SBA Rapid Decision reference guide, Apr. 20, 2021
Summary
A Rapid Reference Guide, updated 04/20/2021, listing "INFO" messages and fraud alerts that may appear when files are processed in the RER system, with the action to take on each. It says "INFO" messages require further review by a loan officer and that, for the EIDL Advance message, no action is necessary because EIDL Advances are no longer available. A section titled Rapid Fraud ALERTS, which says not to discuss specific details with applicants, names alerts such as high risk IP address, suspicious online behavior and client location is international, and directs the loan officer to telephone the applicant, ask verification questions and, in several cases, decline the loan if identity documents are not received within 7 days. It closes with other fraud indicators to monitor, including a VOIP phone number and an email that has not passed validation.
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“SBA Rapid Decision reference guide, Apr. 20, 2021.”
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Rapid Reference Guide
Below are the various “INFO” messages that may be seen when processing files in the RER
system. “INFO” messages are generated based on established business rules and require
further review by a loan officer. These items must be addressed and mitigated
appropriately. Below are the actions to be taken in response to each of the “INFO” messages
that may appear on deals in process.
Before decisioning any deals, review the Notes for information pertaining to the file.
INFO: Advance amount sent to client
INFO: If loan is funded, applicant will receive advance of $XXXX
EIDL Advance amount ranging from $1,000 - $10,000, based on $1,000 per employee.
Action To Take:
No action necessary. EIDL Advances are no longer available, as all appropriations
for this program have been allocated.
INFO: Applicant indicated they are a Franchise:
Results when the Applicant indicates the business is a Franchise.
Action To Take:
• Check SBA’s franchise directory, in addition to the supplemental SBA Franchise Team
ODA-Only Brands list located on the DIG to determine if the applicant’s brand is listed.
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Updated 04/20/2021
Rapid Fraud ALERTS
These are meant for internal use only. Do not discuss specific details with applicants.
Loan Officer Action:
1. High risk IP address – The computer or mobile device may have been reported to be
used in fraudulent activity by other institutions, not an automatic decline. Must
telephone contact applicant to confirm PII information. Inquire about the alert to
update Notes. If everything is correct = Approve the loan. If unable to contact or
phone has been disconnected = Decline the loan (If fraud or identity theft is
suspected/reported, notify PDC’s Fraud Review Team at
@sba.gov or @sba.gov)
2. Suspicious online behavior – The portal may have been accessed from multiple
devices, the applicant may have used a phone or tablet or the data altogether has
possibly been used fraudulently online. Owner associated with fraud online or we
detected attempts to bypass our fraud checks and security measures. Telephone the
applicant to ask some verification PII questions and discuss how they have accessed
the portal, document in NOTES. Verbal request or send an email to obtain a copy of
their valid identification. If not received within 7 days = Decline the loan
(If fraud or identity theft is suspected/reported, notify PDC’s Fraud Review Team at
@sba.gov or @sba.gov)
3. Fraud found on related deal(s) – Must review each Related Deal that is identified as
potential fraud to determine what is the potential fraud and how it relates to the
applicant directly or indirectly. Document these findings in Notes.
4. Large number of applications with other providers – Owner information used in a
high volume of applications with multiple institutions within a short period of time.
Often indicates stolen PII. Telephone the applicant to determine if he has applied
with other sources. Confirm the source and if funds were received as this could be a
duplication of benefit. Add your comments to the notes = Approve the loan
5. Large number of applications for this program – Often indicates attempt to get
multiple funding (several in succession) or use of different false information. Could
also be an owner with multiple businesses. Review each application to determine if
they are duplicates. Mark accordingly. (If fraud or identity theft is
suspected/reported, notify PDC’s IG Liaisons at
@sba.gov or @sba.gov)
6. Client information failed validation – Owner information could not be validated by
data provider. Indicates red flags or discrepancies (information doesn’t go together,
person may have been listed as deceased, etc.). Telephone the owner/principal who
failed the validation. Ask verification PII questions to confirm their identity. Send an
email to obtain a copy of a valid government issued photo ID to further verify
identity. If not received within 7 days or if unable to confirm identity = Decline the
loan
7. Failed online identity verification – Telephone the owner/principal who failed the
online identity verification. Ask verification PII questions to confirm their identity.
May need to send an email to obtain a copy of a valid government issued photo ID to
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Updated 04/20/2021
further verify identity. If not received within 7 days or if unable to confirm identity
= Decline the loan
8. Client location is international – Applicant accessing software from a non-U.S.
location. Accessed application from another country. Generally higher fraud rates
from international traffic. Determine if the applicant business has a physical
presence in a declared county. If not, Decline for no physical presence.
9. Client device(s) associated with fraud – Applicant possibly is accessing their Rapid
loan through an unsecured WIFI at any public establishment. Telephone the
applicant to inquire as to how they are accessing their loan, update Notes. Make sure
to confirm PII that applicant matches application. May need to send an email to
obtain a copy of their government issued identification. No other Alerts or Info
messages move forward with approval.
OTHER FRAUD INDICATORS TO MONITOR
VOIP phone number or phone number not associated with business or owner – Often used
by nefarious organizations to mask their true phone number and locations. Name associated
with the telephone number does not match the applicant or business entity. Also used by
legitimate businesses. Look at the totality of the potential issues with inconsistent
information associated with Fraud.
Telephone the applicant, confirm phone number – Approve
Email has not passed validation – Incorrect or fake email may suggest business may not be
legitimate. Telephone contact with applicant to obtain correct valid email address. Email
address must be correct and accurate to insure loan documents are emailed out through
DocuSign correctly.
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Updated 04/20/2021
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