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #4-06, January 8, 2004
•   SBA OIG, Audit of an Early Defaulted Loan, Report #3-38, September 22, 2003
•   SBA OIG, Audit of an Early Defaulted Loan, Report #3-30, June 19, 2003
•   SBA OIG, Audit of an Early Defaulted Loan, Report #3-27, May 22, 2003
•   SBA OIG, Audit of the Guaranty Purchase Process, Report #3-15, March 17, 2003
•   SBA OIG, Audit of an Early Defaulted Loan, Report #3-07, January 23, 2003
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-32, September 30, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-30, September 24, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-23, August 7, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-15, March 29, 2002
•   SBA OIG, Improvements are Needed in Small Business Lending Company Oversight Process,
    Report #2-12, March 21, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-03, February 27, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #2-05, February 27, 2002
•   SBA OIG, Audit of an Early Defaulted Loan, Report #1-10, March 9, 2001
•   GAO, Major Management Challenges and Program Risks, GAO-01-260, January 2001
•   SBA OIG, Audit of an Early Defaulted Loan, Report #0-10, April 23, 2000
•   SBA OIG, Audit of an Early Defaulted Loan, Report #0-12, March 28, 2000
•   SBA OIG, Audit of an Early Defaulted Loan, Report #0-05, February 14, 2000

Challenge 5:

•   SBA OIG, SBA’s Oversight of SBA Supervised Lenders, Report #8-12, May 9, 2008
•   SBA OIG, UPS Capital Compliance with Selected 7(a) Lending Requirements, Report #8-08, March
    21, 2008
•   GAO, Small Business Administration: Additional Measures Needed to Assess 7(a) Loan Program’s
    Performance, GAO-07-769, July 13, 2007
•   SBA OIG, SBA’s Oversight of Business Loan Center, LLC, Report #7-28, July 11,2007.
•   SBA OIG, SBA’s Use of the Loan and Lender Monitoring System, Report #7-21, May 2, 2007.




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                                   Agency Financial Report   FY 2009
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OFFICE OF THE INSPECTOR GENERAL REPORTS



          •   SBA OIG, Audit of the Office of Lender Oversight Corrective Action Process, Report #7-18, March 14,
              2007.
          •   GAO, Small Business Administration: Improvements Made, But Loan Programs Face Ongoing
              Management Challenges, GAO-06-605T, April 6, 2006
          •   SBA OIG, SBA’s Administration of the Supplemental Terrorist Activity Relief (STAR) Loan Program,
              Report #6-09, December 23, 2005
          •   GAO, Small Business Administration: New Service for Lender Oversight Reflects Some Best
              Practices, But Strategy for Use Lags Behind, GAO-04-610, June 8, 2004
          •   GAO, Continued Improvements Needed in Lender Oversight, Report #03-90, December 2002
          •   SBA OIG, Impact of Loan Splitting on Borrowers and SBA, Advisory Memorandum Report #2-31,
              September 30, 2002
          •   SBA OIG, Improvements needed in SBLC Oversight, Advisory Memorandum Report, #2-12, March
              20, 2002
          •   SBA OIG, Preferred Lender Oversight Program, Report #1-19, September 27, 2001
          •   SBA OIG, SBA Follow-up on SBLC Examinations, Report #1-16, August 17, 2001

          Challenge 6:

          •   SBA OIG, Audit of Two 8(a) Sole –Source Contracts Awarded to Contractors in SBA’s Mentor
              Protégé Program, Report #7-19, March 30, 2007.
          •   SBA OIG, Audit of Monitoring Compliance with 8(a) Business Development Regulations During 8(a)
              Business Development Contract Performance, Report #6-15, March 16, 2006.
          •   SBA OIG, Business Development Provided by SBA’s 8(a) Business Development Program, Report
              #4-22, June 2, 2004.
          •   SBA OIG, SACS/MEDCOR: Ineffective and Inefficient, Report #4-15, March 9, 2004.
          •   SBA OIG, Section 8(a) Program Continuing Eligibility Reviews, Report #4-3-H-006-021, September
              30, 1994

          Challenge 7:

          •   SBA OIG, Audit of SBIC Liquidations Process, Report #5-22, July 28, 2005
          •   SBA OIG, The SBIC Program: At Risk for Significant Losses, Report #4-21, May 24, 2004
          •   OMB, Small Business Administration: PART Assessment on the SBIC Program, February 2, 2004
          •   SBA OIG, FY 2003 Financial Statement Audit in the SBA FY 2003Performance and Accountability
              Report, January 30, 2004, pp. 230-60
          •   SBA OIG, Audit of SBIC Oversight, Report #3-33, July 1, 2003
          •   GAO, Small Business: Update on SBA’s Small Business Investment Company Program, GAO/RCED-
              97-55, February 1997
          •   GAO, Small Business Administration: SBA Monitoring Problems Identified in Case Studies of 12
              SBICs and SSBICs, GAO/OSI-96-3, April 1996
          •   GAO, Small Business Administration: Better Oversight of SBIC Programs Could Reduce Federal
              Losses, GAO/T-RCED-95-285, September 28, 1995
          •   GAO, Small Business Administration: Inadequate Oversight of Capital Management Services, Inc.-An
              SSBIC, GAO/T-OSI-95-19, August 7, 1995
          •   GAO, Small Business Administration: Prohibited Practices and Inadequate Oversight in SBIC and
              SSBIC Programs, GAO/OSI-95-16, May 28, 1995
          •   GAO, Small Business Administration: Inadequate Oversight of Capital Management Services, Inc.-An
              SSBIC, GAO/OSI-94-23, March 1994
          •   SBA OIG, Audit Report on the Small Business Investment Company (SBIC) Liquidation Function,
              Report #3-2-E-004-031, March 31, 1993




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                                                  Agency Financial Report   FY 2009
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                                                                         OFFICE OF THE INSPECTOR GENERAL REPORTS



Challenge 8:

•   SBA OIG, Applicant Character Verification in SBA’s Business Loan Program, Report #3-43, April 5,
    2001
•   SBA OIG, Summary Audit of Section 7(a) Loan Processing, Report #0-03, January 11, 2000
•   SBA OIG, Loan Agents and the Section 7(a) Program, Report #98-03-01, March 31, 1998
•   SBA OIG, Fraud Detection in SBA Programs, Report #97-11-01, November 24, 1997
•   SBA OIG, Operation Cleansweep Memorandum, August 21, 1996

Challenge 9:

•   SBA OIG, Review of Allegations Concerning How the Loan Management and Accounting System
    Modernization Project is Being Managed, Report #9-17 July 30, 2009
•   SBA OIG, Planning for the Loan Management and Accounting System Modernization and
    Development Effort, Report #8-13, May 14, 2008
•   SBA OIG, SBA Needs to Implement a Viable Solution to its Loan Accounting System Migration
    Problem, Report #5-29, September 20, 2005
•   GAO, Information Technology: Agencies Need to Improve the Accuracy and Reliability of Investment
    Information, GAO-06-250, January 12, 2006.
•   GAO, Major Management Challenges and Program Risks: Small Business Administration, GAO-03-
    116, January 1, 2003
•   GAO, SBA Loan Monitoring System: Substantial Progress Yet Key Risks and Challenges Remain,
    Testimony of Joel C. Willemssen, Director, Civil Agencies Information Systems Accounting and
    Information Management Division, Before the Subcommittee on Government Programs Statement
    Committee on Small Business, House of Representatives, GAO/T-AIMD-00-113, February 29, 2000
•   GAO, SBA Needs to Establish Policies and Procedures for Key IT Processes, Accounting and
    Information Management Division, GAO/AIMD-00-170, May 31, 2000

Challenge 10:

•   SBA OIG, SBA’s Management of the Backlog of Post-Purchase Reviews at the National Guaranty
    Purchase Center, Report #9-18, August 25, 2009
•   SBA OIG, The Small Business Administration’s Fiscal Year 2008 Improper Payment Rate for the 7(a)
    Guaranty Loan Program, Report #9-16, July 10, 2009
•   SBA OIG, Audit of Borrower Eligibility for Gulf Coast Disaster Loans, Report #9-09, March 31, 2009
•   SBA OIG, The Small Business Administration’s Fiscal Year 2007 Improper Payment Rate for the
    Disaster Loan Program, Report #9-10, March 26, 2009
•   SBA OIG, Audit of the Liquidation Process at the National Guaranty Purchase Center, Report #9-08,
    January 30, 2009
•   SBA OIG, The Use of Proceeds From Gulf Coast Disaster Loans, Report #9-06, January 15, 2009
•   SBA OIG, Disaster Loss Verification Process, Report #8-15, June 17, 2008
•   SBA OIG, Review of the Adequacy of Supporting Documentation for Disbursements, Report #8-07,
    January 29, 2008
•   SBA OIG, The Quality of Loans Processed Under the Expedited Disaster Loan Program, Report #7-
    34, September 28, 2007
•   SBA OIG, SBA’s Quality Assurance Reviews of Loss Verifications, Report #7-29, July 23, 2007
•   SBA OIG, Securing Collateral for Disaster Loan Disbursements, Report #7-22, May 9, 2007




