SBA Management Review: Office of Credit Risk Management (House Small Business Committee hearing, February 5, 2020)
Summary
The printed record of a House Committee on Small Business hearing, SBA Management Review: Office of Credit Risk Management, held February 5, 2020, Small Business Committee Document Number 116–069. The committee met at 11:35 a.m. in Room 2360 of the Rayburn House Office Building with Chairwoman Nydia Velázquez presiding; she and Ranking Member Steve Chabot gave opening statements. The sole witness was Susan E. Streich, Director of the Office of Credit Risk Management, which the chairwoman describes as responsible for oversight of SBA's lending programs and its $120 billion 7(a) and 504 loan portfolios serving the nation's 30 million small businesses. The appendix carries Streich's prepared statement and her responses to questions from Velázquez, Chabot and Ross Spano.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
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“SBA Management Review: Office of Credit Risk Management (House Small Business Committee hearing, February 5, 2020).”
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SBA MANAGEMENT REVIEW: OFFICE OF CREDIT
RISK MANAGEMENT
HEARING
BEFORE THE
COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES
ONE HUNDRED SIXTEENTH CONGRESS
SECOND SESSION
HEARING HELD
FEBRUARY 5, 2020
Small Business Committee Document Number 116–069
Available via the GPO Website: www.govinfo.gov
U.S. GOVERNMENT PUBLISHING OFFICE
39–556 WASHINGTON : 2020
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HOUSE COMMITTEE ON SMALL BUSINESS
NYDIA VELÁZQUEZ, New York, Chairwoman
ABBY FINKENAUER, Iowa
JARED GOLDEN, Maine
ANDY KIM, New Jersey
JASON CROW, Colorado
SHARICE DAVIDS, Kansas
JUDY CHU, California
MARC VEASEY, Texas
DWIGHT EVANS, Pennsylvania
BRAD SCHNEIDER, Illinois
ADRIANO ESPAILLAT, New York
ANTONIO DELGADO, New York
CHRISSY HOULAHAN, Pennsylvania
ANGIE CRAIG, Minnesota
STEVE CHABOT, Ohio, Ranking Member
AUMUA AMATA COLEMAN RADEWAGEN, American Samoa, Vice Ranking Member
TROY BALDERSON, Ohio
KEVIN HERN, Oklahoma
JIM HAGEDORN, Minnesota
PETE STAUBER, Minnesota
TIM BURCHETT, Tennessee
ROSS SPANO, Florida
JOHN JOYCE, Pennsylvania
DAN BISHOP, North Carolina
MELISSA JUNG, Majority Staff Director
JUSTIN PELLETIER, Majority Deputy Staff Director and Chief Counsel
KEVIN FITZPATRICK, Staff Director
(II)
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CONTENTS
OPENING STATEMENTS
Page
Hon. Nydia Velázquez ............................................................................................. 1
Hon. Steve Chabot ................................................................................................... 2
WITNESS
Ms. Susan E. Streich, Director, Office of Credit Risk Management, United
States Small Business Administration, Washington, DC ................................. 3
APPENDIX
Prepared Statement:
Ms. Susan E. Streich, Director, Office of Credit Risk Management, United
States Small Business Administration, Washington, DC .......................... 17
Questions and Responses:
Questions from Hon. Nydia Velázquez, Hon. Steve Chabot, and Hon.
Ross Spano to Ms. Susan E. Streich and Responses from Ms. Susan
E. Streich ....................................................................................................... 22
Additional Material for the Record:
None.
(III)
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SBA MANAGEMENT REVIEW: OFFICE OF
CREDIT RISK MANAGEMENT
WEDNESDAY, FEBRUARY 5, 2020
HOUSE OF REPRESENTATIVES,
COMMITTEE ON SMALL BUSINESS,
Washington, DC.
The Committee met, pursuant to call, at 11:35 a.m., in Room
2360, Rayburn House Office Building. Hon. Nydia Velázquez
[chairwoman of the Committee] presiding.
Present: Representatives Velázquez, Finkenauer, Golden, Kim,
Evans, Schneider, Delgado, Craig, Chabot, Burchett, and Hern.
Chairwoman VELÁZQUEZ. Good morning.
The Committee will come to order. I thank everyone for joining
us this morning, and I want to especially thank the witness for
being here with us today.
This morning, the Committee will examine the management and
performance of SBA’s Office of Credit Risk Management, otherwise
known as OCRM. It is responsible for conducting oversight of
SBA’s lending programs and its $120 billion 7(a) and 504 loan port-
folios.
All of us are acutely aware that access to capital plays a vital
role in the success of our nation’s 30 million small businesses.
Without it, small businesses cannot stock their shelves, pay their
employees, or upgrade equipment. Capital is the key to unlocking
opportunities to grow and create new jobs in the local economy.
Yet, this Committee has heard from numerous small businesses
from across the country, and they consistently tell us that one of
the biggest challenges they face is accessing affordable capital.
The SBA 7(a) loan program plays an essential role in filling the
gap left by the private markets. In fiscal year 2019, almost 52,000
small businesses were approved for 7(a) loans, injecting over $23
billion in long-term capital into local communities across the coun-
try and supporting approximately 500,000 jobs. To optimize SBA’s
lending programs, SBA established the Office of Credit Risk Man-
agement within the Office of Capital Access. OCRM conducts re-
views of lenders to ensure that they are complying with the pro-
gram requirements.
