Pandemic Darlings The pandemic economy, in original documents
Home Source documents SOP 50 46 3: Claims and Recovery Program

SOP 50 46 3: Claims and Recovery Program

Summary

SBA Standard Operating Procedure 50 46 3, Claims and Recovery Program, effective May 4, 2022 and authorized by Jennifer Vigil, Acting Director, Office of Surety Guarantees, sets the rules for surety bond guarantee claims and recoveries. Under the Small Business Investment Act of 1958, SBA reimburses a Surety for part of its losses on a bonded contract, up to a statutory limit of $6.5 million, or $10 million if a federal contracting officer certifies the need. A Principal is ineligible for further SBA bond guarantees once it is declared in default, sued under the bond or has an unreimbursed Loss. Sureties must report a default on SBA Form 994H within 30 days and file status reports every 6 months, and each bond carries a claim status from 1 (Active) to 5 (Settlement). Chapter 5 lists grounds for OIG referral, including false social security numbers, altered tax returns and bribes.

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

Full text

                                                 50 46 3




SBA                          SOP 50 46 3




Claims and Recovery
Program

                                     Office of Surety Guarantees

                                         Office of Capital Access

                              U.S. Small Business Administration




Effective Date: 05/04/2022                              1
                                                                               50 46 3




                                Small Business Administration


                                Standard Operating Procedure


                                            National


Subject: Claims and Recovery Program


S.O.P. Number: 50 46 3


Revision Number: Not Applicable


Purpose: To establish written guidelines and procedures for surety bond guarantee claims

reimbursement and recovery activity.


Personnel Concerned: All SBA employees and Surety Partners


SOP Canceled: Not Applicable


Originator: Office of Surety Guarantees


Authorized By: Jennifer Vigil, Acting Director, Office of Surety Guarantees


Effective Date: May 4, 2022




Effective Date: 05/04/2022                                                           2
                                                                                                                             50 46 3




Table of Contents
Chapter 1. General Overview of the Surety Bond Guarantee (SBG) Program ................................... 4
      1. The General Scope and Purpose of this SOP ....................................................................... 4
      2. The Program's Statutory Basis ............................................................................................. 4
      3. Program Objectives ............................................................................................................... 5
      4. General Description of Roles and Responsibilities .............................................................. 5
Chapter 2. General Requirements for the Prior Approval Program and Claims Procedures ........... 7
      1. Loss of Eligibility for Further SBA Bond Guarantees............................................................ 7
      2. Surety Notification of a Claim Situation ............................................................................... 8
      3. Review of Contractor File ...................................................................................................... 9
      4. Surety Status Reports on Claim and Recovery Activity ....................................................... 9
      5. Claim Status Code ............................................................................................................... 10
      6. Procedures for Placing a File in “Closed-Final” Status ...................................................... 11
      7. Analysis of the Contractor File ............................................................................................ 11
      8. Surety Request for Reimbursement from SBA................................................................... 15
      9. Reimbursements to Sureties .............................................................................................. 16
      10. Tracking Missing Payments .............................................................................................. 16
      11. Processing Claims for Reimbursement ............................................................................ 17
      12. Steps Taken When a Bid Bond Default Occurs ................................................................ 21
      13. Imminent Breach ............................................................................................................... 22
      14. Processing Imminent Breach Requests ........................................................................... 23
Chapter 3. Subrogation and Recovery Procedures for Prior Approval Program ............................ 24
      1. Subrogation and Recovery Activities.................................................................................. 24
      2. Funds Due SBA ..................................................................................................................... 27
      3. Indemnity Settlements........................................................................................................ 29
      4. Reinstatement of the Contractor ........................................................................................ 31
Chapter 4. Procedures for Sureties that are Defunct, in Rehabilitation, or in Liquidation, for Prior
Approval Program............................................................................................................................... 34
      1. Definitions ............................................................................................................................ 34
      2. Claims Handling Procedures for Sureties that are Defunct, in Rehabilitation, or in
             Liquidation .................................................................................................................... 34
Chapter 5. Procedures Relating to Office of Inspector General Referrals and Freedom of
Information Act Requests ................................................................................................................... 36
      1. Office of Inspector General (OIG) Referrals ........................................................................ 36
      2. Freedom of Information Act Requests and Release of Case File Information ................. 37
Chapter 6. PROCESS MAPS ................................................................................................................. 38
      1. Defaults and Notifications................................................................................................... 38
      2. Claims for Reimbursement ................................................................................................. 39
      3. Recoveries and Settlements ............................................................................................... 40




Effective Date: 05/04/2022                                                                                                            3
                                                                                      50 46 3




Chapter 1. General Overview of the Surety Bond Guarantee (SBG) Program

       1. The General Scope and Purpose of this SOP


This Standard Operating Procedure (SOP) describes the policy and procedures for the

administration and handling of defaults, claims, and recoveries resulting from surety bonds

issued by Prior Approval Sureties and guaranteed by SBA. For the purposes of this SOP, the

terms “Contractor” and “Principal” are used interchangeably.


       2. The Program's Statutory Basis


The Small Business Investment Act of 1958, as amended, empowers SBA to reimburse a Surety

participating in the Surety Bond Guarantee (SBG) Program up to a specified percentage of its

losses incurred and paid as a result of the contract denial or default of a bonded contract.

Contracts or total work orders eligible for SBA’s guarantee cannot exceed the applicable

statutory limit at the time of bond execution. The statutory limit is $6.5 million (as adjusted for

inflation in accordance with 41 U.S.C. 1908 and published in the Federal Register from time to

time), and SBA may also approve a guarantee not to exceed $10 million if a contracting officer of

a federal agency certifies that such a guarantee is necessary. Chapter 13, Part 115 of the Code of

Federal Regulations (13 CFR Part 115) provides regulatory guidelines and provisions for the SBG

Program.




Effective Date: 05/04/2022                                                                  4
                                                                                    50 46 3




       3. Program Objectives


The primary objective of the bond guarantee is to enable small contractors to obtain bonds for

contracts which they could not obtain in the traditional surety market without an SBA

guarantee. The program helps qualified small and emerging contractors grow their businesses

and compete in the marketplace.


