SPARK 7.2.1 Release Notes

These features were released November 28, 2020. This release includes support for the new SBA Forms released on November 3rd, including SBA Form 1920, SBA Form 1919, and SBA Form 2449 (Community Advantage Addendum).

• SBA Information Notice

• SBA Form 1919

• SBA Form 1920

• SBA Form 2449

Here are some new features we included in this release.

SBA Form Updates

SBA Form 1919

Associates

The term “principal” has been retired in SPARK 7.2.1 and is now replaced with “associate” per the instructions in SBA Form 1919.

An associate is defined as:

• For a sole proprietorship, the sole proprietor;

• For a partnership, all general partners, and all limited partners owning 20% or more of the equity of the firm; or any partner that is involved in management of the applicant business;

• For a corporation, all owners of 20% or more of the corporation, and each officer and director;

• For limited liability companies, all members owning 20% or more of the company, each officer, director, and managing member;

• Any person hired by the Applicant to manage day-to-day operations of the Applicant business ("key employee"); and

• Any Trustor (if the Applicant is owned by a trust).

• Each entity owning an equity interest in the Applicant.

Business History Form

A new business history form (section I of SBA Form 1919) is included in this release and will be automatically associated to all SBA products. The new business history form aligns to section I of SBA Form 1919 and includes the following new questions:

• Do you plan to use a 401(K) Plan (including a Rollover for Business Start Up (ROBS) Plan) for equity?

• Will a Management Company be hired by the Applicant to manage the day-to-day operations?

In addition to new questions, the new form requires additional details depending on the answer to certain questions. The details are automatically attached as separate attachments when the 1919 is generated.

Business history forms that were previously completed by an applicant will remain intact; however, SPARK will support “upgrading” the form to the new version. Keep in mind that new questions will need to be answered in order to complete and save the form.

Personal History Form

The personal history form does not include new questions; however, SPARK will prompt for additional details depending on the answer to certain questions. As with the business history form, the details are automatically attached as separate attachments when the 1919 is generated.

Entity Owner History Form

A new “entity owner” form is required for all businesses that are considered “associates” of the applicant business. The new entity owner history form aligns to section III of SBA Form 1919 and includes the following questions:

• Is the Entity, or any of its owners, presently suspended, debarred, proposed for debarment, declared ineligible, or voluntarily excluded from participation in this transaction by any Federal department or agency?

• Does the Entity have any Affiliates?

• Has the entity and/or its Affiliates ever filed for bankruptcy protection?

• Is the Entity and/or its Affiliates presently involved in any pending legal action?

• Has the Entity ever obtained a direct or guaranteed loan from SBA or any other Federal agency or been a guarantor on such a loan? (This includes, but is not limited to USDA, FHA, EDA.)

  • Is any of the financing presently considered delinquent?

  • Did any loan that was for a business purpose ever default and cause a loss to the Government, including a compromise, resolution or settlement of a loan's principal balance for less than the full amount due?

Entity Owner Information Request Workflow

Information requests used on SBA 7(a) loan packages will include a new workflow and activity for all “entity owners”. As part of this release, the new workflow will automatically be added to all standard SBA 7(a) loan application information requests. If your SPARK instance has been customized, the new entity owner information workflow may need to be added to your information requests to ensure that a complete loan application can be collected.

Entity Ownership Validation

Since the new 1919 requires 100% ownership, a new validator has been introduced to verify the ownership structure of all entity owners.

Entity Owner 1919 Placeholder

Prior to this release, SPARK only included placeholders for individual owners of business applicants. Now that the new 1919 includes section III for entity owners, an additional 1919 placeholder has been introduced to support generating a 1919 for these businesses. 1919s generated for entity owners will only include section I (applicant business information) and section III (entity owner information). 1919s generated for individual owners will include section I (applicant business information) and section II (individual owner information).

Rollover for Business Startup Legal Structure

A new legal structure has been added in this release to support Rollover for Business Startup. If selected for a business applicant, Section I’s 401(k) plan checkbox will be checked.

SBA Form 1920

SBA Eligibility Changes

We’ve made changes to SPARK’s SBA Eligibility feature to account for changes in SBA Form 1920.

New Eligibility Sections

The following sections have been added based on changes to SBA Form 1920:

• Occupancy / Leasing – this section replaces the old “construction and improvements” section and aligns to the new 1920.

Revised Eligibility Sections

The following sections have been revised based on changes to SBA Form 1920:

• General Eligibility – updated the section by removing questions that are no longer required on the new 1920.

• Character – updated the section to align to the character determination requirements and removed the tracking of charges.

• Business Acquisition / Change of Ownership – added support for the worksheet used to determine what type of business valuation is required.

• Refinance – removed questions that no longer appear on the new 1920.

• Citizenship – updated the questions to align to the new 1920 and removed the foreign-owned business section.

Retired Eligibility Sections

The following sections have been retired and will no longer be used on new SBA 7(a) loan packages:

• Type of Business

• Lender Certifications

• Construction and Improvements

• Preference

• Franchise

Loans with an SBA Loan Number will retain their historical SBA eligibility sections. Retired and updated sections only apply to new loan packages or existing loan packages that have not been submitted to the SBA.

SBA Form 2449 (Community Advantage Addendum)

Location Analysis

SPARK’s location analysis feature has been updated to align to SBA Form 2449.

Assistance Tracking

The assistance tracking feature has been updated based on minor changes to SBA Form 2449.

Find Out More

If you're interested in learning more, please check out these helpful links:

• SPARK 7.2.1 release notes

• SPARK 7.2.1 webinar

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