While the office played an important role in lender oversight, un-
precedented growth in the program combined with deficiencies
identified by GAO in SBA’s credit risk management prompted con-
gressional action. To that end, Congress passed the 7(a) Lending
Oversight Reform Act, which codified OCRM and gave it the tools
needed to conduct proper oversight and hold non-compliant lenders
accountable.
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Today, I would like to learn more about how the SBA is imple-
menting the legislation. The regulation was expected to be finalized
months ago, so I am eager to hear when the final rule will be pub-
lished.
Secondly, I would like to find out what is currently working at
OCRM, and what more can be done to address the ongoing concern
the Inspector General has with high-dollar, early-default loans,
which present a significant credit risk to the 7(a) program.
Finally, I would like to know more about the steps you are tak-
ing to address the concerns of the Inspector General’s November re-
port. The report highlighted some areas where there is room for
improvement, and my motto always is, if it is not perfect, let’s
make it better.
So, on the heels of that IG report, and in anticipation of SBA’s
budget submission to Congress, this hearing is a timely one.
We look forward to hearing from the Director of the Office of
Credit Risk Management, Ms. Susan Streich, regarding the chal-
lenges she has faced since taking over at OCRM, as well as wheth-
er there are any additional tools Congress can provide OCRM as
it works to continue strengthening the 7(a) loan program.
Again, I want to thank the witness for being here today, and I
now yield to the Ranking Member, Mr. Chabot, for his opening
statement.
Mr. CHABOT. Thank you, Madam Chair. And thank you for
holding this hearing.
Financing for a small business, entrepreneur or startup is the
fuel that turns the Nation’s economic engine on and propels it for-
ward. It can be the key to transforming an idea into the next great
American product or service.
Unfortunately, as our economy moves forward, access to capital
remains one of the top challenges for the Nation’s job creators.
When financing options are limited, small business have the option
of turning to the SBA, the Small Business Administration, and its
numerous lending programs. These public-private partnerships
offer government guarantees based upon a multitude of factors. An-
nually, these programs provide capital assistance to small busi-
nesses all across the country, including in America’s greatest state,
Ohio.
However, with any Federal Government program, vigorous and
comprehensive oversight is mandatory to safeguard American tax-
payer dollars.
While this Committee conducts congressional oversight, the SBA
also dedicates an entire operating unit to this endeavor. The Office
of Credit Risk Management is charged with overseeing lending
partners and monitoring program risk. Last Congress, the Chair-
woman and I led efforts to codify this office and to ensure that it
remains a top priority moving forward.
That is why it is critically important that the office’s director is
testifying today. I am looking forward to a productive conversation
that examines each program’s performance and each program’s
risk. Additionally, I would like to hear how last Congress’s over-
sight bill has been implemented and whether it has provided the
tools necessary to access and to assess and guard against risk with-
in the 7(a) loan program.
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Each program is unique. Thus, each program requires its own
specific oversight plan. I am looking forward to examining each
program at this hearing. The timing of this hearing is fortuitous
because in the coming days we will receive the President’s budget
and each agency’s congressional budget justification which will in-
clude fiscal year 2021 requests. These important documents add
another layer to the monitoring of these programs.
I know this Committee would like to continue to work with the
SBA to ensure these programs run effectively and efficiently on be-
half of the small businesses that truly need the SBA’s services.
I want to thank the witness for joining us this morning. I wel-
come the conversation, and I yield back, Madam Chair.
Chairwoman VELÁZQUEZ. Thank you, Mr. Chabot. The gen-
tleman yields back.
If Committee members have an opening statement, we would ask
that they be submitted for the record.
I would like to explain the timing rules. The witness gets 5 min-
utes to testify and members get 5 minutes for questioning. There
is a lighting system to assist you. The green light comes on when
you begin, and the yellow light means there is 1 minute remaining.
The red light comes on when you are out of time, and we ask that
you stay within that timeframe to the best of your ability.
I would now like to introduce our only witness today.
Our witness is Susan Streich. Susan joined the SBA in 2016 as
Director of the Office of Financial Program Operations, part of the
Office of Capital Access. She became director of the Office of Credit
Risk Management in 2017. Prior to joining the SBA, Susan spent
her distinguished career engaged in SBA lending, working with a
diverse array of financial services organizations, including a 7(a)
bank, a CDC delivering the 504 program in Arizona, and a small
business lending company with a national footprint. More recently,
Susan served in senior consulting roles with Booz Allen Hamilton
and NFI Consulting, leading projects with USDA’s Office of Rural
Development and the U.S. Treasury’s CDFI Fund.
Ms. Streich, you are now recognized for 5 minutes. Thank you for
being here.
STATEMENT OF SUSAN E. STREICH, DIRECTOR, OFFICE OF
CREDIT RISK MANAGEMENT, UNITED STATES SMALL BUSI-
NESS ADMINISTRATION
Ms. STREICH. Thank you, Chairwoman Velázquez, Ranking
Member Chabot, and members of the Committee for inviting me to
speak today. It is my pleasure to appear before you as we start this
new calendar year.
As director of SBA’s Office of Credit Risk Management, or OCRM
for short, I am responsible for the oversight of lenders participating
in the Small Business Administration’s business loan programs.
I bring to this position over 37 years of lending experience and
a commitment to the small business community and the lending
partners that serve them.