                                                  15
                                               Agency Financial Report   FY 2009
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OFFICE OF THE INSPECTOR GENERAL REPORTS




           Agency Response to the OIG Report on
           Management and Peformance Challenges

                                                      U.S. S MALL B USINESS ADMINISTRATION
                                                         O FFICE OF INSPECTOR GENERAL
                                                            WASHINGTON, D.C. 20416




           November 9, 2009
                 October 16, 2009
           To:            Peggy E. Gustafson
                          Inspector General
                 MEMORANDUM
           From:          Eileen Harrington
                 TO:      Chief Karen
                                Operating  Officer
                                       G. Mills
                                  Administrator
           Subject:       FY 2010 OIG-Identified Major Management Challenges
                             Original signed by:
                 FROM:       Peggy E. Gustafson
           On October 16, 2009, the OIGGeneral
                             Inspector   provided to the Administrator its report, entitled: “FY 2010 Report on the Most Serious
           Management and Performance Challenges Facing the Small Business Administration.” The Challenge Report, which is
           published  in the Agency’s
                SUBJECT:               Annual
                                Fiscal Year    Financial
                                            2010           Report
                                                   Report on       (AFR),
                                                              the Most      provides a
                                                                         Serious        currentand
                                                                                 Management     assessment of major Agency management
           challenges that posePerformance
                                 significant risks,  including
                                              Challenges        those
                                                            Facing the that
                                                                        Smallare particularly
                                                                              Business        vulnerable to fraud, waste, error, mismanage-
                                                                                        Administration
           ment or inefficiencies. In FY 2009, SBA made progress on eight major challenges; for FY 2010, the OIG identified three
                In accordance with the Reports Consolidation Act of 2000, we are providing you with the Office of
           new challenges dealing with SBA’s Loan Management and Accounting System (LMAS), improper payments in the loan
                Inspector Generals (OIG) Fiscal Year (FY) 2010 Report on the Most Serious Management and
           programs,   and internal
                Performance         controls.
                              Challenges       Allthe
                                          Facing   11 Small
                                                       challenges  fall Administration
                                                             Business   into two major(SBA).
                                                                                        risk categories:
                                                                                               This report represents our
                 current assessment of Agency programs and/or activities that pose significant risks, including those that
           1. Those   that posevulnerable
                  are particularly risk of losing    taxpayers’
                                               to fraud,          money
                                                         waste, error,      (i.e., guarantee
                                                                       mismanagement            purchase process,
                                                                                            or inefficiencies.      lender oversight,
                                                                                                               The Challenges are not loan agent
               fraud,  SBIC in
                  presented   program
                                 order ofrisk, improper
                                          priority, as     payments);
                                                       we believe  that alland
                                                                            are critical management or performance issues.
           2. Those that pose risk of delivering inefficient programs (i.e., human capital, IT security, contracting loopholes, 8(a)
               program    execution,
                  Our report  is based LMAS,     andOIG,
                                       on specific     Agency   internalAccountability
                                                          Government       controls). Office (GAO), and other official reports, as
                 well as our general knowledge of SBAs programs and operations. Our analysis generally considers those
                 accomplishments that SBA reported as of September 30, 2009.
           One of the Agency’s management goals is to create a transformed, high-performing organization that exercises cost-
           effective stewardship
                 Within               over itsChallenge
                         each Management        resourcesthere
                                                             and offers  transparent
                                                                  are a series          and accountable
                                                                               of “recommended     actions”service  to its
                                                                                                            to resolve  thecustomers. SBA appreci-
           ates the  cooperation     and  work    done   by the  OIG  in helping   the Agency   to address   successfully
                 Challenge. Each recommended action is assigned a color “status” score. The scores are as follows:            its major management
           challenges.
                 Green forInstituting
                            Implemented;sound    internal
                                             Yellow        processes lead
                                                      for Substantial        to reduced
                                                                      Progress;           government
                                                                                  Orange for Some        risk; and
                                                                                                     Progress; lowerRed
                                                                                                                      costfortoNothe taxpayer; and
           reduced   potential
                 Progress.   An for  waste,
                                upwards       fraud
                                           arrow      andcolor
                                                   in the  abuse.
                                                                boxThe   Agency
                                                                    indicates      concurs
                                                                               that the colorwith the OIG
                                                                                              score improvedReport,  which
                                                                                                               over last yearsreflects improvements
           acrossreport.  As part
                   the board   andof the OIGsconsistent
                                      a more     continuingfocus
                                                              evaluation of the Management
                                                                    on addressing              Challenges,
                                                                                      the Challenges.        certain Challenges
                                                                                                         In addition  to eliminating the last remain-
                 have been updated or revised. In addition, actions that were scored Green last year, and which remained
           ing “red” rating and experiencing no deterioration in any single rating, SBA is pleased to report the following results:
                  Green this year, have been moved up to the “history bar” above the recommended actions. The history
                  bar highlights any progress that the Agency has made on a Challenge over the past four FYs (or as long as
           1. Improved    ratings in six of the 29 recommended actions in four of the eight Challenges; maintained “substantial” or
                  the Challenge has existed, if shorter) by showing the number of actions that have moved to Green each
               “limited”
                  year. progress in the other four Challenges.
           2. Achieved three green or “fully successful” ratings out of 29 actions.
           3. Reduced    thereport
                 This years number   of recommended
                                   contains             actions from
                                            three new Management     39 to 29,
                                                                  Challenges   downwith
                                                                             dealing from
                                                                                        (1)136 in FY
                                                                                            SBAs    2004.
                                                                                                  Loan Management
                 and Accounting System (LMAS) project; (2) improper payments in the Disaster and 7(a) loan programs;
           Only and (3) internal
                through          controls. Since
                          our continued          these three
                                           collaboration     Management
                                                          with           Challenges
                                                               you and your staff canare
                                                                                      wenew, no color
                                                                                         create       scores
                                                                                                 a more      have been
                                                                                                         effective and efficient SBA.
                assigned; the Agencys progress in resolving them will be assessed during FY 2010 and color scores will
           Thank you and your staff for your continued commitment in helping us to improve our management environment.
                 be assigned in next years report.

                 Following is a summary of the FY 2010 report on the Agencys Most Serious Management and
                 Performance Challenges.



                                                  Agency Financial Report      FY 2009                                         38




                                                          Agency Financial Report   FY 2009
    110
APPENDICES
                                                         Disaster Customer Service Center (Toll Free)
                                                         (800) 659 – 2955
The SBA home page is www.sba.gov.
Information on the programs may be accessed              504       504 Certified Development Company Loan
from this site. Several of the more frequently                     Program
visited sites are listed below:                                    Provides small businesses with long-term, fixed
                                                                   rate financing for the purchase of land, buildings
SBA INFORMATION                                                    and long-life capital equipment.
  Who We Are and What We Do                 www.sba.gov/aboutsba
                                                     7(a)       7(a) Loan Guaranty Program
  Find Your Local Office                    www.sba.gov/localresources/index.html
                                                                SBA’s primary loan program. It provides general
  SBA’s Plans and Reports                                      loan financing for a wide variety of purposes.
                                            www.sba.gov/aboutsba/budgetsplans/index.html
  SBA En Español                            www.sba.gov/espanol
                                                     8(a)     8(a) Business Development Program
                                                             Assists firms owned and controlled by socially and
  Ombudsman                                 www.sba.gov/ombudsman
                                                                   economically disadvantaged individuals to enter
  Online Library                            www.sba.gov/tools/resourcelibrary/index.html
                                                                and succeed in the economic mainstream.

