ERI has revised its SBA Flowchart to reflect the current SBA SOP (SOP 50 10 6, Oct. 1, 2020). If you would like to replace your existing ERI SBA flowchart with an updated version, we will be glad to send you the one below.
In addition to providing the level of environmental due diligence required by the SBA, the flowchart includes an updated list of industries identified as “Environmentally Sensitive,” as well as the following helpful tips.
1. The Environmental Professional completing the Transaction Screen Assessment, Phase I ESA or Phase II ESA must provide a Reliance Letter and a Certificate demonstrating Professional Liability Insurance coverage.
2. The Reliance Letter is not to be altered or modified from the SBA template.
3. The date of the environmental assessment must be within the coverage period noted on the Certificate of Insurance.
4. A lead risk assessment and testing for lead in drinking water are required for properties that will be occupied by childcare centers, nursery schools or residential facilities occupied by children that were constructed prior to 1978.
5. A Phase II Subsurface Investigation, in addition to the Phase I ESA, is required for all properties with current or former dry cleaners that have used chlorinated and/or petroleum solvents onsite.
6. In cases where the property owner or operator will not sign the Environmental Questionnaire, a Transaction Screen Assessment is the minimum level of due diligence required.
7. For carwash-only facilities, a Transaction Screen Assessment is the minimum level of due diligence required. 8. In situations where the bank has environmental policies and procedures that are different than the SBA due diligence requirements noted above, then the more stringent of the two policies must be followed
Request a Copy of ERI’s SBA Flowchart
About Environmental Risk Innovations (ERI)
ERI is the nation’s largest environmental risk consulting firm, specializing in the management of environmental risk for commercial lenders. ERI’s clients include a broad base of commercial lenders, from regional banks to banks with national footprints. ERI provides third-party review of environmental assessment reports and conducts Records Search with Risk Assessments (RSRAs)/desktop reviews on commercial properties. ERI’s third party reviews of environmental assessments and property regulatory/historical data are accompanied by free “day to day” technical support to commercial loan officers and bank risk managers, as well as complimentary assistance in developing/amending environmental risk management policy based on our client banks’ specific risk tolerance. ERI is not a traditional environmental consulting firm that performs Phase I or Phase II Environmental Site Assessments. As a result, ERI’s recommendations represent a truly independent, third party opinion that conforms to the client bank’s specific risk tolerance. For more information on ERI’s environmental consulting expertise, please contact Karen Nelson at [email protected] or 704.237.8134 or Greg Lathan at [email protected] or 919.657.7500.