In 2016, I was selected by SBA to serve as director of the Office
of Financial Program Operations in the Office of Capital Access.
While in that position, I successfully oversaw SBA’s loan origina-
tion servicing and liquidation operations. In 2017, I became the act-
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ing director of OCRM, and was made permanent director 3 months
later by then-administrator Linda McMahon.
OCRM is responsible for developing and implementing effective
risk management practices and overseeing SBA loan programs and
lender participants. The four main responsibilities of my office are
to provide lender oversight, monitor the entire 7(a) and 504 loan
portfolios for performance, administer enforcement and supervision
of SBA approved lenders, and when necessary, suspend or debar
program participants.
In 2018, Congress passed the Small Business 7(a) Lending Over-
sight Reform Act, which statutorily codified the existence and re-
sponsibilities of OCRM.
I want to thank Congress, and particularly the members of this
Committee, for their work on this very important legislation.
The 2018 legislation required SBA to promulgate regulations to
implement certain provisions of the law. The agency has pursued
this rulemaking in a diligent manner and published the proposed
Lender Oversight Rule in June 2019, 1 year following enactment
of the law. The final rule is expected to be published by the end
of the month.
Over the last 2 years, OCRM has also been seeking ways to bet-
ter fulfill its mission while adapting to the current lending environ-
ment. OCRM has accomplished this by improving its operations, as
well as by bringing on additional staff.
In 2019, OCRM implemented nationwide expansion of the Lend-
er Oversight Pilot Program so that one team is overseeing all feder-
ally regulated 7(a) lender participants. This national rollout cre-
ated a consistent review methodology across the Nation, improving
lender oversight and resulting in a more robust, effective and effi-
cient lender review process. This program enhancement was cou-
pled with a renewed focus on customer service with program par-
ticipants.
OCRM is increasing its number of personnel from 36 to 42 staff
members in order to better fulfill its mission. OCRM has built
strong and collaborative relationships with the Federal Deposit In-
surance Corporation and the Office of the Comptroller of the Cur-
rency as part of its lender oversight activities. These partnerships
with the primary Federal regulators for lenders have enabled
OCRM to fulfill its mission and enhance its effectiveness in pro-
viding lender oversight of SBA program participants.
I want to briefly touch upon the report that SBA’s Inspector Gen-
eral released in 2019 regarding the oversight of high-risk lenders.
The report covers lender oversight practices from 2015 to 2017,
which was before I took my role as director of OCRM. The report
offers six recommendations to improve oversight activities. We are
in the process of addressing those recommendations and will con-
tinue to address the concerns raised in the report.
Finally, I want the Committee to know that OCRM is pursuing
several significant goals during the current fiscal year to improve
its ability to proactively monitor portfolio performance and identify
and mitigate lender risk. These include adding microloan inter-
mediary oversight capabilities by the end of this fiscal year; pub-
lishing the final lender oversight rule by the end of next month; re-
vising our two OCRM SOPs, SOP 5053, which is the Supervision
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and Enforcement SOP and SOP 5100, which is our examination
manual; and continuing to enhance our partnerships with the
FDIC and OCC.
Thank you, Chairwoman Velázquez and Ranking Member
Chabot, for inviting me to testify here today. I look forward to an-
swering your questions and continuing our work together with you
to ensure proper oversight of SBA loan programs.
Chairwoman VELÁZQUEZ. Thank you, Ms. Streich.
I will begin by recognizing myself for 5 minutes.
Last June, the SBA published a proposed rule to implement the
7(a) Lending Oversight Reform Act. The agency received 35 com-
ments from the public in response to the proposal. Can you de-
scribe the nature of the comments OCRM received in response?
Ms. STREICH. Thank you. Okay, sorry.
I do not have that information, that level of granularity with me
today. I would be happy to get that for you if you would like.
Chairwoman VELÁZQUEZ. Sure, thank you.
I am happy to hear that the rule will be published at the end
of this month. Will the rule be significantly different from the pro-
posed rule, the final rule?
Ms. STREICH. No. Not in my estimation. Not significantly dif-
ferent.
Chairwoman VELÁZQUEZ. Okay. The IG has an ongoing high-
risk 7(a) loan review program to see if high dollar 7(a) loans that
defaulted early were originated, closed, and complying with SBA’s
rule. The IG has identified numerous such loans that have created
a considerable credit risk to the agency. What specific action items
are you taking to make sure noncompliant lenders are held ac-
countable?
Ms. STREICH. So Chairwoman Velázquez, the primary responsi-
bility for that activity actually resides with my former team, the
Office of Financial Program Operations, and they work closely with
the OIG on those issues throughout the year and try to resolve
them as quickly as they can.
Now, how it impacts OCRM, as we are involved in lender over-
sight and reviews for those lenders that have actually originated
those loans, we are looking and collaborating with our team mem-
bers over an OFPO to see how we can actually build upon what
they are learning and make sure that we are collaborating and
learning from one another how we can help coach that lender into
doing the right thing from a compliance standpoint going forward.
Chairwoman VELÁZQUEZ. The Oversight Act gave you addi-
tional tools to deal with program violations. How, and how often
have you used them?