FOR START-UP BUSINESSES                                  A-123   Designation for OMB Circular on “Internal Control
                                                                 Systems.” It prescribes policies and procedures to
  What is a Small Business?                 www.sba.gov/starting/indexwhatis.html
                                                                 be followed by executive departments and agencies
  Starting Your Business                    www.sba.gov/starting/in establishing, maintaining, evaluating, improving,
  Start-up Kit                              www.sba.gov/smallbusinessplanner/index.html
                                                                 and  reporting on internal controls in their program
  On Line Training                                               and  administrative activities.
                                            www.sba.gov/services/training/index.html
  Outside Resources and Business Hotlinks   www.sba.gov/hotlist/
                                                      AA         Associate Administrator

                                                     AFMAC Audit and Financial Management Advisory
FOR ESTABLISHED BUSINESSES
                                                               Committee
  Financing Your Business                   www.sba.gov/services/financialassistance
                                                               Assists the Administrator in overseeing SBA’s
  Contracting                               www.sba.gov/services/contractingopportunities
                                                               financial operations.
  Surety Bond                               www.sba.gov/services/financialassistance/suretybond/index.html
                                                      AFR       Agency Financial Report
  Business Opportunities                    www.sba.gov/expanding/
                                                                The name of one of the annual PAR reports.

                                                         APR	Annual Performance Report
CONTRACTING WITH THE GOVERNMENT
                                                                   A report required by the GPR that presents a fed-
  Government Contracting                    www.sba.gov/GC         eral agency’s progress in achieving the goals in its
  PRO-Net:                                  pro-net.sba.gov/       strategic plan and performance budget.

                                                         ARRA	America’s Recovery Capital Loan Program
DISASTER ASSISTANCE                                            A new temporary guarantied loan program autho-
  Disaster Assistance                       www.sba.gov/services/disasterassistance
                                                               rized by the American Recovery and Reinvestment
  Disaster Area Office Locations                               Act of 2009.
                                            www.sba.gov/services/disasterassistance/officelocations
  FEMA Information                          www.fema.gov
                                                     BATF	         Business Assistance Trust Fund.
                                                                   A trust fund in the U.S. Treasury maintained to
Phone Numbers to Call                                              receive and account for donations made by private
                                                                   entities for activities to assist small business.
SBA Answer Desk (Toll Free) (800) 827-5722
                                                                         APPENDICES




Appendix 1                                                  The delegation of responsibility for the 7(a) guar-
                                                            anty program to SBA’s participating lenders na-
Improper Payments                                           tionwide for the making, servicing and liquidation
                                                            of 7(a) loans causes a medium risk of improper
As required by the Improper Payments Information            payments in the guaranty purchase process that is
Act, the SBA reviewed its payment programs for              subject to SBA oversight, monitoring and atten-
improper payments during FY 2009. The SBA                   tion to identified discrepancies. The 7(a) guaranty
Inspector General’s reports issued this year on the         purchase process operates in a center in Herndon,
sampling and test methodologies for improper                Virginia that purchases defaulted 7(a) guarantied
payments were considered in the development                 loans and in centers in Fresno, California and
of the SBA’s FY 2009 improper payment results.              Little Rock, Arkansas that purchase defaulted
Consequently, the SBA has restated some of the              SBAExpress guarantied loans. The 7(a) guaranty
FY 2008 improper payment results in this year’s             loan origination process is considered to be low risk
report and has changed the methodologies used               with regard to the approval of loans that are deemed
in the statistical sampling process for the 7(a) and        to be ineligible for the 7(a) program.
504 programs. In addition, the methodology used
for the disaster improper payment program was               The risk of FY 2009 improper payments in the 504
changed to use disbursements of disaster loans              CDC program is deemed by the SBA to be a low
rather than disaster loan approvals and to fully            risk due to extensive controls that exist in the loan
consider documentation required in SBA’s Disaster           origination process that include reviews by SBA
program procedures.                                         program and legal professionals. This includes both
                                                            CDC debenture issuance and financings by CDCs
An Agency should:                                           to the small concerns.
I.   Briefly describe the risk assessment(s), performed     The SBIC program has a low risk of improper pay-
     subsequent to completing its full program inven-       ments due to extensive internal controls, including
     tory. List the risk-susceptible programs (i.e.,        legal review over guaranty issuance and default pur-
     programs that have a significant risk of improp-       chase activities. The SBIC examination program
     er payments based on OMB guidance thresh-              subjects SBICs to at least a biennial review of the
     olds) identified through its risk assessments. Be      SBICs investments in small business ventures.
     sure to include the programs previously identi-
     fied in the former Section 57 of Circular A-11         The Disaster program has a low risk of loss due to
     (now located in Circular A-123, Appendix C).           extensive, thorough operational controls over the
     Please highlight any changes to risk assessment        Disaster application, damage verification, credit
     results that occurred since last years report.         review and loan closing activities.
Response: The SBA’s four major credit programs              II. Briefly describe the statistical sampling process
are included in the improper payments program.                  conducted to estimate the improper payment
They are: (1) 7(a) Business Loan Program, (2) 504               rate for each program identified. Please high-
Certified Development Company Program, (3)                      light any changes to the statistical sampling
Small Business Investment Company Program                       process that occurred since the last improper
and (4) Disaster Loan program. The first three                  payment report.
are loan guaranty programs and disaster is a direct
lending program. No other SBA programs meet                 Response: The 7(a) loan purchase statistical sam-
OMB guidance thresholds for improper payment                pling process was changed in FY 2009 in response
reporting. There have been no changes in SBA’s risk         to the SBA Inspector General’s report issued in July
assessment process since the last improper payment          2009 on the FY 2008 report. Last year’s improper
report.                                                     payment report applied the sampling guidance
                                                            in OMB Circular A-123 Appendix C directly
                                                            to SBA’s loan purchase program. This year the

                                               Agency Financial Report   FY 2009
                                                                                                                    113
                                 APPENDICES



      sampling process was enhanced in response to the                tory provisions, SBA regulations, any agreement
      OIG draft report.                                               the lender executed with SBA, standard operating
                                                                      procedures (SOPs), loan authorizations, and of-
      The 7(a) and 504 CDC populations contain                        ficial SBA notices and forms applicable to the 7(a)
      loan types that are not homogeneous and exhibit                 loan program. The reviews were to determine if
      skewed distributions in loan size. That is, large               the lender (1) originated the loan in a prudent and
      loans constitute a relatively smaller percentage of             commercially reasonable manner, (2) misrepresent-
      the populations by count, but a larger percentage               ed or failed to disclose a material fact to SBA, and/
      by dollar amount. Therefore, the SBA stratified                 or (3) put SBA’s financial interest at risk.
      the data on several key variables and used a sam-
      pling method known as Probability Proportional                  For 7(a) guarantied loan approvals the sample cases
      to Size sampling with replacement. This is a                    were chosen using PPS Sampling with replacement
      sampling technique in which the probability that                from all loan guaranties approved during the 12
      a particular loan will be selected for the sample is            month period ended March 31, 2009. The loan
      proportional to the population size of the corre-               guaranties were approved through SBA’s loan pro-
      sponding strata. By using PPS, the SBA attempts                 cessing centers, consisting of the Standard 7(a) Loan
      to create a comprehensive sample that addresses                 Guaranty Processing Center with dual locations in
      the fact that different types of loans may have                 Sacramento, California and Hazard, Kentucky; and
      unequal improper payment probabilities.                         the Sacramento, California Loan Processing Center
                                                                      which handles PLP and SBAExpress loan approvals.
      For 7(a) purchase reviews, the sample cases were                The approval population was divided into five strata
      chosen using PPS sampling with replacement                      based on the loan delivery method. The 7(a) loan
      from all purchases approved during the 12 month                 delivery methods are SBA Express, Community
      period ended March 31, 2009. The purchase                       Express, Patriot Express, Preferred Lender Program,
      population was divided into twelve strata based                 and all others. The SBA determined the appro-
      on the following three factors: (1) which servic-               priate total sample size to be 112 loans from the
      ing office processed the purchase, (2) whether the              population. The base sample size was 110 as de-
      purchase process was streamlined, and (3) whether               termined by the SBA in the FY 2008 AFR. Using
      the loan was considered an early default. Using                 the PPS sampling process within strata, the SBA
      the PPS approach, the SBA determined the ap-                    rounded up when a fractional loan was selected in
      propriate total sample size to be 203 loans from                any stratum. Therefore, the final sample size for FY
      the population. The sample included aggregate                   2009 was 112. The estimated improper payments
      purchase outlays of $89,774,114 and improper                    rate for the annual period ending March 31, 2009
      payments of $3,014,571 within the sample. Using                 was calculated as 0 percent based on the aggregate
      the Hansen-Hurwitz estimation method, the                       gross disbursement amount of $90,321,505 on the
      estimated improper payment rate for the 7(a)                    approved loans with no improper payments found.
      guaranty purchase population is 3.81 percent for
      the annual period ending March 31, 2009. SBA’s                  For 504 CDC approval reviews, the sample cases
      previous improper payment rates were calculated                 were chosen using PPS sampling with replacement
      at 0.53 percent for FY 2008 (now adjusted to 3.2                from all loan guaranties approved during the 12
      percent in connection with the audit by SBA’s                   month period ended March 31, 2009. The loan
      Office of Inspector General), 0.43 percent for fiscal           guaranties were approved at the SBA’s Sacramento
      year 2007, and 1.56 percent for fiscal year 2006.               loan processing center and closed at various SBA
                                                                      district offices, with servicing subsequently han-
      The 7(a) loan guaranty purchase and approval                    dled by the Fresno, California Commercial Loan
      reviews were conducted to examine whether the                   Servicing Center and the Little Rock, Arkansas
      lender complied materially with the 7(a) loan                   Commercial Loan Servicing Center. The approval
      program origination requirements including statu-               population was divided into three strata based on

