- Before
- Fields 25–40 rule questions a week from six officers, each one a search through the SOP, the notices and the bank's policy.
- Now
- Reads a cited answer under the right edition, checked against the term sheet, and confirms it — “I don’t need the rule. I need the rule that applies to this loan.”
One seller note, one file, from question to the loan file
Monday 12 October 2026 at Harrow Creek Bank. Cedar Hollow Animal Hospital, SB-26-0418, opened in September under the old SOP and goes to SBA on Wednesday. Here is what happens, screen by screen, in the working solution.
- 01Monday morning
One question, one loan, one date
Renee Alvarado · Senior SBA underwriterRenee's screen is not a dashboard. It is the question, the loan and the date that decides its rules: every SBA edition since November 2023 as a band on a time axis, with Cedar Hollow pinned at 14 Oct 2026 and Larkspur at 12 Mar 2024. Red lines mark where the equity injection rule changed. Three questions are waiting for her.
“1 Oct 2026 · Never reduced for an initial acquisition; passive equity joins the 50% cap”
- 029.1 seconds
Does the $320,000 seller note count toward the 10%?
Dana Whitfield · SBA business development officerUnder SOP 50 10 8.1, in force on the loan's date, it counts $0: the note is on payments deferred 24 months, then amortizing — not standby for the life of the loan. The buyer's $345,000 cash is 10.0% of the $3,450,000 project, so it meets the 10% alone, with nothing to spare. Beside the answer sits the SOP page, Appendix 15, ¶ B, page 514, with the operative paragraph highlighted.
“$0 of the seller note counts · Meets the 10% · under the rules in force on 14 Oct 2026”
- 03Date moved to 2023
Slide the date, and the answer rewrites
Renee Alvarado · Senior SBA underwriterRenee jumps the date to 1 Dec 2023. Under SOP 50 10 7.1 a seller note on full standby for 24 months counted for up to half the required injection, so $172,500 of the same note would have counted. The page beside it switches to the 7.1 paragraph, with a margin note: replaced 1 Jun 2025.
The strip marks it “Not Cedar Hollow’s loan date”, so nobody mistakes the old answer for the current one.
- 04Guaranty purchase
Larkspur, judged by the rules of its own date
Renee Alvarado · Senior SBA underwriterLarkspur Dental Lab, SB-24-0112, was numbered on 12 March 2024 and is now in an SBA guaranty purchase review. As of that date $59,000 of its seller note counted and the injection was $118,000, exactly 10%. Under every later edition it reads short of the 10%. Renee saves the dated answer to Larkspur's file, with the date, the edition and every clause.
“Saved to Larkspur Dental Lab’s file · as of 12 Mar 2024 · SOP 50 10 7.1”
- 05Today 07:52
“Does the deal still work as I wrote it?”
Dana Whitfield · SBA business development officerDana's real question is the whole file. On Check a file the loan's date is settled first: SB-26-0418 has no SBA loan number yet and goes to SBA on Wed 14 Oct, so it will be numbered after 1 Oct 2026 and SOP 50 10 8.1 governs. Then each step runs in view — the rules picked, 1,214 clauses searched across 9 sources, the answer written, the file checked.
“Compared with the version Dana assumed · SOP 50 10 8 → 8.1 · 3 changes touch this deal”
- 06Answered in 9 s
Three issues, every sentence cited
Answer writerOwnership is not eligible as written: Dr. Tomas Ferreira holds 15% as a permanent resident, and a permanent resident may now own no interest. A quality of earnings report is required at a $3,200,000 purchase price, and the seller's CPA review does not count. Coverage is 1.19x against a 1.25x minimum. The bank's own SBA Credit Policy still says 1.20x; SBA's 1.25x is stricter and governs, so the policy is flagged for update.
Marked “Changes the term sheet”, so it goes to an underwriter before it goes anywhere else.
- 07Same answer
Checked against the term sheet, with the arithmetic
File checkerFive checks against Dana's term sheet of 18 Sep, each with the rule in force on 14 Oct 2026 beside the file's figures. Coverage: $565,000 ÷ ($432,447 + $40,729) = 1.19x, because a seller note not on full standby is now counted. Equity injection 10.0% and the 10-year maturity pass.
The file checker never changes the file and never decides eligibility — an underwriter confirms.
- 08Confirmed
Confirmed, saved to the loan file, sent
Renee Alvarado · Senior SBA underwriterRenee confirms the answer and attaches it to SB-26-0418 with its 13 citations, the version and the governing date, and tells Dana and Kofi Mensah, the closer. The loan file now lists three things to clear before submission: remove Dr. Ferreira's 15%, commission a quality of earnings report, and put the seller note on full standby — coverage 1.19x → 1.31x.
- 09The Thursday before
Every change, and every file it touches
Marcus Bell · SBA Lending ManagerMarcus asked at 10:30 how many files cross into 8.1. What changed puts SOP 50 10 8 beside 8.1 topic by topic — coverage 1.15x to 1.25x, seller notes in coverage, quality of earnings at $3 million, 7(a) Small closed to changes of ownership — with the pipeline files each one touches. Eight files cross into 8.1; four need a change.
- 10This week
A record an examiner can read
Ellen Cho · Compliance officerEvery question is in the log: who asked, the loan, the version that answered, the clauses cited, the time and who confirmed it — 146 this week, a 9-second median to a cited answer. Where no clause stands behind an answer, it goes to a person, never a guess.
“Kept for the life of the loan, ready for an SBA review or an examiner.”