Ms. STREICH. We have approximately, in a variety of ways,
ma’am, we have approximately 40 lenders on the watch list, which
means that they are under increased supervision. That list changes
almost monthly depending upon——
Chairwoman VELÁZQUEZ. What type of supervision? Are you
coaching them? Informal mechanism or——
Ms. STREICH. It involves everything from voluntary agreements
with them to stand down on use of delegated authority or PLP au-
thority, to standing by on sale of any loans in the secondary mar-
ket without our view and permission of each and every loan trans-
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action. So, it can be a pretty significant impact on those lenders.
Many of those lenders are under orders from their primary federal
regulators.
And then we have additional informal and formal actions under
way right now. I cannot be specific as to what they are as you
might know because they are confidential. And we have additional
supervision actions that we take, including when we are conducting
a review of a lender and we have concerns about the performance
that is exhibited both operationally for them and in deficiencies in
the loan review process. We will call them in to headquarters and
have a conversation with them and give them some kind of an ac-
tion plan to work with us on.
Chairwoman VELÁZQUEZ. How many lenders are you dealing
with in this category?
Ms. STREICH. Probably close to 125 at this point in time.
Chairwoman VELÁZQUEZ. Ms. Streich, as you may know, ear-
lier this summer an SBA loan broker pleaded guilty to SBA loan
fraud amounting to more than $100 million and was sentenced to
prison for 9 years. Back in 2013, a codefendant was sentenced to
15 years and ordered to pay restitution of $91 million. Clearly,
keeping track of loan brokers and agents like this is a challenge
for the SBA. How effective is the current mechanism for tracking
loan brokers and agents? Please comment on its effectiveness.
Ms. STREICH. Thank you, ma’am.
Two things to think about here. One is that I am the suspension
and debarment agent’s agent for the SBA for all financial pro-
grams. I have the ability with OIG and OGC participation to take
suspension and debarment actions against individuals that have
received convictions or even indictments that we are concerned that
should get out of the lending industry entirely. And we do take
those actions regularly.
Chairwoman VELÁZQUEZ. Have you taken such actions?
Ms. STREICH. Yes. Yes.
The risk that loan agents pose to the agency is something that
we are constantly monitoring. About 11 percent of the portfolio in
7(a) has been generated through loan agent activity. We work
closely as the FDIC and the OCC guidance has been provided to
their lenders. We work closely with the lenders involved that have
those contractual relationships with loan agents, and we work with
them to see how they are managing the third parties that they re-
tain, including loan agents. When we have an upcoming review of
a lender, we ask them if they have third parties involved in their
SBA loan operation at any stage. If we do find out that they do
have third parties, we get copies of the loan agreements that they
have, the contracts that they have with those agents. We review
those as part of our overall review, and then for each one we ask
them to complete a nine-page questionnaire to give us much more
detail about what is going on with that lender relationship and
what services they provide. That gives us a great deal of informa-
tion. That just began about the last 6 months so we do not have
lots of comprehensive data yet, but we are gathering it in hopes
that it will give us insight into how we can manage that and mon-
itor that more closely.
Chairwoman VELÁZQUEZ. So last point.
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Ms. STREICH. Yes.
Chairwoman VELÁZQUEZ. Do you have enough staff to keep
track of loan brokers?
Ms. STREICH. Ma’am, I think it depends on what you mean by
‘‘keep track.’’ In terms of monitoring the risk on the portfolio and
the performance for lenders, yes, at this point we do.
Chairwoman VELÁZQUEZ. Okay.
Now, we recognize the Ranking Member.
Mr. CHABOT. Thank you, Madam Chair.
Thank you for being here today, Ms. Streich.
As you know, Congress passed, and President Trump signed into
law the Small Business 7(a) Lending Oversight Reform Act in the
last Congress. While there are many provisions in the law that
strengthen the SBA’s ability to oversee risk, I want to touch on just
one that is essential for the program to serve small businesses that
truly need the SBA’s resources.
Could you walk the Committee through the credit elsewhere test
and how your office monitors that?
Ms. STREICH. So the legislation that you passed last year and
I would expect we will see something like this in the rule, and we
have SOPs that designate what the credit elsewhere rule means
and how lenders comply with it. And it is very specific in the SOP
50 10(5)(K). And we apply and interpret that in our reviews of
lender files so that we can determine whether or not they are actu-
ally maintaining compliance with credit elsewhere.
The challenge with credit elsewhere, frankly, has been that we
do not have an easy, automated, electronic solution at this point in
time to check the box and determine how many of each reason for
credit elsewhere not being available the lender may have actually
checked. So, it is a bit of a manual exercise for us right now in the
loan review process.
Just to give you an idea of the volume of loan files that are re-
viewed, the federally regulated team reviewed 2,000 loan files last
fiscal year, and that did include the SBA supervised loan files that
were reviewed, each and every one. We are manually keeping that
information on spreadsheets at the moment in hopes that eventu-
ally we will be able to actually have a database that we can include
that information on and make it easier to query and gather that
information and share it with you more specifically.
Mr. CHABOT. Thank you.
How often does it occur that lenders violate the credit elsewhere
test?
Ms. STREICH. It is interesting that you would ask that. We had
a meeting about this just the other day, wrapping up 2019 reviews,
some of which the reports, or some of them are still getting com-
pleted and getting out. And we only have one lender in all of 2019
that really, in your opinion, was egregious with regard to not docu-
menting credit elsewhere to our satisfaction, and we have talked to
that lender.