                                            Agency Financial Report    FY 2009
114
                                                                       APPENDICES



the loan delivery method. The 504 loan delivery           loan disbursements from the period July 1, 2008
methods are Accredited Lenders Program, Premier           to June 30, 2009 was used. The scope of the QAR
Certified Lenders Program, and Regular. The SBA           covers three compliance areas: (1) basic eligibility,
determined the appropriate total sample size to be        (2) adherence to relevant laws, rules, regulations
49 loans from the population. The base sample             and standard operating procedures, and (3) cred-
size was 48 as determined by the SBA in the FY            itworthiness. The total number of loans disbursed
2008 AFR. Using the PPS sampling process within           was 20,425 and the total value of disbursements
strata, the SBA rounded up when a fractional loan         was $806 million. The improper payment rate
was selected in any stratum. Therefore, the final         determined was 20.9 percent or $168.5 million in
sample size for FY 2009 was 49. The estimated im-         improper payments.
proper payments rate for the annual period ending
March 31, 2009 was calculated as 0 percent based          III. Describe the Corrective Action Plans for:
on the aggregate gross disbursement amount of               a. Reducing the estimate rate and amount of
$61,951,000 on the approved loans with no im-                  improper payments for each type of root
proper payments found.                                         cause of error (e.g. Administrative and
The SBIC program used OMB guidance to deter-                   Documentation errors, Authentication and
mine a random sample of 95 SBIC financings by                  Medical Necessity errors, and Verification and
SBICs having SBA guarantied leverage during the                Local Administrative errors). This discussion
period July 1, 2008 to June 30, 2009. Improper                 must include the corrective action(s) for each
payments were identified when an SBIC examina-                 different type of root cause of error. If efforts
tion or a review by a SBIC program analyst found               are ongoing, it is appropriate to include that
a discrepancy with SBIC program regulations in                 information in this section and to highlight
the sampled financings. About 48 percent of the                current efforts, including key milestones.
sampled financings were subjected to an SBIC ex-            b. Grant-making agencies with risk susceptible
amination during the year. The rest of the sampled             grant programs, discuss what your agency has
financings were reviewed by SBIC program ana-                  accomplished in the area of funds stewardship
lysts. The program analysts reviewed term sheets               past the primary recipient. Include the status
(which include the terms of the financings), Forms             on projects and results of any reviews.
468 financial statements, Forms 1031s reports of in-
dividual financings and other material to determine       A. Response: The 7(a) guaranty purchase process
compliance with regulatory requirements. The              improper payments program includes identifying
reviews revealed one potential erroneous payment          and tracking the reasons for any improper pay-
among the sampled financings involving a possible         ments discovered in the IPIA reviews, and then
pre-payment penalty that constituted $1,000,000           making appropriate adjustments to the guaranty
of the $88,004,157 in financings sampled, or 1.1          purchase process to reduce the purchase error rate
percent of the total.                                     in future years. Improper payments in the guar-
                                                          anty purchase process arise from the failure of a
The Disaster program improper payment rate was            purchase processor to identify material lender defi-
determined using the Disaster Quality Assurance           ciencies in the handling of an SBA guarantied loan.
Review program that reviews the approved loan             Primary reasons noted for the determination that
portfolio annually to identify any deficiency that        all or a portion of the guaranty purchases identified
would result in an improper payment. As a result          as improper were:
of an audit by SBA’s Inspector General, beginning
in FY 2009, the Disaster program improper pay-                yyImproper use of proceeds (not in accordance
ments are based on disaster loan disbursements, not             with loan authorization).
disaster loan approvals as in prior years. Following
OMB guidance, a sample of 245 randomly selected

                                             Agency Financial Report   FY 2009
                                                                                                                   115
                                 APPENDICES



          yyFailure to maximize recovery on loan collateral           payments in 7(a) loan processing and 504 loan
            in liquidation proceedings.                               originations because of multiple reviews that take
          yyIncomplete documentation to justify lender                place when a loan is being processed.
            action.
                                                                      The SBIC guaranty program had one potential er-
          yyUnderpayment of interest owed lender.                     roneous payment. Over the four-year period that
          yyFailure to verify borrower financial                      this sampling methodology has been used, there
            information using IRS tax transcripts.                    have only been two instances of potentially errone-
          yyDisbursement of guaranty purchase without                 ous payments. The SBA expects that this minimal
            required SBA Form 1919 for SBAExpress                     number of erroneous payments will continue to
            loan.                                                     be the case and has instituted a number of steps to
      Corrective action procedures followed for the 7(a)              ensure that. First, in the early to mid 1990s, more
      guaranty purchase process involve advising the                  rigorous program standards were instituted. This
      purchase processing team of improper payment                    has led to more knowledgeable fund managers
      determinations and also providing clarification as to           and reduced the likelihood that program fraud
      the nature of the issues to avoid possible improper             would be committed. Second, the SBA requires
      payments in the future. In this regard, a fully docu-           all fund managers to undergo training on regula-
      mented guaranty purchase procedure handbook                     tions as a condition for receiving leverage. Almost
      has been completed, including transcript analysis               all SBICs are represented by very knowledgeable
      instructions, and is updated as needed. This assures            service providers who have extensive experience
      consistency in the purchase process and will serve to           in the program. As part of the licensing process,
      minimize errors. In addition, the purchase centers              the SBA conducts extremely detailed background
      are two years into a process of lean six sigma based            checks on fund managers with both the Office of
      continuous improvement to enhance standardiza-                  the Inspector General and the Federal Bureau of
      tion and reduce deviations. Other remedial actions              Investigation. The SBA also does credit checks
      include:                                                        on all potential fund managers as part of the due
                                                                      diligence process in licensing. The SBA has a
          yyidentify and analyze error patterns,                      program of auditing licensees on a periodic basis
          yycommunicate error patterns to the centers                 to determine compliance. These steps ensure that
            processing purchases,                                     only fiscally prudent managers become part of the
          yyreview current policies and procedures to                 program.
            ensure that any error patterns are appropriately
            addressed in current guidance,                            The Disaster program improper payment rate in FY
                                                                      2009 is substantially greater than reported in prior
          yyrevise policies and procedures where necessary,
                                                                      years. The increased rate does not reflect a greater
          yyissue guidance to the purchase centers on                 risk in the portfolio, only that the SBA is classify-
            specific issues,                                          ing improper payments differently than in the past.
          yyprovide training, and                                     In prior years improper payments represented loan
          yysupplement center resources where possible                funds that were disbursed to a borrower that based
            to ensure ongoing quality assurance review                on Standard Operating Procedures were not appro-
            programs that will identify any emerging                  priate. In FY 2009 the majority of errors identified
            patterns or potential problem areas that                  were the result of missing loan documentation.
            might result in future improper payments, as              The errors generally do not have an impact on the
            well as take action to mitigate these potential           eligibility of the borrower to receive the funds or
            problem areas.                                            the willingness and/or ability of the borrower to
      7(a) loan guaranty approvals and CDC loan ap-                   repay the disaster loan. The SBA has instituted ad-
      provals had no improper payments. There appear to               ditional training to ensure that staff is aware of all
      be sufficient safeguards in place to prevent improper           paperwork requirements and the proper steps to

