Challenge
A top 100 SBA lender (by dollar volume) received its first OCRM onsite audit notification and document request list — just three weeks before the examination start date. The OCRM “full review” audit request included strategic documentation such as projections, strategic plans and process documentation, as well as loan-specific requests for more than 70% of the loans the lender had funded since program inception.
Solution
As a Windsor Advantage client since 2011, the lender had already implemented risk-focused SBA lending best practice recommendations across all processes — starting with strategy and risk assessment. All of the documentation requested by OCRM, from strategic plans to process-based requests and loan-specific files, was readily available electronically and organized for submission.
Documentation readiness included:
- SBA department strategic plan. Since defining the lender’s unique SBA strategy is the first step in Windsor’s risk assessment process, the lender had already answered and documented the four key questions for formulating a comprehensive risk-focused strategy. Many of the documents requested by OCRM had been prepared by the bank during the risk-assessment process.
- Policies and procedures. The bank was equipped with detailed and consistent policies and procedures for credit risk, operational risk and regulatory risk.
- Internal controls. As part of the implementation of Windsor’s services, the lender had completed a comprehensive risk assessment, including the design and implementation of preventative and detective controls to ensure the quality of the processes.
- LSP oversight. Lender Service Provider (LSP) oversight documentation was included within the design and implementation of the preventative and detective controls.
- Loan files. Complete, consistent, well-structured files for each loan were available electronically and already consistently organized for submission.
Results
- Compliant documentation and files uploaded in a secure manner within 24 hours of request
- Minimal documentation deficiencies identified, resulting in a successful examination
- Credit memo “best practice” suggestions by OCRM implemented immediately due to strategic SBA lending processes with a focus on constant improvement already in place
- Immediate audit readiness illustrated lender dedication to the SBA program integrity
- Turned potentially stressful examination into ongoing learning opportunity to improve lender’s SBA business through best practices