       4. General Description of Roles and Responsibilities


       a. Headquarters Office

The Office of Surety Guarantees (OSG) is responsible for the oversight and control of SBG-related

activities. With respect to claims, OSG’s function is to minimize SBA’s losses and maximize

recoveries by:


       (1) Reviewing and approving or denying, claims for reimbursement under the guarantee;

       (2) Establishing SBA loss reserves;

       (3) Determining whether cancellation or denial of SBA liability in whole or in part is
            warranted under the guarantee; and

       (4) Establishing procedures for ensuring that SBA receives its share of any surety
            recovery in a timely manner.

       b. Surety Companies




Effective Date: 05/04/2022                                                                5
                                                                                   50 46 3




Participating sureties are required to take all reasonable actions necessary to minimize loss and

pursue recovery on any defaulted bond for which the Surety seeks reimbursement of its losses

and/or expenses. A Surety must have salaried staff that is employed directly by the Surety (not

an agent or entity under contract with the Surety) to perform all claims and recovery functions

other than specialized services the costs of which may be reimbursable under 13 CFR 115.16(e).

Final settlement authority for claims and recovery must be vested only in the Surety’s salaried

claims staff. SBA’s only contractual relationship is with the participating surety company, and

not with the individual contractor responsible for completing the bonded contract.




Effective Date: 05/04/2022                                                               6
                                                                                    50 46 3




Chapter 2. General Requirements for the Prior Approval Program and Claims

Procedures


       1. Loss of Eligibility for Further SBA Bond Guarantees


The Principal and its Affiliates are ineligible for further SBA bond guarantees under any of the

following conditions


       a. Legal action against the Principal and/or the Surety under the bond has been
          initiated;

       b. The Obligee has declared the Contractor to be in default under the Contract;

       c. The Surety has established a claim reserve for the bond in the amount established
          under 13 CFR 115.14 ;

       d. The Principal, or any of its Affiliates, has defaulted on an SBA-guaranteed bond
          resulting in a Loss that has not been fully reimbursed to SBA, or SBA has not been fully
          reimbursed for any Imminent Breach payments;

       e. The guarantee fee has not been paid by the Principal; and

       f. The Principal committed fraud or material misrepresentation in obtaining the bond
          guarantee.




Effective Date: 05/04/2022                                                                 7
                                                                                      50 46 3




Upon receipt by the Claims and Recovery Division (CRD) of any of the events listed above, the

CRD will make an entry in the Capital Access Financial System (CAFS) that the Contractor has

been placed in a default status, under which the Contractor is ineligible for further SBA bond

guarantees. If any of the above events occur in connection with a contract, and the same

Principal has other contracts, the other contracts will also be placed in a default status. Ineligible

Principals may be reinstated in accordance with 13 CFR 115.14(b).


       2. Surety Notification of a Claim Situation


A Surety must notify CRD of any of the following events by submitting SBA Form 994H (with

supporting documentation) through CAFS at the earlier of the time the Surety applies for a

guarantee on behalf of an affected Contractor, or within 30 days of the date the Surety acquires

knowledge, or should have acquired knowledge:


       a. Legal action is initiated under the bond;

       b. The Obligee declares the Contractor to be in default under the Contract;

       c. The Surety established a claim reserve for the bond; or

       d. The Surety receives any adverse information concerning the Contractor’s financial
          condition or possible inability to complete the project or to pay laborers,
          subcontractor, or suppliers (e.g., a rumble).

       e. Notice of Default, Investigation Period, and Status Updates




Effective Date: 05/04/2022                                                                  8
                                                                                     50 46 3




Upon receiving notification from the Surety that the Principal is in default of the Contract, the

CRD will make an entry in CAFS that the Principal has been placed in a default status, The claims

Investigation period starts when the Surety initially advises CRD of a default through CAFS (SBA

Form 994H). Once the Claims Investigation period is initiated, the Surety must submit

semiannual status reports on each claim 6 months after the initial default notice and every 6

months by submitting SBA Form 994H. The Surety must also immediately notify SBA of any

substantial changes including, for example, if the Obligee has filed for bankruptcy, a request for

an “Offer and Compromise” has been made, or if the claims investigation is placed on hold.


       3. Review of Contractor File


Upon receiving notification from the Surety that the Principal is in default of the Contract, CRD

will review the electronic file and/or will request additional information, if needed. The

documents contained in the contractors’ files for bond guarantees approved after October 2007

are available electronically in CAFS.


       4. Surety Status Reports on Claim and Recovery Activity


       a. The CRD uses status reports (SBA Form 994H and any supporting documentation)
          from participating surety companies to monitor a Surety’s claims and recovery
          activity on defaulted bond guarantees. Status reports must include the project’s
          completion status, remaining contract balances, performance and payment bond
          activities, Surety’s indemnity efforts, and the Surety’s claim reserve. This information
          is also used to adjust SBA’s loss reserves and to update the computer database. These
          administrative updates must be submitted by the Surety through the CAFS.



Effective Date: 05/04/2022                                                                   9
                                                                                     50 46 3




       b. The Surety is required to submit semiannual status reports on each claim beginning
          six months after the initial notice of default, and then every six months thereafter. The
          Surety must notify SBA immediately of any substantial changes (e.g., in the status of
          the claim or the amount of loss reserves.) (See Chapter 6.1 Defaults and Notifications)

       5. Claim Status Code


Based on the information that is provided in the status report(s), the bond is placed in one of the

claim statuses listed below in CAFS. The Surety is responsible for performing this function if the

Surety submits the claim electronically, and CRD will perform this function if the Surety submits

the status reports by mail if CAFS is unavailable.


The following is a list of the possible categories and descriptions.


       a. Claim Status "1": This is an "Active" status used to establish the case in claims when
          the Surety indicates that there is contingent liability and that the Surety will be
          submitting claims for reimbursement.

       b. Claim Status "2": This is a "Closed-No Loss" status used after SBA has received full
          recovery from the Surety for its claims for reimbursement paid by SBA; or when no
          payment was made by the Surety or SBA after contractor was placed in a claim status.

       c. Claim Status "3": This is a "Closed-to-Subrogation" status used when the project has
          been completed and all outstanding claims have been paid by the Surety and
          recovery is being pursued from the indemnitor(s), and/or the obligee (contract
          retainage), and/or the Contractor.

       d. Claim Status "4": This is a "Closed-Final" status that is used only after the Surety has
          exhausted all reasonable recovery efforts and has received SBA's approval to cease
          further pursuit of recovery.