                                            Agency Financial Report    FY 2009
116
                                                                                                               APPENDICES



be taken to waive requirements when appropriate.                                                  (ii) where no measurement is provided, agency
Additionally, a new quality assurance team report-                                                     should indicate the date by which a mea-
ing to the Disaster Headquarters office is being                                                       surement is expected;
assembled to provide an independent review of the
Disaster processing center. The improper payment                                                  (iii) if the Current Year (CY) is the baseline
review will then be completed more frequently                                                           measurement year, indicate by either note or
than annually allowing corrective actions to be                                                         by “n/a” in the Prior year (PY) column;
implemented in a timely manner.                                                                   (iv) if any of the dollar amounts(s) included in
B. Response: The SBA does not have any report-                                                         the estimate correspond to newly established
able grant programs under risk susceptible OMB                                                         measurement components, separate the two
guidance. However, the Agency does employ in-                                                          amounts to the extent possible;
ternal control measures to address improper grant                                                 (v) include outlay estimates for CY+1, +2 and
payments.                                                                                             +3; and
IV. Program improper Payment Reporting                                                            (vi) agencies are expected to report on CY activ-
  (a) The table below is required for each report-                                                     ity, and if not feasible, the PY activity is
      ing agency. Agencies must include the fol-                                                       acceptable. (future year outlay estimates
      lowing information:                                                                              (CY+1, +2 and +3) should match the
                                                                                                       outlay estimates for those years as reported
  (i) all risk susceptible programs must be listed                                                     in the most recent President’s Budget.)
      in this chart whether or not an error mea-
      surement is being reported;                                                             Response: The SBA’s report of improper payments
                                                                                              is shown in the following table.

                                                      Improper Payment Reduction Outlook ($ in millions)
                            1                                                                    1                                1                                 1
                     FY08         FY08       FY08   FY091            FY09      FY09        FY10    FY10         FY10        FY11    FY11          FY11        FY12    FY12 FY12
 Program
                   $ Outlays      IP %       IP $ $ Outlays          IP %      IP $      $ Outlays IP %         IP $      $ Outlays IP %          IP $      $ Outlays IP % IP
 7(a) Guaranty       1,230.9      3.206     39.46      1,805.4       3.816      68.8      1,900.0      3.50      66.5      1,800.0       3.25      58.5      1,700.0      3.00     51.0
 Purchases1
 7(a) Guaranty      11,739.1        0.0       0.0      8,934.7        0.0       0.0      12,000.0       0.0       0.0     13,000.0        0.0      0.0      14,000.0       0.0      0.0
 Approvals2
 CDC                 5,245.6        NA        NA       3,820.6        0.0       0.0       4,000.0       0.0       0.0      4,500.0        0.0      0.0       5,000.0       0.0      0.0
 Debentures3
 CDC Loans           5,245.6        0.0       0.0      3,820.6        0.0       0.0       4,000.0       0.0       0.0      4,500.0        0.0      0.0       5,000.0       0.0      0.0
 Guarantied2
 SBIC                2,283.0        0.0       0.0      1856.0         1.1       20.4      1,800.0       1.0      18.0      1,750.0        1.0      17.5      1,750.0       1.0     17.0
 Guaranties4
 Disaster Loan        825.3         .74       6.1       806.0        20.96     168.5       800.0       16.7     133.6       800.0        13.3     106.4       800.0       10.7     85.6
 Approvals5

 1. Outlays in this report represent the base amount of the program activity related to SBA improper payments; and this amount will differ from the amount reported as outlays in SBA’s
    President’s Budget submissions because they include reestimates of subsidy cost, reimbursements to SBA administrative funds and other costs. Outlays for 7(a) Guaranty Purchases
    are the amount of disbursements for the purchase of defaulted guarantied loans. Outlays for 7(a) Guaranty Approvals are the amount of new guaranty approvals by banks and other
    SBA lending partners. Outlays for CDC Debentures and CDC Loans Guarantied are approvals irrespective of disbursement, net of approval increases, decreases, reinstatements and
    cancellations for the current year. Outlay figures for Disaster are loan disbursements.
 2. Beginning with FY 2007, 7(a) and CDC reporting includes guaranties approved.
 3. SBA has zero improper payments assumed for CDC debentures
 4. SBIC guaranties include SBA guaranties of SBIC investments in small business for SBICs having SBA leverage.
 5. Disaster Loan Approvals projected for FY 2010 thru FY 2012 reflects a historical average level.
 6. The SBA Inspector General issued audit reports on the 7(a) and disaster improper payment programs in July and March 2009. As a result of findings and recommendations in these
    reports the SBA has changed its methodology used in both of these programs for sampling and testing improper payments. As a result the improper payment rates and dollars have
    increased in FY 2009 reflecting these changes. In addition, the 7(a) Guaranty Purchase program FY 2008 improper payment rate is restated reflecting the findings and conclusions
    from the IG audit (3.20 versus 0.53 percent). The MD&A section of this report has additional information on the consequences of the IG audits.




                                                                             Agency Financial Report           FY 2009
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                                 APPENDICES



        (b) Discuss you agency’s recovery of improper                 very rare step and has not been necessary for the
            payments, if applicable. Include in your                  most part.
            discussion the dollar amount of cumula-
            tive recoveries collected beginning with FY               The Disaster program improper payments are gen-
            2004.                                                     erally the result of loan documentation errors and
                                                                      do not result in a disaster victim receiving funds
      Response: For 7(a) guaranty purchases, the SBA                  that they are not eligible to receive. The disaster
      has established a recovery target of 85 percent                 loan program operation has a built in recovery
      of the aggregate amount of improper payments                    system in that the majority of loans made are col-
      identified by March 30, 2010 (and will pay the                  lateralized and all loans have to be repaid.
      lender two small underpayments noted). While
      SBA will attempt to recover 100 percent of the                  V.                  Discuss your agency’s recovery auditing
      amounts identified as overpayments (with the                                        effort, if applicable, including any contract
      exception of the purchase where no loan file has                                    types excluded from review and the justifica-
      yet been located), litigation may be necessary in                                   tion for doing so; actions taken to recoup
      some instances with uncooperative lenders and                                       improper payments, and the business process
      additional information may be presented which                                       changes and internal controls instituted and/
      could indicate that all or a portion of a disburse-                                 or strengthened to prevent further occurrences.
      ment is not actually improper. Also, decisions may                                  In addition complete the table below.
      be made when appropriate to accept reasonable
      settlements of improper payment claims rather

                                                                                          Amount subject to Review   Actual Amount Reviewed
      than to pursue protracted recovery proceedings.


                                                                                                                                                                                                                    Amount Recovered PYs
                                                                                                                                                                                                                                           Cumulative Amount



                                                                                                                                                                      Amount Recovered CY
                                                                                                                                              Amount Identified for                         Amount Identified for                                                    Cumulative Amount
      Procedures for Recovery of 7(a) guaranty purchas-


                                                                       Agency component
                                                                                                                                                                                                                                           Identified for Recovery
      es: SBA will make formal written demand upon

                                                                                          for CY Reporting           and Reported CY          Recovery CY                                   Recovery PYs                                                             Recovered (CY + PYs)
      and/or engage in discussions with 7(a) lenders it
      identifies as having received improper payments.                                                                                                                                                                                     (CY + PYs)
      If a lender refuses to return a payment, litigation or          N/A                      N/A                       N/A                      N/A                                           N/A                 N/A                                                  N/A
      other action will be explored if analysis determines
      that such action will be cost effective and there will          Response: Recovery auditing is a control tech-
      be a reasonable chance for the Agency to prevail.               nique to identify improper contractor payments
      The litigation office in SBA’s Office of General                and initiate recovery actions where appropri-
      Counsel will conduct this analysis                              ate. Even though SBA does not meet the OMB
      The SBA has a recovery program for the SBIC                     threshold for recovery auditing, SBA does employ
      program and current recovery efforts are very                   internal control measures to address improper con-
      effective. Most regulatory violations are resolved              tract payments.
      in a fairly short time frame. The resolution can be             VI. Describe the steps the agency has taken and
      in a number of ways. The violation may be deter-                    plans to take (including time line) to ensure
      mined not to be a violation of the regulations after                that agency managers (including the agency
      further study. In other instances, the SBIC may be                  head) are held accountable for reducing and
      asked to change the terms of the investment in the                  recovering improper payments.
      portfolio concern in a manner that resolves the is-
      sue. If the situation cannot be corrected, the SBIC             Response: The SBA’s Strategic Goal 4 is to assure
      may be asked to divest its interest in the portfolio            SBA programs operate efficiently and effectively,
      concern. In very rare instances, the SBIC might be              including compliance with federal regulations im-
      found to be in default of its covenants and trans-              proper payment guidelines. The strategic goals are
      ferred to the Office of SBIC Liquidations, where                included in annual performance plans for all of its
      recovery efforts will be implemented. This is a                 programs as business objectives, and these business

