Small Business Administration Paycheck Protection Program (PPP) Non-Bank Lender Review

Evaluating and underwriting lender applications for SBA’s largest federal credit program

Challenge: As part of the COVID-19 Economic Stimulus package the U.S. Small Business Administration (SBA) was responsible for standing up and administering the $659 billion Paycheck Protection Program (PPP). The program allowed qualified, non-Federally regulated, non-bank lenders to participate in the program. With a highly condensed timeline, SBA lacked the resources and expertise to evaluate the risk of non-bank lender applications.

Solution: FI Consulting provided an analytical team to develop evaluation criteria, set up an application review framework and process, and provide underwriting decisioning for all non-bank lender applications received by SBA. The team provided defensible and detailed documentation of the evaluation process and review results.

FI Impact: FI provided a robust, defensible, and detailed evaluation framework to evaluate over 150 lender applications. FI developed review criteria and performance benchmarks to assess the lender’s capacity to lend, compatibility with the PPP, expected business viability, and reputational risk. The team evaluated all applications in less than 2 1/2 months and documented all results for auditability.