Effective Date: 05/04/2022                                                                10
                                                                                      50 46 3




       e. Claim Status "5": This is a "Settlement" status that is used when the Surety has
          executed an agreement with the Principal/indemnitor for less than the actual losses
          and/or expenses paid on behalf of the principal/indemnitor. The Surety must obtain
          SBA’s concurrence before entering into any settlement agreement.

       6. Procedures for Placing a File in “Closed-Final” Status


A surety must obtain SBA’s written consent to discontinue recovery efforts when further

indemnity pursuit is considered economically impractical or when the indemnitor has been

discharged in bankruptcy. In requesting SBA’s consent, Surety must submit the following

documentation to CRD:


       (1) A summary of the Surety’s subrogation and recovery attempts on each defaulted
           project;

       (2) Financial background information on each respective indemnitor (individuals and
           entities) to verify that it is no longer practical to continue indemnity pursuit.;

       (3) If the indemnitor(s) have been discharged in bankruptcy, a copy of the Bankruptcy
           Discharge. Each indemnitor listed on the GIA must be listed on the Discharge.; and

       (4) Verification that there are no outstanding reimbursement payments due to the
           Surety and all claims are settled (including, but not limited to, Settlement
           Agreements and Releases). In the case a claim for reimbursement request is
           submitted with the Surety’s request to close, the file will remain in “Close to
           Subrogation” status until the final billing is closed.

       (5) Upon receiving authorization to close the file, the Surety must update the claim file in
           CAFS by changing the file stated to “Close-Final”.

       7. Analysis of the Contractor File


Effective Date: 05/04/2022                                                                 11
                                                                                     50 46 3




       a. CRD examines the financial conditions, business, underwriting, and default/claim
          information for bond guarantees in default to verify the Surety’s compliance with the
          regulations and SOP provisions of the SBG Program.

       b. A review of the financial, business, and underwriting information is the first step in
          analyzing the claims file. CRD examines the following documents to determine that
          the guarantee was approved in accordance with the regulations and SOP provisions
          of the SBG program and to determine the validity of the claim.

       (1) General Indemnity Agreement (GIA). Make certain this is signed by the principal(s) of
           the Contractor and indemnitor(s) and notarized by an authorized person(s). The GIA
           must indemnify the Surety that appears on the bonds and the SBA guarantee
           agreement.

       (2) SBA Form 994, "Application for Surety Bond Guarantee Assistance". Review for
           pertinent information about the company’s gross annual receipts, the project, its
           location, starting and completion dates, contract amount, penalty clause, and the
           Contractor's experience with other SBA programs. In addition, review and confirm
           that the Contractor satisfies the character and reputation eligibility requirements.

       (3) SBA Form 994F, “Schedule of Work in Process”. Review for a listing of all
           uncompleted work (bonded and unbonded) of the Contractor (and any of its
           subcontractors) at the time the guarantee was issued.

       (4) SBA Form 990, "Surety Bond Guarantee Agreement". This form is SBA's commitment
           to guarantee bonds issued by the Surety. Verify both the Surety and SBA
           representative signatures to ensure they were authorized to execute the SBA Form
           990. SOP 50 45 Chapter 1, “General Overview of the Surety Bond Guarantee
           Program,” should be used to verify the delegated authority of the SBA signature on
           the SBA Form 990.



Effective Date: 05/04/2022                                                               12
                                                                                       50 46 3




       (5) SBA Form 990A, "Quick Bond Guarantee Application and Agreement". This form is
           SBA's commitment to guarantee bonds which were issued by the Surety up to the
           amount authorized by regulation. Verify both the Surety and SBA representative
           signatures to ensure they were authorized to execute the SBA Form 990A. SOP 50 45
           Chapter 1, “General Overview of the Surety Bond Guarantee Program,” should be
           used to verify the delegated authority of the SBA signature on the SBA Form 990A.

       (6) SBA Form 991, “Surety Bond Guarantee Agreement Addendum”. This form is used
           when work under the contract has started prior to the Surety receiving SBA’s
           guarantee. It provides evidence from the Contractor that the surety bond
           requirement was contained in the original contract and sufficient documentation as
           to why the surety bond was not previously obtained. The SBA Form 991 also
           provides certification that all subcontractors and suppliers were paid before the SBA
           Form 991 is approved is correct, based on the contract amount and program
           regulations. It is important that the percentage of guarantee on the SBA Forms 990
           or 990A.

       (7) Financial/Business Data is reviewed to determine if the Contractor met program
           eligibility requirements for the SBG Program at the time that the guarantee was
           approved.

       c. CRD will thoroughly review the applicable bond(s), bonded Contract, bid solicitation,
          and Contract award letter to verify that the bonds were required, that the Contract
          amount is the same on the SBA Forms 990 or 990A, that the Contract amount was
          within statutory limits, that the Contract itself fell within the regulatory definition of
          “Contract”, that any notification and approval of increases or decreases in the
          Contract or bond amount was provided as required by 13 CFR § 115.32(d), and that
          the project was eligible for the SBG Program. (Refer to SOP 50 45, “Surety Bond
          Guarantee Program,” for more details.)



Effective Date: 05/04/2022                                                                  13
                                                                                   50 46 3




       d. CRD will also review the default notification and current status reports to ascertain
          the following information:

       (1) A description of the claim(s) filed against the bond;

       (2) The status of the project and completion arrangements;

       (3) Remaining Contract funds;

       (4) Surety's plan for settling or defending the claim(s);

       (5) The anticipated loss plus reserve amount;

       (6) Liquidated damages asserted; and

       (7) Other information pertinent to the claim.

       e. CRD will request clarification from the Surety on any discrepancy or inconsistency in
          information provided in the status reports and case files. Once the analysis is
          completed and CRD determines that payment can be made under the SBA guarantee,
          CRD places the Contractor in default status in the SBA CLS Application System. The
          SBG Specialist will prepare an initial write-up with his or her recommendation to
          approve, deny, or request additional information on the reimbursement request.

       f. Denial of Liability

       (1) The Director of the Office of Surety Bonds (D/OSG) may deny liability under SBA’s
           guarantee (in whole or in part within its discretion) in accordance with 13 CFR §
           115.19. For any claim for reimbursement for which there are grounds for denial, CRD
           will prepare and submit a written referral to the D/OSG.