                                            Agency Financial Report     FY 2009
118
                                                                       APPENDICES



objectives are included in employee performance           making and disbursement function, and are
plans. SBA management monitors accomplish-                responsible for the relatively minimal amounts of
ment of its business objectives in its performance        unauthorized and/or ineligible loans. In addition,
plan using its performance management process,            the Disaster Loan Program, by its very nature,
and action is taken when progress is not on target.       legally obligates the recipient of any disaster loan
Executive and management bonuses are based                (or any IP portion of a disaster loan) to pay back
on the accomplishment of business objectives              all the loan funds whether the loan contains any
included in employee annual performance plans.            Improper Payments or not. Not only is there a
This management process assures accountability of         legally binding contract (between the government
improper payment administration.                          and the SBA) to repay the loan, the contract is usu-
                                                          ally secured by real estate collateral which further
For the SBIC program, operations analysts are             strengthens the government’s recovery position.
evaluated, in part, on the resolution of regula-          Accordingly, an ODA recovery auditing effort is
tory violations in a timely manner. They are also         not applicable because each loan contract legally
evaluated, in part, on responding to requests for         assures recovery of the entire loan (with interest)
clarification on regulations by licensees. Although       as soon as the loan agreement is signed – notwith-
examiners are not evaluated on the number of              standing the circumstances.
violations they uncover, they are evaluated on
the number of exams they perform. The Agency              VII. Agency information systems and other
believes the assistance provided by the operations             infrastructure
analysts and the approximately annual exams for
leveraged SBICs provide an incentive to perform             A. Describe whether the agency has the informa-
within the framework of the regulations.                       tion systems and other infrastructure it needs
                                                               to reduce improper payments to the levels the
For the Disaster program, it is important to note:             agency has targeted.
The majority of improper payments identified thru
annual Quality Assurance Reviews indicate mini-           Response: SBA’s 7(a) program Guaranty Purchase
mal findings of unauthorized and/or ineligible            Tracking System supports the 7(a) guarantied loan
loans. Disaster program internal controls include         purchase process very well, and it is continually
the following:                                            updated to enhance the overall integrity of the
                                                          purchase process. The 504 program software used
   yyDisaster related damages are verified onsite         by the Central Servicing Agent is owned by the
     by SBA staff. The cost to repair and/or              SBA. Therefore the Agency has a higher level of
     replace the disaster damaged property is             control over that software than would typically ex-
     determined by SBA construction analysts.             ist with contractor owned systems. In addition the
   yyDisaster procedures also include credit              contractor provides audited financial statements
     checks, verification of income, verification         and a SAS 70 report to verify its system. The
     of ownership and checks with FEMA                    SBIC program maintains a data system that tracks
     to ensure that federal assistance is not             exams, exam findings and resolution of exam find-
     duplicated during loan processing and                ings. All individuals are empowered to refer any
     disbursement of all disaster loan funds.             case of suspected fraud to the Inspector General.
   yyEvery secured disaster loan is reviewed by           The Disaster loan program does have the informa-
     disaster staff attorneys for legal sufficiency       tion systems and other infrastructure it needs to
     and the use of electronic funds transfer is          reduce improper payments to targeted levels. For
     utilized to prevent lost and stolen checks.          example, ODA is engaged in an ongoing process
                                                          of developing and has already implemented an
Disaster program internal controls (checks and            integrated, electronic loan processing system to
balances) have always been a part of its loan             streamline, enhance and improve the loan-making


                                             Agency Financial Report   FY 2009
                                                                                                                 119
                                APPENDICES



      process. This system will support workflow                     VIII. Describe any statutory or regulatory barri-
      management, electronic file management and                         ers which may limit the agencies’ corrective
      document generation functions. In fact, a Quality                  actions in reducing improper payments and
      Assurance Task Force partnered with the Disaster                   actions taken by the agency to mitigate the
      Credit Management System development team to                       barriers’ effects.
      improve the Quality Assurance process with a goal
      to minimize future Improper Payments events as                 Response: Not applicable. The SBA does not
      much as possible. As a result, many of the busi-               have any statutory or regulatory barriers limiting
      ness rules that govern the programming of this                 improvement to its performance on improper pay-
      new system have been designed to help improve                  ments initiative.
      the Quality Assurance process. The DCMS will                   IX. Additional comments, if any, on overall
      significantly impact the disaster assistance pro-                  agency efforts, specific programs, best prac-
      gram and the manner in which it delivers services                  tices, or common challenges identified, as a
      to disaster victims.                                               result of IPIA implementation.
        B. If the agency does not have such systems                  Response: No additional comments.
           and infrastructure, describe the resources the
           agency requested in its most recent budget
           submission to Congress to obtain the neces-
           sary information systems and infrastructure.
      Response: Although SBA’s existing systems are
      used to adequately manage its programs to avoid
      improper payments, the SBA has requested ad-
      ditional funding in its FY 2011 budget request
      to support the implementation of the Loan
      Management and Accounting System. This is an
      important systems project that will require signifi-
      cant additional budget authority in SBA’s budgets
      through FY 2014. LMAS will enhance SBA’s
      administrative and loan receivables information
      systems that will support and improve improper
      payment identification and results.




                                           Agency Financial Report    FY 2009
120
                                                                      APPENDICES




Appendix 2 – Contact SBA: Useful Sites and Numbers
The SBA home page is www.sba.gov. Information on the programs may be accessed from this
site. Several of the more frequently visited sites are listed below:


 SBA INFORMATION
  Who We Are and What We Do                 www.sba.gov/aboutsba
  Find Your Local Office                    www.sba.gov/localresources/index.html
  SBA’s Plans and Reports                   www.sba.gov/aboutsba/budgetsplans/index.html
  SBA En Español                            www.sba.gov/espanol
  Ombudsman                                 www.sba.gov/ombudsman
  Online Library                            www.sba.gov/tools/resourcelibrary/index.html

 FOR START-UP BUSINESSES
  What is a Small Business?                 www.sba.gov/starting/indexwhatis.html
  Starting Your Business                    www.sba.gov/starting/
  Start-up Kit                              www.sba.gov/smallbusinessplanner/index.html
  On Line Training                          www.sba.gov/services/training/index.html
  Outside Resources and Business Hotlinks   www.sba.gov/hotlist/

 FOR ESTABLISHED BUSINESSES
  Financing Your Business                   www.sba.gov/services/financialassistance
  Contracting                               www.sba.gov/services/contractingopportunities
  Surety Bond                               www.sba.gov/services/financialassistance/suretybond/index.html
  Business Opportunities                    www.sba.gov/expanding/

 CONTRACTING WITH THE GOVERNMENT
  Government Contracting                    www.sba.gov/GC
  PRO-Net:                                  pro-net.sba.gov/


 DISASTER ASSISTANCE
  Disaster Assistance                       www.sba.gov/services/disasterassistance
  Disaster Area Office Locations            www.sba.gov/services/disasterassistance/officelocations
  FEMA Information                          www.fema.gov


Phone Numbers to Call:
SBA Answer Desk (Toll Free) (800) 827-5722
Disaster Customer Service Center (Toll Free) (800) 659 – 2955



                                            Agency Financial Report   FY 2009
                                                                                                             121
                                   APPENDICES




      Appendix 3 – Glossary of Acronyms and Abbreviations

      504     504 Certified Development Company Loan                      BD         Business Development
              Program                                                                The Office of Business Development uses SBA’s
              Provides small businesses with long-term, fixed                        statutory authority to provide business development
              rate financing for the purchase of land, buildings                     and federal contract support to small disadvan-
              and long-life capital equipment.                                       taged firms.