Mr. CHABOT. That is good to hear. Thank you.
Congress was notified this time last year that the 7(a) loan pro-
gram required a $99 million subsidy to continue operating in fiscal
year 2020. In the coming days we are set to receive the fiscal year
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2021 number. Will the 7(a) loan program and/or the 504 CDC loan
program require a subsidy moving forward?
Ms. STREICH. I am sorry; I will not be able to answer that ques-
tion. The Office of Capital Access and OCRM are not involved in
determining what the subsidy model components are and how it is
going to be developed. That really resides with our OCFO office.
Mr. CHABOT. Expecting, anticipating that answer, let me ask
the question in another way.
How have the 7(a) loan program and the 504 loan program per-
formed this year compared to last year?
Ms. STREICH. So I would say that overall the entire portfolio is
performing well, both in 7(a) and 504. 504 defaults are at a re-
markable low level, remarkably low level. 7(a), we have seen early
defaults in 7(a) creeping up slightly year over year, but not chang-
ing dramatically and are not presently a cause for concern.
Mr. CHABOT. Okay. Thank you.
As you stated in your testimony, the SBA lending programs are
reserved for ‘‘creditworthy small businesses that otherwise would
not be able to access capital to start or expand their business.’’
We want to continue to work with your office to ensure the ap-
propriate small businesses have access to these programs. What, if
any, additional tools do you think that you might need at your dis-
posal to meet this mission? Anything come to mind?
Ms. STREICH. Thank you very much for asking.
I think at this point we are still trying to digest all the changes
that have come about because of the act that you all were so won-
derful to provide for us and the additional authority provided to us.
We are actually also making changes organizationally and func-
tionally to make sure that we can do everything from a regulatory
standpoint that we are changed with and do it well. Obviously, in-
terest and sustaining a program integrity for the long term and
serving the needs of the small businesses who really need access
to capital. So, I think we need a little more time to digest every-
thing before I can recommend anything new that we might need
in terms of authority.
Mr. CHABOT. Thank you very much.
Since I am in single digits as how much time I have left, I am
going to yield back rather than go over here. Thank you. I yield
back.
Chairwoman VELÁZQUEZ. Thank you. The gentleman yields
back.
Now we recognize the gentleman from Pennsylvania, Mr. Evans,
for 5 minutes.
Mr. EVANS. Thank you, Madam Chairperson.
For the 7(a) loan program, SBA is not the direct lender. Instead,
it relies on private sector lenders, and these private sector lenders
are mostly banks. But it also includes small business lending com-
panies. FinTech lending has become increasingly popular for small
businesses looking for loans. Are there any plans for the SBA to
engage with FinTech lenders, and do you think it should?
Ms. STREICH. Thank you for the question. I appreciate it very
much.
We have talked to a number of FinTech lenders through the
course of the last couple of years. There is not an easy relationship
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between what they do and what we do at this point in time, but
we are learning from one another. And the result of just that con-
cept of quick decisioning and Internet-based applications has
helped foster the lender Match program at SBA. You may have
heard about that. It is an online application that is actually free
to the borrower or the proposed borrower and enables a number of
lenders participating in the 7(a) program to review applications
that come in right to the SBA website. It is a very successful pro-
gram. It is actually going forward and being improved now. And by
the end of, I believe, March, we are going to have a Spanish
version of Lender Match.
Mr. EVANS. So you are going to engage with FinTechs?
Ms. STREICH. It is a very similar approach to the FinTech solu-
tion because it is an Internet-based application. Yes, that is simi-
lar. We not really working one of the FinTechs to do this, however.
Did I answer your question, sir?
Mr. EVANS. Yes, you did.
Ms. STREICH. Okay.
Mr. EVANS. In your written statement you said that your office
participates in informal and formal enforcement actions, including
volunteer agreements and suspensions from participation in SBA
programs. How many enforcement actions did your office initiate in
2019? And what were the nature of these actions?
Ms. STREICH. In 2019, we had informal and formal enforcement
actions. I think it was five. We have since then taken additional
actions in fiscal 2020 and we are continuing to be rigorous in our
approach to suspension and enforcement activities. The informal
activities generally involve calling a lender into a headquarters
meeting, which is actually a very serious occasion wehore we sit
down with them and we ask them if they understand why they are
not compliant with our requirements and what we can do to get
them on track. We want them on a compliant path, obviously, to
go forward.
And then secondly, we have voluntary agreements. So if it is a
PLP lender, a preferred lender that has delegated authority, we
will ask them to please stand by in delegated authority and submit
all of their loan applications to the center in Citrus Heights for
their review, underwriting, and approval. So, we can track through
the center how they are performing in terms of application activity.
Are their applications complete? Do they really catch everything
from a credit administration standpoint in the credit memo? Do
they follow up and abide by the credit elsewhere criteria? All of
that can be checked by the center and they feed that information
back to us. When we think that they have solved their problems
and they are performing well, then we are willing to let them use
delegated authority again, but not until then.
Mr. EVANS. This is somewhat of a piggyback on the Chair-
woman’s question earlier about resources. The 7(a) loan program
has made rapid growth in recent years, and in fiscal 2012, the pro-
gram approved $15.2 billion in loans. By fiscal 2017, that number
increased to $24.5 billion.
Ms. Streich, how has your office adapted to this rapid growth?
And does it need additional resources to provide effective oversight
of credit risk?