       (2) Listed below are examples of the circumstances that are grounds for denial of
           liability:



Effective Date: 05/04/2022                                                              14
                                                                                     50 46 3




               a) Work began prior to obtaining SBA’s Guarantee;

               b) Original contract amount exceeds statutory limit;

               c) Ineligible type of Contract (e.g., Contracts for Financial Guarantees);

               d) Surety’s failure to obtain a GIA;

               e) Bond(s) amount exceeds contract amount;

               f) Surety did not notify SBA timely of possible default/claims;

               g) Surety’s negligence in handling losses;

               h) Surety’s material misrepresentation or omission of statement of material fact;
                  and

               i) Surety has committed a substantial violation of SBA regulations.
       8. Surety Request for Reimbursement from SBA


The Surety must submit reimbursement requests by submitting SBA Form 994H through CAFS

(except if CAFS is unavailable, the Surety may submit a paper copy via regular mail).


Under the Rule of Two, a request for reimbursement must be approved by the combined action

of two SBA employees who hold delegated or re-delegated authority. An SBA professional staff

member must recommend the action and the approval official must concur with the

recommendation. If the recommender and approval official disagree, the reimbursement

request will proceed through the chain of command until a final decision is made.


Claims and Recovery Division Approval Authority:


 Position                                             Dollar Amount (in the aggregate)
 Director, OSG                                        More than $4,000,000
 Supervisor, Claims and Recovery Division             Up to $4,000,000




Effective Date: 05/04/2022                                                                  15
                                                                                     50 46 3




       9. Reimbursements to Sureties


SBA will reimburse the Surety within 45 days of receipt of its payment request in accordance

with 13 CFR 115.35 provided that all necessary information is submitted (and subject to the

offset provisions of 13 CFR 140). To help expedite the payment process, CRD requires the

sureties to provide the following items with the initial claims for reimbursement:


       (1) Initial Default Notification;

       (2) Signed copy of the General Indemnity Agreement;

       (3) Documentation for all fees and expenses;

       (4) An original signature and date of execution of the 994H;

       (5) A narrative status report that includes percentage of completion, contract balance,
            cost to complete, appropriate reserve, and details regarding the claim situation; and

       (6) A Copy of the Agent’s power of attorney.

When additional information is needed to review a reimbursement request, CRD may disallow

the questionable amount pending receipt of the information, unless the requested information

pertains to the entire claim. If the requested information pertains to the entire amount of the

claim, CRD will return the reimbursement request to the Surety with an explanation.


       10. Tracking Missing Payments


If a Surety informs SBA that it has not received a check or electronic deposit, the Surety must

provide CRD with the SBG number, the payment amount, and the approval date.




Effective Date: 05/04/2022                                                               16
                                                                                     50 46 3




       11. Processing Claims for Reimbursement


In processing requests for claims reimbursement, CRD reviews the following items in detail:


       a. For the Initial Payment:

       (1) Review SBA Form 994H, “Surety Bond Guarantee Program- Default Report, Claim for
           Reimbursement, and Report of Recoveries” to ensure that information corresponds
           with information contained in the document in CAFS. The Surety must use the SBA
           Form 994H to file an initial or updated default status report, file a claim for
           reimbursement, report that it has established a claim reserve”, or report recoveries.
           (See Chapter 6.2, Claims for Reimbursement)

       (2) Review SBA Forms 990 or 990A, to determine the following:

              a) The SBA Official who executed the form was duly authorized.

              b) The guarantee percentage, which is:

               i.     80 percent for contracts more than $100,000;

               ii.     90 percent for contracts up to and including $100,000 at the time of
   Execution of the bond. If the contract amount increases to more than $100,000 after Execution
   of the bond, the guarantee percentage decreases by 1 percentage point for each $5,000
   increase or part thereof, but it does not decrease below 80 percent; or

               iii.    90 percent for all contracts awarded to firms owned and controlled by
   socially and economically disadvantaged individuals, by qualified HUBZone small businesses,
   or by veterans or service-disabled veterans.




Effective Date: 05/04/2022                                                                   17
                                                                                        50 46 3




When the Contract or Order amount is increased above the Applicable Statutory Limit after

Execution of the bond, SBA's share of the Loss is limited to that percentage of the increased

Contract or Order amount that the Applicable Statutory Limit represents multiplied by the

guarantee percentage approved by SBA. For example, if a contract amount increases to

$6,800,000, SBA's share of the loss under an 80% guarantee is limited to 76.5%

[6,500,000/6,800,000 = 95.6% x 80% = 76.5%].


               c) The correct name of the Surety - When there are two sureties named on the
                   SBA Forms 990 or 990A (Surety and co-Surety), the lead Surety is specified. All
                   transactions with SBA will be done through the lead Surety.

       (3) Review current status reports, including the loss reserves established by the Surety
            (loss reserves are estimated future liabilities that must be settled at a later date). If
            the validity of the claim for reimbursement or justification for payment appears to
            be questionable, refer the file to the supervisor for appropriate action.

       (4) Review the list of itemized disbursements provided by the Surety in SBA Form 994H
            by date, draft number, payee, amount, recovery received and the loss summary.
            Documentation to support the itemizations on all attorney and/or consultant fees
            must be entered by the Surety in CAFS. Once the information is entered, CAFS will
            calculate the payment amount owed the Surety or the amount due to SBA by the
            Surety.




Effective Date: 05/04/2022                                                                   18
                                                                                   50 46 3




Example #1:

            Items                                         Amount
            Loss Disbursements                            $ 4,000.00
            Loss Disbursements Previously Reported        $      -
            Total Loss of Disbursements                   $ 4,000.00
            Recovery                                      $      -
            Recovery Previously Reported                  $      -
            Undisbursed Trust Account Balance             $      -
            Total Recovery                                $      -
            Surety Net Loss                               $ 4,000.00
            Less Deductible Amount                        $      -
            Share of Surety Reimbursable Loss
            (90%)                                         $ 3,600.00
            Prior Total SBA Payments                      $      -
            Balance Due Surety                            $ 3,600.00

The Surety must make any reimbursement request by submitting SBA Form 994H to SBA within

90 days from the time of each disbursement. CRD staff, with the appropriate delegated

authority, will review and approve the SBA Form 994H in CAFS for payment to be issued.