      7(a)    7(a) Loan Guaranty Program                                  BDMIS	 Business Development Management
              SBA’s primary loan program. It provides general                    Information System
              loan financing for a wide variety of purposes.                         The system that automates the certification and
                                                                                     annual review process for the 8(a) program.
      8(a)    8(a) Business Development Program
              Assists firms owned and controlled by socially and          BLIF	      Business Loan and Investment Fund
              economically disadvantaged individuals to enter                        Fund operated by the Treasury Department to
              and succeed in the economic mainstream.                                maintain the accounting records of loans approved
                                                                                     prior to 1992.
      A-123   Designation for OMB Circular on “Internal Control
              Systems.” It prescribes policies and procedures to          CA	Capital Access (See OCA)
              be followed by executive departments and agencies           CDC	Certified Development Company
              in establishing, maintaining, evaluating, improving,                   Refers to the Section 504 Certified Development
              and reporting on internal controls in their program                    Company debenture program.
              and administrative activities.
                                                                          CFO	Chief Financial Officer
      AA      Associate Administrator                                                The CFO is responsible for the financial leadership
      AFMAC Audit and Financial Management Advisory                                  of the Agency. This includes responsibility for all
            Committee                                                                Agency disbursements, management and coordi-
              Assists the Administrator in overseeing SBA’s                          nation of Agency planning, budgeting, analysis and
              financial operations.                                                  accountability processes

      AFR     Agency Financial Report                                     CFR	Code of Federal Regulations
              The name of one of the annual PAR reports.                             The codification of the general and permanent
                                                                                     rules published in the Federal Register by the
      APR	Annual Performance Report                                                  executive departments and agencies of the federal
              A report required by the GPR that presents a fed-                      government.
              eral agency’s progress in achieving the goals in its
              strategic plan and performance budget.                      CIO	Chief Information Officer
                                                                                     The CIO is responsible for the management of in-
      ARRA	America’s Recovery Capital Loan Program                                   formation technology for the Agency, including the
              A new temporary guarantied loan program autho-                         design, implementation and continuing successful
              rized by the American Recovery and Reinvestment                        operation(s) of information programs and initiatives.
              Act of 2009.
                                                                          CLA	       Office of Congressional and Legislative
      BATF	   Business Assistance Trust Fund.                                        Affairs
              A trust fund in the U.S. Treasury maintained to                        The CLA assists in the development and enactment
              receive and account for donations made by private                      of SBA legislative proposals and serves as the
              entities for activities to assist small business.                      liaison for SBA’s communications on all legislative
                                                                                     and congressional activities.


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122
                                                                               APPENDICES



COO     Office of the Chief Operating Officer                     FBCI	Faith-Based and Community Initiatives
                                                                               The office promotes SBA partnerships with faith-
COOP	Continuity of Operations Plan                                             based and neighborhood organizations to help
        A predetermined set of instructions or procedures                      people receive training and credit assistance.
        that describe how an organization’s essential func-                    In accordance with an Executive Order issued in
        tions will be sustained for up to 30 days following a                  February 2009, the name will change to the Center
        disaster and then return to normal operations.                         for Faith-Based and Neighborhood Partnerships.
CRC	Civil Rights Center                                           FCRA	Federal Credit Reform Act
        The CRC administers and enforces various federal                       A law enacted to provide a more realistic picture of
        statutes, regulations, and Executive Orders that                       the cost of U.S. government direct loans and loan
        relate to nondiscrimination and equal opportunity.                     guaranties.
DAIP    Disaster Assistance Plan                                  FECA	Federal Employees’ Compensation Act
        Executive Order 13411 mandates that the federal                        Provides compensation benefits to federal civilian
        agencies create a single application that fulfills the                 employees for work-related injuries or illnesses
        information requirements of all applicable federal                     and to their surviving dependents.
        disaster assistance programs.
                                                                  FEMA 	Federal Emergency Management Agency
DCMS	   Disaster Credit Management System                                      The agency that is tasked with responding to,
        The electronic system used by the SBA to process                       planning for, recovering from and mitigating
        loan applications for all new disaster declarations.                   against disasters.
DCIA	   Debt Collection Improvement Act                           FERS	Federal Employees’ Retirement System.
        A federal law to maximize collections of delinquent                    A three-tiered retirement plan for federal employ-
        debts owed to the government.                                          ees hired after 1984, composed of Social Security
DFP     Dealer Floor Plan                                                      benefits, a basic benefit plan, and contributions to
        A small pilot program to make revolving loans to                       a TSP.
        retail dealerships including automobile dealers that      FFMIA	Federal Financial Management
        began in July 2009.                                             Improvement Act of 1966
DLF	    Disaster Loan Fund                                                     A law that requires each agency to implement and
        Assists eligible small businesses impacted by                          maintain financial management systems that com-
        disasters.                                                             ply substantially with federal financial management
                                                                               systems requirements, applicable federal account-
ECCB	Enterprise Change Control Board                                           ing standards, and the USSGL.
        The ECCB is in charge of the administration of the
        centeralized network accounts for the SBA.                FHCS	Federal Human Capital Survey
                                                                               A survey administered by OPM, to measure federal
EEO	Equal Employment Opportunity                                               employees’ perceptions about how effectively
                                                                               agencies have managed their workforces.
ELA	Electronic Loan Application
        Simplifies the application process by providing           FICA	Federal Insurance Contribution Act
        electronic loan applications.                                          The law establishing a social security tax, a largely
                                                                               self-supporting program for employees.
FASAB	Federal Accounting Standards Advisory
      Board                                                       FMFIA	Federal Managers Financial Integrity Act
        Promulgates accounting principles for federal                          Requires ongoing evaluations and reports on the
        government reporting entities.                                         adequacy of the internal accounting and adminis-
                                                                               trative control systems of executive agencies.


                                                     Agency Financial Report   FY 2009
                                                                                                                                       123
                                    APPENDICES



      FPDS	Federal Procurement Data System                                 LMS	Loan Monitoring System
                                                                                      Aids the SBA in managing its core loan guaranty
      FT	Fiscal Transfer Agent                                                        programs and serves as one of the building blocks
      FY	Fiscal Year                                                                  in the overall systems modernization project.
               The SBA fiscal year begins on October 1st and               MAS	       Multiple Awards Schedule
               ends the following September 31th.
                                                                           MAX        Budget Information System
      GAO      U.S. Government Accountability Office                                  OMB uses the MAX Budget Information System to
               The audit, evaluation and investigative arm of                         collect, validate, analyze, model and publish budget
               Congress.                                                              Information.
      GC/BD    Office of Government Contracting and                        MD&A	      Management’s Discussion and Analysis
               Business Development                                                   The MD&A is considered required supplementary
               GB/CD works to cerate an environment fro maxi-                         information for federal financial statements and is
               mum participation by small, disadvantaged and                          designed to provide a high level overview of the
               woman-owned business in Federal Government                             Agency.
               contract awards and large prime subcontract
               awards.                                                     MRA	       Master Reserve Account
                                                                                      SBA’s fiscal agent maintains this escrow fund to
      GSA	     General Services Administration                                        facilitate the operation of the Certified Development
      GWAC	    Government wide Acquisition Contract                                   Company program.

      HUBZone Historically Underutilized Business-Zone                     MRF	       Master Reserve Fund
              Program                                                                 SBA’s fiscal and transfer agent maintains this
               Encourages economic development by the estab-                          reserve fund to facilitate the operation of the 7(a)
               lishment of federal contract award preferences                         secondary market program.
               for small businesses located in historically under-         NAICS	     North American Industry Classification
               utilized business zones.                                               System
      IP	Improper Payments                                                            NAICS is the standard used by federal statistical
               (See IPIA)                                                             agencies in classifying business establishments
                                                                                      for the purpose of collecting, analyzing, and pub-
      IPA	Independent Public Accountant                                               lishing statistical data related to the U.S. business
               A firm or person, other than the agency’s IG, who                      economy.
               meets the independence standards specified in
               GSA, and is engaged to perform the audit of a               NGPC	      National Guaranty Purchase Center
               federal agency or for other purposes.                                  SBA’s centralized loan guaranty purchase process-
                                                                                      ing center.
      IPIA	Improper Payment Infraction Act
               A federal law, enacted in 2002 to identify and              NWBC	      National Women’s Business Council
               reduce erroneous payments in the government’s                          A bi-partisan federal advisory council created to
               programs and activities.                                               serve as an independent source of advice and pol-
                                                                                      icy recommendations to the President, Congress,
      IT	Information Technology                                                       and the SBA on economic issues of importance to
               Refers to matters concerned with the design,                           women business owners.
               development, installation and implementation of
               information systems and applications.                       OCA	       Office of Capital Access
                                                                                      The office responsible for small business program
      L/LMS	Loan and Lender Monitoring System                                         loans, lender oversight, the investment company



                                                 Agency Financial Report    FY 2009
124
                                                                              APPENDICES



       program, the surety bond program and the interna-         OPM          U.S. Office of Personnel Management
       tional trade program.                                                  The federal government’s human resources agency.

