Skip to content
BOL Conferences
Thread Options
#1836598 - 07/25/13 08:14 PM Commercial Loans & Credit Reports
Ray_ Offline
Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
I was just wondering how many of you report your commercial purpose loans to the credit bureaus? Historically we have not, but I'm wondering if we are alone in this practice.

Return to Top
Lending Compliance
#1836600 - 07/25/13 08:17 PM Re: Commercial Loans & Credit Reports Ray_
RR Joker Offline
10K Club
RR Joker
Joined: Nov 2002
Posts: 20,656
The Swamp
You are not alone.
_________________________
My opinion only. Not legal advice.

Say you'll haunt me - Stone Sour

Return to Top
#1836712 - 07/26/13 01:31 PM Re: Commercial Loans & Credit Reports Ray_
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
There are way too many variables to probably even attempt to report commercial loans - one being is that your automated loan accounting software probably does not support it.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1836785 - 07/26/13 02:47 PM Re: Commercial Loans & Credit Reports Ray_
Ray_ Offline
Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
The question originated from an article we read that SBA requires charged-off loans to be reported to the credit bureaus. So I wanted to see if this was creating an issue for any other SBA lenders.

Return to Top
#1836797 - 07/26/13 02:53 PM Re: Commercial Loans & Credit Reports Ray_
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
I would be looking for a citation. According to this document from the SBA, they decide what to do - see the footnote ** after wrap up.

http://www.sba.gov/sites/default/files/bank_wrapup_report.pdf
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1836823 - 07/26/13 03:10 PM Re: Commercial Loans & Credit Reports Ray_
Ray_ Offline
Platinum Poster
Joined: Aug 2006
Posts: 879
Dallas, TX
This is what SBA sent us:

Page 30 of SOP 50-57 provides the following guidance:

2. Reports to Credit Reporting Agencies

In accordance with the Debt Collection Improvement Act of 1996, Lenders are required to report information to the appropriate credit reporting agencies whenever they extend credit via an SBA loan. Thereafter, they should continue to routinely report information concerning servicing, liquidation, and charge-off activities throughout the life-cycle of the loan. (See Chapter 26 for more information regarding credit reporting requirements for loans in charge-off status.)

Return to Top
#1836828 - 07/26/13 03:11 PM Re: Commercial Loans & Credit Reports rlcarey
HRH Okie Banker Offline
Power Poster
Joined: Jan 2003
Posts: 3,070
Oklahoma
Originally Posted By: rlcarey
There are way too many variables to probably even attempt to report commercial loans - one being is that your automated loan accounting software probably does not support it.


The second being that comm'l loans are notorious for not being renewed in a timely manner because officers are waiting for updated financials or tax returns. Too often a loan officer will not think of processing an extension and the loan will go over 30 days past due for these reasons. I can't imagine constantly having to go into E-Oscar to fix these bank error issues.

I've never worked at a F/I that reported comm'l loans.
_________________________
Just working here until I get my letter from Hogwarts.

Return to Top
#1836912 - 07/26/13 04:17 PM Re: Commercial Loans & Credit Reports Ray_
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
Page 30 of SOP 50-57 provides the following guidance:


Hmmm.... There is no such statement on Page 30 of the March 1 2013 version??? There is mention of credit bureau reporting on page 164, but it really is not clear whether that section is directed at the lender or at the SBA, because I doubt that lenders have access to ("CAIVRS").

http://www.sba.gov/sites/default/files/SOP%2050%2057%20-%207(a)%20Loan%20Servicing%20and%20Liquidation%20(FINAL).pdf
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1844639 - 08/21/13 07:47 PM Re: Commercial Loans & Credit Reports Ray_
WI Banker Offline
Gold Star
Joined: Dec 2006
Posts: 253
We report commercial loans and spend a lot of time on manual changes and corrections. I highly recommend not reporting them.

Return to Top
#1977252 - 11/18/14 08:08 PM Re: Commercial Loans & Credit Reports WI Banker
MK Offline
Member
Joined: Apr 2006
Posts: 62
Florida
I'd like to revisit this topic. According to page 30 of the SOP 50 57 effective 3/1/13 (https://www.sba.gov/sites/default/files/sops/SOP_50_57-7(a)_Loan_Servicing_and_Liquidation_FINAL_1.pdf) lenders are required to report SBA or federally guaranteed loans to the credit bureaus. Are any other banks that make SBA loans doing this? If so, what issues have you run into?
Last edited by MK; 11/18/14 08:09 PM.
Return to Top
#2240085 - 07/24/20 01:12 PM Re: Commercial Loans & Credit Reports Ray_
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
Reviving this old thread, does anyone know if reporting the loans to SBA is required? we are being asked the same question.

pg 28 of this document links to the 1502 reporting form in the second link...
https://www.sba.gov/document/sop-50-57-7a-loan-servicing-and-liquidation

https://www.sba.gov/document/sba-form-1502-sba-form-1502-instructions
_________________________
CRCM, CAMS

Return to Top
#2240086 - 07/24/20 01:37 PM Re: Commercial Loans & Credit Reports Ray_
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
after additional research, you are required to report the loans on form 1502 to Colson, which we are doing. Doesn't sound like we're required to report them elsewhere.
_________________________
CRCM, CAMS

Return to Top
#2274837 - 08/28/22 12:38 AM Re: Commercial Loans & Credit Reports bcompliance
Jamie G Offline
New Poster
Joined: Jun 2016
Posts: 4
What was your additional research that led you to that conclusion? From what I'm reading we ARE required to report SBA loans to a commercial credit bureau in addition to reporting them directly to the SBA on the 1502.

Return to Top
#2274838 - 08/28/22 01:26 PM Re: Commercial Loans & Credit Reports Ray_
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,356
Galveston, TX
Read Page 28: https://www.sba.gov/sites/default/files/files/SOP_50_57_2_1.pdf

Read Appendix 3: https://www.fiscal.treasury.gov/files/reference-guidance/fedcreditbureauguide.pdf

Form 1502 only reports the loans to the SBA and not to the credit bureaus, unless someone has later information.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top

Moderator:  Andy_Z