       (5) Reinsurance

Review any reinsurance treaty that to which the Surety is a party that covers SBA guaranteed

bonds. Any amounts that the Surety receives under this treaty is applied first to the Loss, and

SBA would reimburse Surety the guaranteed percentage of any part of the Loss that is not

covered by reinsurance. For example, if the Surety has treaty reinsurance that covers the first

$100,000 in losses in excess of $50,000, and a loss of $75,000 occurs on an SBA guaranteed bond,

the reinsurance is applied first to the Loss before SBA’s guarantee as follows (assuming no other

salvage or recovery is available):




Effective Date: 05/04/2022                                                              19
                                                                                         50 46 3




                    Items                    Amount
                    Claims and Expenses Paid $75,000
                    Reinsurance Recovered    $25,000
                    Loss to Surety (gross)    $50,000
                    SBA pays the Surety (80%) $40,000*

(80% guarantee of $50,000 = $40,000, 90% guarantee of $50,000 = $45,000)


        b. For Subsequent Payments:

The same procedures used for the initial payment are used for subsequent payments. However,

it is important that CRD review the itemizations closely for any duplication of payment from

prior requests. All items that have been previously paid are considered duplicates and are

disallowed from the itemized total amount. Note disallowances(s) on the SBA Form 994H and

notify the Surety of the disallowance(s) and advise the Surety of the corrected amount that is

approved for payment.


Request and review current status reports with sufficient loss reserves (loss reserves are

estimated future liabilities that must be settled at a later date). If the validity of the claim for

reimbursement or justification for payment appears to be questionable, refer the file to the

supervisor for appropriate action.


An example of how CAFS will preliminarily calculate a subsequent payment is as follows:

Example #2




Effective Date: 05/04/2022                                                                    20
                                                                                     50 46 3




                 Items                                          Amount
                 Loss Disbursements                             $    5,500.00
                 Loss Disbursements Previously Reported         $    4,000.00
                 Total Loss of Disbursements                    $    9,500.00
                 Recovery                                       $    -

                 Recovery Previously Reported                    $      -
                 Undisbursed Trust Account Balance               $      -
                 Total Recovery                                  $      -
                 Surety Net Loss                                 $      9,500.00
                 Less Deductible Amount                          $      -
                 Share of Surety Reimbursable Loss (90%)         $      8,550.00
                 Prior Total SBA Payments                        $      (3,600.00)
                 Balance Due Surety                              $      4,950.00

       c. For Final Review and Approval of Initial and Subsequent Payments:

After the SBA Form 994H has been recommended for payment in CAFS and the original SBA

Form 994H with the original signature has been received, it is sent to the approving official for

final review and approval.


       12. Steps Taken When a Bid Bond Default Occurs


       a. A bid bond default occurs when the Surety declines to issue the final bond for any
          reason or when the contractor refuses to enter the Contract after notification of
          proposed award. To process a claim under the bid bond, SBA must receive the
          following information:

       (1) A copy of the demand letter from the obligee;

       (2) A copy of the lawsuit (if applicable);

       (3) A copy of the bid bond; and

       (4) A copy of the contract.




Effective Date: 05/04/2022                                                                21
                                                                                         50 46 3




        b. For a bid bond guarantee executed under a bonding line, CRD should review the
           bonding line in addition to the bid bond, lawsuit, or demand letter from the obligee
           when no SBA Form 990 or SBA Form 990A exists. The Surety must prepare an SBA
           Form 990 or SBA Form 990A, which must be signed by the area office surety bond
           guarantee personnel with the appropriate delegated authority. This action does not
           constitute SBA’s approval of the bond guarantee under the bonding line, but is used
           only to document the Surety’s commitment under the bonding line. CRS will carefully
           review information pertaining to the bid bond default to determine if the bid bond
           was issued after the contract was awarded and/or the job had started.

        13. Imminent Breach


Imminent Breach is a threat to the successful completion of a bonded contract that, unless

remedied by the Surety, makes a default under the bond appear to be inevitable. Subject to the

conditions set forth below, SBA will share, to the same extent that it would share in any other

loss, a loss arising out of a Principal’s failure to repay in full funds advanced to it by the Surety in

order to avoid, or attempt to avoid, an imminent breach of the terms of a Contract covered by an

SBA guaranteed bond. To qualify for such reimbursement, a Prior Approval Surety must first

request in writing SBA approval for such advances not to exceed in total 10% of the contract

price (unless the Administrator determines that advances in excess of 10% are necessary and

reasonable). The Surety must demonstrate that the circumstances make a breach imminent and

that there is no other recourse to prevent such breach. The Surety’s request for approval must

also describe the basis for the Surety’s belief that the Principal can successfully complete the

contract if the advances are made. In no event shall SBA pay a Surety an amount exceeding the

guaranteed share of the bond. (See § 411(b)(3) of the Small Business Investment Act).

Effective Date: 05/04/2022                                                                    22
                                                                                    50 46 3




       14. Processing Imminent Breach Requests


       a. Once SBA receives an Imminent Breach request, CRD will review the Principal’s
          electronic file. (CRD will review the case file with an emphasis on the current work in
          progress; the Principal’s ability to repay the Surety; the number of potential claims;
          and the nature and extent of work to be completed.

       b. CRD will provide a brief summary of the case with recommendations on whether SBA
          should reimburse the Surety for imminent breach payments to the Director of OSG
          (D/OSG). If the D/OSG agrees to reimburse the Surety for Imminent Breach, CRD will
          enter the imminent breach payments information into CAFS. This entry will set-up a
          computerized file so that SBA can reimburse the Surety and monitor repayment
          activity. If the amount of reimbursement will exceed 10% of the Contract amount, the
          D/OSG must seek the Administrator’s approval and provide a recommendation on
          whether this greater amount is reasonable and necessary.




Effective Date: 05/04/2022                                                               23
                                                                                      50 46 3




Chapter 3. Subrogation and Recovery Procedures for Prior Approval Program

       1. Subrogation and Recovery Activities


       a. Conditions Necessary to Transfer a Bond to Subrogation/Recovery Status

CRD will place the defaulted bond into a “Closed-to-Subrogation” status (Claim Status “3”) in

the CAFS when the Surety advises SBA that the project has been completed, all claim payments

have been made, no further contingent liability remains, and recovery is being actively pursued

from the Contractor, the principal(s), indemnitors, and obligee. CRD then monitors Surety’s

recovery efforts through regular status reports.


       b. Status Reports

       (1) CRD uses status reports (SBA Form 994H) from Sureties to monitor recovery and to
            check the expenses anticipated relative to recovery efforts. In accordance with 13
            CFR § 115.35(d), the Surety must submit these reports semi-annually; however, the
            Surety must notify SBA immediately of any substantial changes in the status of the
            claim or the amounts of Loss reserves (e.g., additional claims are made against the
            bond, contractor filed for bankruptcy). CRD can also request additional information
            at any time, if necessary. CRD compares information contained in the current status
            report to that in previous status reports, as well as to other information on file to
            check for consistency, accuracy, and to verify that the Surety is taking all steps
            necessary to minimize the loss and is pursuing all possible sources of recovery.