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I think what I heard you when you were responding to the
Chairwoman, you said, kind of gave an answer that was not that
clear to me.
Ms. STREICH. Okay. Happy to have to provide additional infor-
mation.
We have a great data warehouse called the Loaner Lender Moni-
toring System, LLMS for short. It is managed for us by Dun &
Bradstreet. And that system provides great data analytics for us to
measure performance by loan, by loan segment, by industry, by in-
dustry type, by geography and a variety of other segmentations
that we can perform of the portfolio to identify where risk is in the
portfolio, where emerging risk may be, and then what we need to
do to mitigate it. So that information is readily available from
LLMS. And we use that information weekly, monthly, quarterly,
semi-annually, and annually in intense deep drives into certain as-
pects, segments of the portfolio give us great data to use to deter-
mine what kind of course of action we as a risk identifying and
mitigating group have to proceed to make sure that we have man-
aged risk in the portfolio for 7(a).
Did I do a better job of answering that question?
Mr. EVANS. I yield. Yes.
Chairwoman VELÁZQUEZ. The time has expired.
Mr. EVANS. I yield. Yes. Thank you.
Chairwoman VELÁZQUEZ. Now, we recognize the Ranking
Member of the Subcommittee on Economic Growth, Tax, and Cap-
ital Access, the gentleman from Oklahoma, Mr. Hern.
Mr. HERN. Thank you, Madam Chairwoman, Ranking Member
Chabot.
Director Streich, thanks for being here.
As the Ranking Member of the Small Business Committee, Sub-
committee on Economic Growth, Tax, and Capital Access, I under-
stand the need for small businesses and entrepreneurs to obtain
access to capital. Additionally as a founder of a small community
bank, I also understand that heavily financial risk involved with
lending and loan programs such as this, sort of a loan of last re-
sort, if you will, I have experience with both the banking and the
business side. I find that it is essential that we have the necessary
checks and balances in place to ensure that the SBA’s loan pro-
grams are being properly executed and that the government is not
being taken advantage of due to lack of oversight. So, thank you.
As you know, the 7(a) loan program gives small businesses the
opportunity to gain access to capital who often do not have the ca-
pacity to gain funding on their own. This successful program has
provided nearly 52,000 loans for small businesses and entre-
preneurs across the country, and the program operates by taking
fees which allow the SBA to run the loan program efficiently while
also protecting our taxpayers.
These built-in fees meant to cover all program costs have been
sufficient until recently as the 7(a) program claimed the need for
a $99 million subsidy in fiscal year 2020.
As someone who has successfully managed budgets his whole life
this was very concerning. It was concerning for every member on
the panel, the Chairwoman, both sides of the aisle here. To go from
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self-sufficiency to reliance on a $99 billion subsidy leaves me with
numerous questions including the following.
And I appreciate it. I have been listening to you for short min-
utes here and you have got answers. When your former CFO was
here, he seemed not to have any answers to the tough questions,
so thank you for coming prepared to answer questions today.
Director Streich, what performance characteristics contributed to
the 7(a) loan program needing subsidy? Was it performance de-
cline? What are you seeing today? You have described some of
those as I was walking in here. Could you talk to us about what
are you needing?
Ms. STREICH. So, Congressman, I do not have specific informa-
tion into the components, into the subsidy model that was created
by our OCFO office in conjunction with OMB. That information is
closely held, and they segregate that away from those of us that
actually are involved in the capital access for purposes of, you
know, making sure that——
Mr. HERN. But you are in credit risk——
Ms. STREICH. Right.
Mr. HERN. And I do not want this to be confrontational, but you
are in credit risk. So, you look at a lot of actuarial data, historical
data. We do not ever throw that away. You described a growing
economy. You described a default rate that you are collecting your
monies. And so, it is hard for us I think, I do not think most mem-
bers’ thoughts have changed on this because we have not had any-
thing to change it. The economy has even gotten better. We have
not heard a lot, or anything about business failure. So, what, in
your assessment of credit risk, there has to be some thoughts about
what would go on to drive this need for extra money to some myth-
ical credit risk.
Ms. STREICH. So let me go back to my banking and lending
days and running a SBA loan production center, and talk to you
about just the countercyclical nature of SBA loans because I think
that will be helpful.
During the Great Recession, SBA lending really took off and we
put in the portfolio a lot of really high creditworthy borrowers be-
cause the banks and others, as you might recall, stopped doing
lending almost entirely. So, the only way some of these borrowers
could get money was through the SBA loan program.
As a result, with the economy being strong, those loans per-
formed really well. Now, those loans are refinancing and going con-
ventional because the conventional credit box during a strong econ-
omy has actually been opened up as a lender. If you have a con-
servative credit box during tough times, you have a more open
credit box as you probably did at your community bank during good
times. And as a result, more loans are going through that process
conventionally, which is really the purpose of the program. And
then we are getting loans that may be a little higher risk and fall-
ing outside of the conventional, the new conventional credit param-
eters.
Mr. HERN. If I may stop you because I have got one other ques-
tion, but I like the word you just put in there, may be. They have
not proven to be, and so they are not based on really historical
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facts. They are based on presumption. And so, we have not seen
that yet.
Let me ask you this last question before we lose our time here.
As a result of the 7(a) loan program having a subsidy, what has
your office done to ensure taxpayer dollars are being protected
moving forward?
