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Important SOP Revisions Affecting 504 Lending

Mar 2009

Effective March 1, 2009, the Small Business Administration (SBA) put in place its first update to SOP 50 10(5) - now known as 50 10 5(A) - for lender and certified development company (CDC) loan programs, including the 504 program. Future updates are expected every six months going forward.

Please note that the SBA is posting the revised SOP in two versions. The first version will show all changes as “tracked changes” to enable users to more easily identify what has been modified. (As a note, the Table of Contents has been updated but, for ease of viewing, those changes are not shown.) The second version incorporates all of the changes into the document.

List of Significant Changes Due to SBA Additions to SOP 50 10 5 (A):

• Loan loss reserve fund change - page 69
• New business - page 237
• Definition of passive business change - page 254
• 912 procedure changes - pages 258, 261 and 267
• Legal permanent resident - page 267
• EPC/OC lease with new provisions for EPC rights to mineral lease - page 269
• Additional public policy goals - page 272
• Eligible project costs - page 273-274
• Residential space - page 275
• Reducing ownership interest - page 277
• ESOP or 401(k) plans - page 278
• Construction projects requirement of as-completed appraisal - page 279
• Disbursement period - page 290
• PCLP waiver of flood insurance for non-project collateral - page 292
• Tax transcripts - page 294
• No adverse change - page 300
• Complete file review - page 302
• Form 159 requirements - page 309
• vAppendix 3: reliance letter
• Environmentally sensitive NAICS codes list revised - page 324
• Appendix 5: requirements for gas station loans- page 326

For more information on Florida First Capital and its 504 loan program, visit www.ffcfc.com, email us at insider@ffcfc.com or call 888.320.5504.