       (2) As part of a status report, a Surety must include an update, if applicable, of the
            approved repayment plan for a defaulted contractor. CRD will review and monitor
            the repayment plan to ensure receipt of SBA’s share of monies received by the
            Surety.


Effective Date: 05/04/2022                                                                 24
                                                                                     50 46 3




        (3) CRD also monitors actual and anticipated legal fees and costs associated with the
              Surety's subrogation and recovery efforts.

        (4) A detailed status report should include as much information as possible to reduce
              any ambiguity. At a minimum, a status report must include the following
              information:

                a) How the default claim arose.

                b) Current state of claim:

                c) Current monetary claims against bond(s);

                d) Contract completion percentage;

                e) Remaining contract funds;

                f) Investigative stage(s);

                g) Project completion plan;

                h) Attorney involvement; Litigation or Adjudication Rules (ADR); Monetary
                   Litigation or ADR Settlement (include information relied on to arrive at
                   settlement amount, and any other pertinent information, like comparisons of
                   jury verdicts, and/or similar claims)

                i) Subrogation/Recovery/Indemnification (collection efforts) including all of the
                    information pertaining to collection efforts, and all the information relied on
                    to reach either the conclusion to settle and for how much, or the conclusion
                    to discontinue recovery efforts.

                j) Sources of Recovery and Related Documentation
The following is a list of documentation required for SBA’s review of the Surety’s recovery

activities:


        (5) GIA: This is an agreement signed by an individual or entity (jointly and severally,
              accepting responsibility) to reimburse the Surety for any monetary loss or exposure
              incurred on a bond that it issues. The signatures on this form determine who the
              Surety holds liable and what assets may be pursued by the Surety.


Effective Date: 05/04/2022                                                                25
                                                                                  50 46 3




       (6) Investigative Reports: These reports should locate the indemnitors and ascertain
           what assets are available for indemnity pursuit. (Two of the most common
           investigative reports are obtained from Equifax and Dun and Bradstreet.)

       (7) Financial Statements and Reports: These reports include the assets and liabilities of
           the individual indemnitors or the Contractor at a given point in time. Current
           financial statements should be compared to those that were originally submitted
           with the underwriting package (including the SBA Form 413 - Personal Financial
           Statement) and reviewed for any discrepancies. Examples of the types of assets that
           would be included in these reports are:

       (8) Corporate Assets

              a) Real Estate

              b) Machinery and Equipment

              c) Accounts Receivable

              d) Supplies and Materials

              e) Bank Accounts

              f) Insurance Policies

              g) Personal Assets

              h) Residence (In some states, subject to Homestead Acts)

              i) Land and Real Estate

              j) Bank Accounts/Stocks and Bonds

              k) Insurance Policies

              l) Luxury Items (Jewelry, automobile, boats, etc., check with the Department of
                  Motor Vehicles for registration)




Effective Date: 05/04/2022                                                             26
                                                                                   50 46 3




       (9) Letters of Credit: Issued by banks, these are sometimes required by the Surety as
           collateral at the time that the bond was underwritten. If a default occurs, this can be
           pursued as recovery.

       (10) Discharge in Bankruptcy: This may be requested from the Surety as documentation
           of the actual parties to the bankruptcy and the date of discharge, as well as the type
           of bankruptcy.

       (11) Judgment: A copy of the judgment against the Contractor and/or Indemnitors is
           requested from the Surety to clarify the details of the judgment.

       (12) Accounting of Contract Funds: Since the contract funds remaining on a defaulted
           project may represent a substantial amount of recovery, a complete accounting of
           the remaining funds is conducted by CRD.

       2. Funds Due SBA


       a. A “Due SBA” account occurs when the Surety’s reimbursable loss amount is less than
          SBA’s paid amount. SBA is entitled to its guaranteed percentage of all salvage and
          recovery obtained by the Surety. The Surety must reimburse or credit SBA its
          guaranteed share within 45 days of receipt of any recovery by the Surety. A “Due SBA”
          account can also occur when a refund is due SBA because an over payment was made
          to the Surety as the result of overbilling or otherwise.

       b. The following procedures apply to “Due SBA” accounts:

       (1) For Active (currently participating) and non-Active (Sureties who are not actively
           submitting applications) or Defunct Sureties, all recovery and refund payments are
           sent through www.Pay.gov.




Effective Date: 05/04/2022                                                              27
                                                                                  50 46 3




       (2) The “Due SBA” amount is submitted by the Surety via CAFS on SBA Form 994H,
           “Default Report, Claim for Reimbursement, Report of Recoveries and Record of
           Administrative Action.” (See Chapter 6.3, Recoveries)

       (3) If reimbursement is not received by SBA within 45 calendar days of receipt of any
           recovery by the Surety, and there is no indication that the recovery monies have
           been credited to the appropriate bond, CRD will notify the Surety that SBA has not
           yet received reimbursement and request the Surety to either verify to CRD that
           monies were sent or immediately remit the reimbursement to SBA. A Surety’s failure
           to forward payment verification or to remit recovery monies to SBA within 14
           calendar days of the remittance deadline will result in the D/OSG issuing of a
           demand letter with the assistance of SBA’s Office of General Counsel. If the monies
           have not been sent, CRD will postpone all future claims handling transactions
           associated with the bond and refuse to issue further guarantees until payment
           verification is submitted by the Surety. Additional measures may be considered if
           there is a pattern of persistent disregard to remittance procedures including (but not
           limited to) renegotiation of the guarantee percentage and/or SBA's charge to the
           Surety for bonds. (13 CFR §115.18)

       (4) If recovery monies have been applied to an incorrect bond, the Surety must
           immediately contact CRD with the transaction information and request a reversal
           and reimbursement application to the appropriate bond.

       (5) If a refund of recovery monies is warranted, the Surety must submit SBA Form 994H
           and complete the line in paragraph G, “Total Due and Submitted to SBA”. The
           Surety must also provide an adequate description of the request in Section C of SBA
           Form 994H, including (but not limited to) the circumstance which resulted in the
           overpayments of SBA’s share of the recovery. All refunds will be reviewed by CRD in
           consultation with the D/OSG and evaluated based on the standing of the claim file.



