More SBA SOP Revisions – Effective November 2023

by | Dec 6, 2023 | Guides, SBA

Earlier this year, the US Small Business Administration (SBA) released the updated Standard Operating Procedure 50 10 7, effective August 1, 2023. Subsequently, a further refinement, referred to as SOP 50 10 7.1, was issued, becoming effective on November 15, 2023.

As a quick recap, SOP 50 10 7 introduced several key changes, including:
• Additional guidance regarding applicability of the Environmental Policies and Procedures
• Additional requirements for Child Occupied Facilities
• References to the updated ASTM standards for Phase I Environmental Site Assessments (ASTM E 1527-21) and Transaction Screen Reports (ASTM E 1528-22)
• Modifications to NAICS codes concerning Gasoline Stations and Fuel Vendors
• A clarification on the types of Food Manufacturing facilities that are considered environmentally sensitive

Building upon these updates, SOP 50 10 7.1 presents further clarifications. These are the key changes:
• The database records and “historical records search” are now required to be appended to the Transaction Screen Assessment report.
• Under Mitigating Factors – Contamination Originating from Another Site – has been modified to remove specific reference to groundwater. Therefore, any type of contamination should be considered under this mitigating factor.
• Under the “Release of Rights to Indemnification from SBA/Lender for 504 loans,” the revised SOP clarifies that local SBA counsel would conduct the review and approval of the waiver and release documents submitted to the SBA processing center.

The updated SBA SOP can be found here.

Should you require support with your environmental due diligence, please don’t hesitate to reach out to us today! We’re here to assist you.