SBA & SPARK Update Regarding Citizenship & SBSS Scores

The SBA has released four procedural notices that go into effect on March 1st:

• 5000-876626: Revised Applicant Ownership, Citizenship, and Residency Requirements for 7(a) and 504 Loans

• 5000-875701: Sunset of SBSS Score for 7(a) Small Loans

• 5000-876777: Sunset of SBSS Score - Supplemental Guidance

• 5000-875051: 7(a) Alternative Base Rate Options

To align with these changes, SPARK will deploy a hotfix on Saturday, February 28th, at 11:00 PM CT.

SBA Citizenship Eligibility

Updates to Edit Individual Details for Internal Users

We are adding support for documenting individuals that are U.S. Nationals and updated behavior for Legal Permanent Residents.

• If the answer to 'Is this individual a U.S. Citizen?' is No, a dropdown will be shown with the following options:

  • U.S. National

  • Legal Permanent Resident

  • Foreign National / Other

• If Legal Permanent Resident is selected, SPARK will continue to display the following fields:

  • Alien Registration Number

  • Country of Citizenship

• If US National is selected, no additional fields are shown

• If Foreign National / Other is selected, SPARK will display the following field:

  • Country of Citizenship

• These same updates apply to internal Information Requests.

Updates to Information Requests for Applicants

When completing the Citizenship section in an Information Request, we are making the following updates:

• If the answer to 'Are you a U.S. Citizen?' is No, the question 'What is your status?' which will appear, with the following options:

  • U.S. National

  • Legal Permanent Resident

  • Foreign National / Other

• If Legal Permanent Resident is selected, SPARK will show the following fields:

  • Alien Registration Number

  • Country of Citizenship

• If Foreign National / Other is selected, SPARK will show the following field:

  • Country of Citizenship

Updates to Citizenship section in SBA Eligibility

Question 1: Are 100% of all direct and indirect owners of the applicant U.S. Citizens or U.S. Nationals?

• If answered No, this section will Fail.

• This question will be automatically answered when all owners are documented as US Citizens or US Nationals in SPARK. The answer can be changed by the lender.

Question 2: Do all direct and indirect owners have their principal residence in the United States, its territories, or possessions?

• If answered No, this section will Fail.

• This question will be automatically answered when all owners have a current address documented in SPARK that is a US address. The answer can be changed by the lender.

Impact to SPARK API

• SPARK’s API (v2 / v3) will not have any schema changes to support Foreign National / Other to avoid breaking existing integrations.  Legal permanent resident can be used and will set the citizenship status to “Legal Permanent Resident” accordingly.  We will not support designating a U.S. National in the API.

SBSS Scores for 7(a) Small Loans

We are making the following updates to phase out SBA SBSS scores:

• Existing SBA SBSS scores will remain visible in SPARK, but new scores can no longer be retrieved from E-Tran.

• The 'SBA Summary' section of the Package Summary will display any previously recorded SBA SBSS scores. The package 'Scoring Dashboard' will no longer show the option to retrieve an SBA SBSS score for small 7(a) loans.

• In SBA Eligibility, the '7(a) Small Loan section' under General Eligibility will be hidden for any 7(a) small loan packages that do not have an SBSS score.

SBA Knowledge Assistant

• The four new procedural notices will be added to the SBA Knowledge Assistant.

• SBA Procedural Notice 5000-872050: Update to SOP 50 10 8 – Citizenship and Residency Requirements will be removed from the SBA Knowledge Assistant.

Find Out More

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