Effective Date: 05/04/2022                                                              28
                                                                                    50 46 3




       3. Indemnity Settlements


A settlement occurs when a defaulted contractor and its Surety agree upon an amount less

than the total loss amount that will satisfy the contractor’s indebtedness to the Surety. SBA

must concur, in writing, to a Surety’s recommendations regarding the settlement offer before

the settlement can be finalized. Once the settlement has been executed, the Surety must

submit SBA’s guaranteed share of such amount within 45 days of receipt.


       a. Types of Settlements

CRD will identify in CAFS the type of settlement approved as follows:


       (1) Settlement (Immediate Payment of SBA's Pro Rata Share of Recovery). The Surety
            settled its claim with the indemnitor(s) for an amount less than the Surety's total
            loss with terms accepted by OSG.

       (2) Settlement (Delayed Payment of Settlement Adequately Assured). The contractor
            has paid the Surety a portion of the settlement amount and the Surety has taken
            firm collateral from the contractor for the balance of the settlement amount. CRD
            must obtain a copy of the collateral document and SBA's share of the partial
            payment from the Surety.

       (3) Contested Claim (Scheduled Court Appearance). The contractor has been presented
            with a claim which it contests in court. The contractor posts collateral with the
            Surety in the amount of the possible loss from the claim, including legal and
            administrative fees reimbursed to the Surety by SBA. The Surety sends SBA a copy of
            the draft, money order, or collateral document plus confirmation that there are no
            other claims outstanding on this or any other SBA-guaranteed bond involving this
            contractor.


Effective Date: 05/04/2022                                                               29
                                                                                     50 46 3




       b. Policy Guidelines for Settlements

Under the terms and conditions of SBA Forms 990 or 990A, the authority to take charge of all

suits or claims arising under the bond lies with the Surety and not SBA (unless SBA decides

otherwise and so notifies Surety); however, under 13 CFR 115.36(a), the Surety must obtain

SBA’s written concurrence with the terms negotiated by the Surety before the Surety may enter

into a settlement agreement. The contractor's contractual relationship is with the Surety

company, not SBA; therefore, all matters pertaining to settlement and reinstatement must be

arranged with and through the Surety. SBA will not negotiate or discuss with the contractor any

amount owed to the Surety by the contractor or settlement of such debts.


       c. Procedures Used to Review a Settlement Proposal

CRD takes the following steps to review a Surety’s recommendation for indemnity settlement.


       (1) Checks SBA’s payment amount for all defaulted projects (including projects with
           other sureties) to determine SBA’s total net loss on all projects.

       (2) Determines which defaulted projects are involved in the settlement proposal.

       (3) Reviews the facts outlined in the settlement letter and any other correspondence.

       (4) Reviews the following information in the file:

              a) GIA - Make sure that all of the indemnitors are accounted for in the Surety
                 settlement proposal. If not, request information regarding what recovery
                 actions have been taken against the indemnitor(s) in question.

              b) Status Reports, Financial Statements (including tax returns) - ascertain the
                 financial status of the indemnitors.

              c) Investigative Reports (credit, asset reports, etc.) - Further evaluate the
                  financial status of the indemnitors.

Effective Date: 05/04/2022                                                                30
                                                                                     50 46 3




                d) If clarification of questionable items or supporting documentation is needed,
                    contact the Surety for additional information.

                e) Compare the total net loss figure with the total amount of the settlement
                   being offered. Consider whether the settlement offer is reasonable compared
                   to the total loss amount.

                f) Prepare a written summarization of the facts of the case, including any
                    pertinent recommendations concerning the settlement proposal. Explain any
                    agreement or disagreement with the settlement offer.

                g) Submit recommendations to the D/OSG through your supervisor.

                h) Advise the Surety of SBA's decision concerning the settlement offer. This
                   response may be in the form of a telephone call, email, or a letter, depending
                   upon the urgency of the situation. If the response is by phone, prepare a letter
                   of confirmation no later than the next business day. The letter should outline
                   the settlement terms as submitted to SBA.

                i) If the settlement proposal is not satisfactory to SBA, CRD will advise the Surety
                     and request that it to re-negotiate the settlement terms.

                j) Request a follow-up letter from the Surety representative outlining the
                    settlement terms and the final outcome. If the settlement is executed, CRD
                    must request a copy of the executed agreement and SBA’s share of monies
                    received.

                k) Upon receipt of this follow-up letter, monitor the file for an appropriate period
                   of time to ensure that the recovery monies have been received.
       4. Reinstatement of the Contractor


A reinstatement occurs when the Contractor becomes eligible for further Surety bond guarantee

consideration and the SBA CLS Application System is updated accordingly. See 13 CFR

115.14(b)(1).


       a. Circumstances Permitting Reinstatement




Effective Date: 05/04/2022                                                                31
                                                                                       50 46 3




At any time after a Contractor becomes ineligible for further bond guarantees, a Prior Approval

Surety may recommend that such Contractor’s eligibility be reinstated, and OSG may agree to

reinstate the Contractor if:


       (1) The Surety has settled its claim with the Contractor, or any of its affiliates, for an
            amount that results in no Loss to SBA or in no amount owed for Imminent Breach
            payments, or D/OSG finds good cause for reinstating the Contractor
            notwithstanding the Loss to SBA or amount owed for Imminent Breach payments.
            Good cause may exist, for example, if the loss was attributed solely to the acts or
            omission of a co-owner who is no longer a part of the business, or

       (2) D/OSG and the Surety determine that further bond guarantees are appropriate after
            the Contractor was deemed ineligible for further SBA bond guarantees under
            Chapter 2, paragraphs 3.a, b, c, e, and f.

Note: The Surety is the only party that may request reinstatement of a Contractor. The Surety

shall not direct or encourage a Contractor, the Contractor’s attorney, or the Contractor’s current

agent to contact SBA regarding the reinstatement of the Contractor. If this occurs, SBA

personnel will refer the party to the Surety of record.


       b. Impact of Surety Company Financial Status on Reinstatement

       (1) Settlement Effected Prior to the Surety Company's Status Change: If a settlement
            between the Contractor or Contractor's legal representative and the Surety
            company was approved by SBA and was in effect prior to the Surety company's
            status change to defunct, rehabilitation, or liquidation, then the amount and the
            terms of the settlement should stand as the duly renegotiated debt.