Ms. STREICH. So we identify through each of our lender reviews
targeted and full reviews, we pull credit files, loan files from the
lenders and we review each and every page of each and every file,
usually thousands of pages, to make sure that they are being com-
pliant with SBA’s requirements. If we identify deficiencies during
those loan file reviews, we communicate that information back to
the centers that are involved in the operations side, the origination
and the Guaranty Purchase Center. Through the cron, which is an
electronic communication tool, we tell them where to focus their at-
tention. If that loan goes into default and ends up with a purchase
request to honor the guaranty, the NGPC, which is the National
Guaranty Purchase Center in Herndon, then that financial analyst
that pulls that information up on the cron can go right to that part
of the file, identify whether there is a deficiency that is material,
and if so, can either repair or deny the guaranty. That enables us
to make sure that we are not providing taxpayer dollars unneces-
sarily and inappropriately to a lender who has done the wrong
thing.
Mr. HERN. Thank you.
Madam Chairwoman, if I may, I would like to recognize the fact
that the SBA sent somebody that actually has answers to some of
our questions. I really appreciate that. This is a refreshing follow
up to the former member that was here. Thank you.
Chairwoman VELÁZQUEZ. Thank you.
Time has expired. Now we recognize——
Mr. CHABOT. We do not complement witness around here that
much, so that is pretty good.
Mr. HERN. That is a rarity. Thank you.
Chairwoman VELÁZQUEZ. The gentleman from Illinois, Mr.
Schneider, for 5 minutes.
Mr. SCHNEIDER. Thank you, Madam Chairwoman. Thank you
for having this hearing.
Ms. Streich, thank you for being here. I will echo the comments
of my colleague, Mr. Hern. I think that is important.
He was touching on some important issues. As you related, the
countercyclicality of the portfolio within the SBA. And as the econ-
omy is growing, access to capital is still critically important, espe-
cially for small businesses who enter conventional lending markets
to tell their story. Often, they may not have the track record of a
larger business or a more tenured business. It is a startup. And so,
these opportunities are vitally important to continue to grow our
economy.
At the same time, while I think it is important that SBA lending
be easily accessed, efficient, effective, we need to monitor and man-
age the credit. As you were implementing the recommendations of
the OIG report as you look to the future what are some of the key
things that we need to do to make sure that we are protecting
against in appropriate risk, identifying and addressing when lend-
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ers are behavior inappropriately, but making sure that we main-
tain that access for small businesses to get the capital they need
to grow their businesses.
Ms. STREICH. That is a great question. One of the challenges
that we are working with across all of our capital access team, es-
pecially our Office of Financial Assistance and our Office of Finan-
cial Program Operations is what kind of additional training we can
provide to lenders on a regular basis through our district offices,
through the Office of Field Operations, as well as directly. We did
16 conferences last year alone, both at district level, regional, and
trade associations. We do webinars regularly. The whole goal is to
make sure that lenders do not do the wrong thing. Do not make
a misstep. There is nothing worse if you are a small business per-
son relying upon your bank to be judicious in the amount of credit
they are willing to give you than to have them give you too much,
you cannot afford to repay it, and all of a sudden then you are in
trouble.
Mr. SCHNEIDER. Right.
Ms. STREICH. Right? So, we used to say, very similari to the
medical community, at first, do no harm. Right? And so, one of the
things that we have seen in our reviews of certain loan files for cer-
tain lenders this last year, is that, in fact what is happening in
part is smaller transactions are being overfunded. And as a result,
the borrowers are not able to repay that entire amount. They prob-
ably could have gotten away with significantly less money and it
would have been much more affordable for them. So it is our job,
in part, to make sure that we are working with the trade associa-
tions and the districts and all other opportunities to provide that
kind of insight and feedback to the lenders to get them to make
sure that they are actually making good, judicious credit decisions.
Mr. SCHNEIDER. I think that is important. Oftentimes here we
are talking about unconventional ideas, unconventional risk. That
does not mean they are inappropriate, that does not mean they are
outside the range of what is an acceptable risk. But if you take
them too far, I like to say, I grew up near the mountains and I am
very comfortable driving on mountain roads. I tend to keep both
wheels on the road and in the center. I try not to go too far to the
edge, and that is what I want these small businesses to be able to
do, is to take the risk, to make the ascent, but to do it in a way
that is supported by the lender. So, I think it is important to com-
municate that.
Taking that a step further, how do we make sure that—and this
may be outside your role—that the lenders are getting out to the
marketplace so that small businesses understand what is available
to them. That there is an opportunity to get capital, to fund their
ideas and invest in their business, but to do it in a way that is pru-
dent and appropriate for them.
Ms. STREICH. That is an interesting question.
When I started in this business, in 1981, as a 503 lender, nobody
knew what SBA was, but they were horrified that they might, as
a small business borrower, need to access any capital through the
SBA. It was a terrible reputation. So, we had to try to figure out
how to sell everything by developing some kind if credibility with
the small business borrower first.
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That is not true today. Today, wherever I go, I like to talk to en-
trepreneurs—restuarants, my physical therapy office—I like to ask
them, you know, how did you get to this point? And I love hearing
them say, well, I got an SBA loan. And then I always ask them
from whom? Because I just like to know who is active in each mar-
ketplace. And I just think it just speaks to the fact that many lend-
ers really like this program. And they really are out there offering
it to the marketplace in a very active way. That is wonderful. They
are an adjunct to our educational opportunity for the marketplace.