OCFO   Office of the Chief Financial Officer                     ORACLE The Accounting program used by SBA’s
       The office responsible for the financial activity                Administrative Accounting Division
       of the Agency, including Agency disbursements,
       management and coordination of Agency planning,           ORCA	        Online Representation and Certification
       budgeting, analysis and accountability processes.                      Application
                                                                              an e-Government initiative that was designed to
OCIO   Office of the Chief Information Officer                                replace the paper based Representations and
       Supports and provides guidance for SBA’s na-                           Certifications process
       tionwide computer automation and information
       technology efforts.                                       OSA	         Office of Strategic Alliances

OCRM   Office of Credit Risk Management                          OVBD         Office of Veterans Business Development
                                                                              The SBA office that works to enhance and increase
ODA	   Office of Disaster Assistance                                          successful small business ownership by veterans.
       SBA office that promotes economic recovery
       in disaster ravaged areas. SBA loans are the              PAR	         Performance and Accountability Report
       primary form of federal assistance for non-farm,                       Reporting that presents financial, budgetary and
       private sector disaster losses for individuals and                     performance information to OMB, Congress and
       businesses.                                                            the public.

OFA	   Office of Financial Assistance                            PART         Program Assessment Rating Tool
       SBA office that administers various loan programs                      An OMB methodology developed to assess and
       to assist small businesses.                                            improve program performance.

OFO    Office of Field Operations                                PCECGF	 The Pollution Control Equipment Contract
       SBA office that represents field offices, including               Guarantee Fund
       regional and district offices, at headquarters.                        Supports costs associated with the credit portfolio
                                                                              of pre-October 1991 pollution control equipment
OGC	   Office of General Counsel                                              loans and guaranties being liquidated by the SBA.
       Provides legal advice for senior management, as
       well as legal support for all Agency programs,            PCOE	        President’s Council on Integrity and
       initiatives and administrative responsibilities.                       Efficiency

OHCM   Office of Human Capital Management                        PIA	         Privacy Impact Assessment
       Supports the strategic management of human                             Part of the Privacy Impact Statement from the
       capital in the accomplishment of the Agency’s                          Privacy Act.
       mission.                                                  PLP          Preferred Lender Program
OIG    Office of Inspector General                                            Covers certified or preferred lenders that receive
       Conducts and supervises audits, inspections                            full delegation of lending authority.
       and investigations relating to SBA programs and           PMA	         President’s Management Agenda
       operations.                                                            A Bush Administration program to improve man-
OMB    U.S. Office of Management and Budget                                   agement of the federal government.
       Presidential office that oversees preparation of the      QA	          Quality Assurance
       federal budget and supervises its administration in
       Executive Branch agencies.                                QAR	         Quality Assurance Review



                                                    Agency Financial Report   FY 2009
                                                                                                                                    125
                                    APPENDICES



      SAS	Statement on Auditing Standards                                  SCORE	 Offers counseling and training for small business
              Establish standards and provide guidance on the                         owners who are starting, building or growing their
              design and selection of an audit sample and the                         businesses. Sponsored by the SBA, SCORE’s ser-
              evaluation of the sample results.                                       vices are free of charge and are provided by retired
                                                                                      or active business volunteers.
      SBA	Small Business Administration
              A federal agency of the Executive Branch whose               SDB	Small Disadvantaged Business
              mission is to aid, counsel and protect the interests                    Small business owned and controlled by
              of small businesses and help families and busi-                         individual(s) claiming to be socially and economi-
              nesses recover from national disasters.                                 cally disadvantaged.

      SBA	    Provides selected lenders with a 50 percent guar-            SMG 	Secondary Market Guaranty
              anty on their loans in exchange for the ability to use
              primarily their own application and documentation            SOP	Standard Operating Procedure
                                                                                      SOPs are the primary source of the Agency’s
              forms. This makes it easier and faster for lenders to
                                                                                      internal control.
              provide small business loans of $250,000 or less.

      SBDC	Small Business Development Center                               SOX	Sarbanes-Oxey Act 2002
                                                                                      The law introduced major changes to the regulations
              SBDCs deliver management and technical as-
                                                                                      of financial practice and corporate governance.
              sistance, economic development and management
              training to existing and prospective small business-         SSBIC	Specialized Small Business Investment
              es through cooperative agreements with universi-                   Company
              ties and colleges and government organizations..                        Provides equity capital, long-term loans, debt-
                                                                                      equity investments and management assistance
      SBG	Surety Bond Guarantee Program
                                                                                      to socially or economically disadvantaged small
              Provides guarantees bid, performance and payment
                                                                                      businesses.
              bonds for contracts up to $2 million for eligible
              small businesses that cannot obtain surety bonds             TOP        Treasury Offset Program
              through regular commercial channels.                                    A centralized debt collection program developed by
                                                                                      the Treasury Department’s FMS to assist agencies
      SBGRF	Surety Bond Guarantees Revolving Fund
                                                                                      in the collection of delinquent debts owed to the
              Provides assistance to small business contractors
                                                                                      Federal Government.
              in obtaining bid, performance and payment bonds
              for construction, service and supply contracts.              WBC	Women’s Business Center Program
                                                                                      WBCs provide long-term training and counseling to
      SBIC	Small Business Investment Company
                                                                                      women owning or managing a business, including
              Provides equity capital, long-term loans, debt
                                                                                      financial, management, marketing and technical
              equity investments and management assistance to
                                                                                      assistance, and procurement.
              small businesses, particularly during their growth
              stages.

      SBLC	Small Business Lending Companies
              Non-depository small business lending companies
              listed by the SBA Office of Capital Access.

      SBPRA	Small Business Paperwork Relief Act of
            1992

      SBREFA	Small Business Regulatory Enforcement
             Fairness Act


                                                 Agency Financial Report    FY 2009
126
                                                 Acknowledgments

This Agency Financial Report was created by the energy and talent of the U.S. Small Business Administration staff. To all
these dedicated individuals listed below, as well as those not listed, we offer our sincerest acknowledgement.


                         CFO OFFICE                                                 PROGRAM OFFICES

Jonathan Carver               John Kushman                      Michael Avant                  Christine Koronides
Melissa Atwood                David Lippold                     Dennis Bumpass                 Nina Levine
Raymond Baca                  Theresa Lucero                    Shawne Carter                  Robert Naylor
James Bates                   Valerie Meadows                   Martin Coyret                  Bruce Purdy
Rory Berges                   Shirley Mebane                    Eugene Cornelius               Yan Russell
Deepak Bhargava               Robert Montgomery                 Jeanne Crepeau                 Holly Schick
Debra Braswell                Maureen Moore-Vellucci            Alan Escobar                   Ajoy Sinha
Jeffrey Brown                 JoAnn Mueller                     Roger Garland                  Annie Spiczak
Joshua Bull                   Rosemary Ngwiri                   Martin Gold                    James VanWert
Ashok Chaudhry                Ivey Packwood                     Grady Hedgespeth               Yvonne Walters
Randall Christopherson        Sarada Parthasarathy              Brian Hooper                   Gloria Wright-Simms
Elizabeth Cottom              Mike Peterson                     Calvin Jenkins
Bruce Crippin                 Janette Porter
Mary Dam                      Trevor Postlethwaite
Gayle Daugherty               Anthony Powell
Tamara Dollarhite             Tong Qin
Sharon Evans                  Steve Ramey
Angela Ferrell                Daniel Rivas
Leon Fleischer                Donald Romek
Jananne Garl                  Ann Marie Schaef
Michelle Gierwatoski          Harold Simmons
Leslie Godsey                 Rodney Simoneau
Gordon Goeke                  Jessica Smith
Timothy Gribben               Katrina Sterling
Kylina Hanley                 Bruce Swartz
Marilyn Henderson             Sylvia Thornton
Joseph Henry                  Darrell White
Malene Hernandez              Kelly Wilcox
Blake Hoing                   Rita Williams
Michael Holland               Petrina Worthington
Jonathan Jones                Uma Yanamandra
Thomas Karg




                                                                        We would also like to acknowledge the SBA Office
                                                                        of the Inspector General and KPMG, LLP for the
                                                                        professional manner in which they conducted the
                                                                        audit of the FY 2009 financial statements.

                                                                        We offer our special thanks to Innovative
                                                                        Consultants International (ICI), and Corporate
                                                                        Visions, Inc. for outstanding contributions to
                                                                        producing this report.


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