Effective Date: 05/04/2022                                                                  32
                                                                                        50 46 3




       (2) Settlement Effected After the Surety Company's Status Changed: Subject to SBA
            approval of the settlement terms, a new settlement on a defaulted SBA- guaranteed
            bond may be in effect between a Contractor and a State Insurance Department as
            liquidator, if the Contractor's Surety is defunct, in rehabilitation, or in liquidation.

       c. Reinstatement Procedures

CRD takes the following steps to reinstate a file.


       (1) Review the file in the CLS.

       (2) If the file was previously closed final and sent to storage, update the status in the CLS.

       (3) If a settlement has been approved, check the net loss figure, recovery total, and
            default status, and review to ascertain that the terms of the settlement have been
            satisfied.

       (4) Update the SBA CLS Application System database records to reflect the
            reinstatement or closing status.

       (5) Prepare a reinstatement letter and submit it to the supervisor for approval.

       (6) If the reinstatement has been approved and the reinstatement letter signed, the
            following steps should be taken to return the file, if applicable, to the area office.

               a) The reinstatement letter and documentation that supports the reinstatement
                   are to be uploaded to the electronic file contained in the SBA CLS Application
                   System.

               b) Send notification of reinstatement to the appropriate area office via e- mail or
                  with the file by overnight mail.




Effective Date: 05/04/2022                                                                   33
                                                                                         50 46 3




Chapter 4. Procedures for Sureties that are Defunct, in Rehabilitation, or in

Liquidation, for Prior Approval Program


        1. Definitions


Defunct Surety: A defunct Surety has ceased to function and no longer conducts business

operations.


Surety in Rehabilitation: A Surety in rehabilitation is under corporate reorganization of Chapter

11 of the Bankruptcy Code in an attempt to reinstate the Surety to its former condition of

successful operation and solvency.


Surety in Liquidation: A Surety in liquidation is in the process of settling its financial affairs by

reducing its assets to cash, discharging liabilities, and dividing surplus or loss. Liquidation may

precede or follow dissolution, which is the end of the legal existence of a corporation.


        2. Claims Handling Procedures for Sureties that are Defunct, in Rehabilitation, or in
          Liquidation


If a Surety becomes insolvent (i.e., defunct, in rehabilitation, or in liquidation), all rights or

benefits conferred on the Surety under a valid and binding Prior Approval agreement will accrue

only to the trustee or receiver of the Surety. SBA will not be liable to the trustee or receiver of the

insolvent Surety except for the guaranteed portion of any loss incurred and actually paid by such

Surety or its trustee or receiver under the guaranteed bonds. The State Insurance Department

where the Surety is located becomes responsible for settling claims and handling all claims

matters. The trustee or receiver must submit to SBA quarterly status reports accounting for all

Effective Date: 05/04/2022                                                                    34
                                                                                     50 46 3




claims paid, all funds received, and all settlements being considered. All correspondence

concerning sureties that are defunct, in rehabilitation, or liquidation will be referred to OSG’s

claims director for action. Payment requests from insolvent sureties will be processed in

accordance with Chapter 2, “Claim Reimbursement Procedures for the Prior Approval Program,”

of this SOP.




Effective Date: 05/04/2022                                                                35
                                                                                      50 46 3




Chapter 5. Procedures Relating to Office of Inspector General Referrals and Freedom

of Information Act Requests


       1. Office of Inspector General (OIG) Referrals


All SBA officials, Sureties and other program participants should be on the lookout for fraud and

report any known or suspected irregularities involving SBA programs, program participants, or

personnel to the OIG. Whether acting alone or in collusion with others, surety bond guarantee

applicants, Principals, Sureties, Obligees, or other individuals with an interest in the contract

may intentionally provide false information to SBA. Examples of irregularities that must be

referred include:


       (1) Overstating income;

       (2) Understating or failing to disclose liabilities and debts;

       (3) Overvaluing collateral;

       (4) Failing to disclose criminal record;

       (5) Making false claims of U.S. citizenship;

       (6) Failing to disclose true ownership of the business;

       (7) Using false social security numbers to conceal poor credit history;

       (8) Submitting altered tax returns;

       (9) Creating false work histories;




Effective Date: 05/04/2022                                                                 36
                                                                                    50 46 3




       (10) Actions by corrupt surety agents who orchestrate, facilitate, or otherwise support
            any of the illegal acts committed by SBG applicants; or

       (11) Misconduct by a Surety, surety agent or representative, or SBA official such as the
            solicitation, offer or acceptance of a bribe to approve a surety bond guarantee.

A referral to the OIG can be made by:


Calling the toll –free OIG Hotline at 1-800-767-0385;

Completing the on-line OIG Complaint Submission Form at https://sbax.sba.gov/oigcss/ and

submitting the referral via the Internet; or

Mailing the referral to:

U.S. Small Business Administration

Office of Inspector General

Investigations Division, Mail Code 4113

409 Third Street, SW Washington, DC 20416


       2. Freedom of Information Act Requests and Release of Case File Information


       a. Public access to information contained in SBA case files is governed by provisions
          established by the Freedom of Information Act and Privacy Act. See 13 CFR 102,
          “Record Disclosure and Privacy” and SOP 40 03 3, “Disclosure of Information” and
          SOP 40 04 3, “Privacy Act Procedures”, (or their successor SOPs).

       b. If SBA receives a subpoena and/or court order for a file in claims, CRD will notify the
          D/OSG and the Office of General Counsel immediately. Under no circumstances
          should CRD release a case file from OSG without notifying and consulting with the
          D/OSG and the Office of General Counsel.


Effective Date: 05/04/2022                                                               37
                                            50 46 3




Chapter 6. PROCESS MAPS

       1. Defaults and Notifications




Effective Date: 05/04/2022             38
                                          50 46 3




       2. Claims for Reimbursement




Effective Date: 05/04/2022           39
                                            50 46 3




       3. Recoveries and Settlements




Effective Date: 05/04/2022             40


File and source

File
2022-05_SOP50463_508.v3.pdf
Size
703,298 bytes
SHA-256
e0eef2827d3dd16a1645c936d12506ce50089c100af369b0cb4ea8c6388225fe
Our copy
2022-05_SOP50463_508.v3.pdf
Original
www.sba.gov
Back to top