Mr. SCHNEIDER. And just to close, I am a little bit past my
time, but the role that we can play as members of Congress engag-
ing in our community, we have seminars, roundtables. We bring
entrepreneurs together to say, hey, we can make a difference, and
I look forward to continuing that.
I yield back.
Chairwoman VELÁZQUEZ. The gentleman yields back.
Now we recognize the gentleman from Tennessee, Mr. Burchett,
for 5 minutes.
Mr. BURCHETT. Thank you, Chairlady, Ranking Member. It is
always a pleasure being here, ma’am. And thank you, ma’am, for
being here with us.
Let me make sure I have got the name right. Streich. Is that how
you say it?
Ms. STREICH. Just like strike three and you are out. Yes.
Mr. BURCHETT. All right. Well, Burchett. Just like the tree,
birch like the tree, and ett like I just ‘‘ett’’ lunch. Which I did not,
but the Chairlady always promises me she is going to bring me a
meal, but she never does, so anyway. That is just what happens
here in Congress, I guess.
Does the Office of Credit Risk Management need any additional
oversight tools to further protect our taxpayer dollars within the
microloan program? And if so, what would you request?
Ms. STREICH. That is a great question. I cannot answer it
today. We have as our goal to take on microlender oversight in
2020 but we are just starting to recruit for that position, and we
will be taking over the oversight that the program office has been
engaged in heretofore. So, in another 3 to 6 months I will be able
to probably answer that question much better than I can today.
Mr. BURCHETT. Okay. That was an honest answer. So, thank
you.
Let me ask you one more. What is the current oversight plan
that the Office of Credit Risk Management has in place to oversee
the microloan program?
Ms. STREICH. So microlenders, as you know, are intermediaries
for us. We provide a loan to them and they actually provide the
loans to microlending opportunities, and they are usually within
their community. And they do that very well. Their performance
overall has been very stellar in terms of their portfolio. And what
we want to be able to do is examine what they are doing, make
sure it is compliant with any requirements that the SBA has for
their performance, and make sure that they are servicing those
loans very, very well and diligently. And if we request information
or access to their files that they will allow us to have a chance to
look at them. Very basic.
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Mr. BURCHETT. Thank you, ma’am.
Chairlady, Ranking Member, I yield back the remaining 2 min-
utes and 59 seconds of my time. Please use it wisely as I know you
will.
Chairwoman VELÁZQUEZ. The gentleman yields back.
Now we recognize the gentleman from Maine, Mr. Golden, for 5
minutes.
Mr. GOLDEN. Thank you, Madam Chair.
Director Streich, thank you for being with us today.
I want to follow up on an earlier conversation you were having.
Does SBA assign loan brokers and agents with unique identifiers
to systematically track their activity?
Ms. STREICH. Not at this time. No, sir.
Mr. GOLDEN. And would there be any benefit to your office in
carrying out your role if you were to do that?
Ms. STREICH. I do not believe so at this time. We have a variety
of tools available to us to track loan agent performance by lender
that they have relationships with. One way is through the review
process, and we ask the lender to provide a great deal of informa-
tion, including the agreements that they have with those loan
agents. We review those and see what kind of relationship there is
and what kind of services are provided and what kind of fees are
being charged and to whom. We also have the Form 159, which is
a form that really gives us a great deal of information for any fees
that are charged during the course of a loan origination, whether
it is by the lender or by a loan agent. And we use that information
and are just starting to aggregate that so we can determine and
monitor loan agent risk and performance of each individual loan
that they have referred into a specific lender. If we see that there
is a trend that a lender specifically with a relationship with a loan
agent is experiencing challenges with their portfolio performance,
then we are talking to them about why they are continuing to ac-
cept referrals from that loan agent if, in fact, their performance is
less than adequate.
Mr. GOLDEN. You have a good level of confidence that you are
pulling in the information that you need to have visibility and that
it is compiled in a way that is easy for you and your staff to put
it to good use?
Ms. STREICH. Well, we are certainly getting the information.
We are still working on the best way to compile it and access it
so that it is easier to automate and electronically available to us.
Mr. GOLDEN. Thank you very much.
Chairwoman VELÁZQUEZ. Well, Ms. Streich, thank you very
much. It is like a breath of fresh air to bring someone from the Ad-
ministration, at SBA, that really provides the facts and is able to
provide the answers to our questions. I really feel confident that
you are doing a very good job. Thank you.
We have now learned more about a key function of the SBA’s
capital access programs and one without which the programs could
function effectively. However, we have also learned that there is
more work to be done towards ensuring proper oversight and ac-
countability over SBA’s partner lenders. If we intend to continue
enhancing access to affordable capital for small businesses, it is
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clear SBA’s Office of Credit Risk Management will be a key stake-
holder.
I look forward to working with my colleagues from across the
aisle as we continue to work to enhance the efficiency of SBA’s op-
erations and more broadly, to continue enhancing access to capital
for America’s small businesses.
I would ask unanimous consent that members have 5 legislative
days to submit statements and supporting materials for the record.
Without objection, so ordered.
If there is no further business to come before the Committee, we
are adjourned. Thank you.
[Whereupon, at 12:25 p.m., the Committee was adjourned.]
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APPENDIX
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Æ
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