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SBA 7(a) Lender Fee Navigator
A visual guide to understanding the Annual Service Fee based on SOP 50 57 3.1.
Foundational Principles
It's a Guaranty Fee
Think of it as an insurance premium. The fee is the price the lender pays to keep the SBA's loan guaranty active, not a charge for servicing activities.
It's a Lender Obligation
The SOP is clear: this fee is a direct, non-negotiable debt owed by the lender to the SBA. It cannot be passed on to the borrower.
The Fee Lifecycle
Loan Disbursement
The clock starts. Fee accrual begins as soon as the loan is funded.
In Liquidation
The clock keeps ticking. The guaranty is still active, so the fee continues to accrue throughout the liquidation process.
The End of the Line: Accrual Ceases
Fee accrual only stops when one of two specific events occurs:
Path A: Guaranty Purchase
The SBA buys its portion. Accrued fees are automatically deducted from the lender's payout. The books are closed.
Path B: Voluntary Termination
The lender cancels the guaranty. Future accrual stops, but all fees accrued up to this point become a payable debt.
Scenario Explorer
Fee Status: ACCRUING
Placing a loan in liquidation does not stop the fee. It is a required step *before* a guaranty purchase can be requested. The guaranty remains active, and so does the fee obligation, until the purchase is complete.
"Payable to SBA until such time that SBA purchases the guaranty." - SOP 50 57 3.1
The NGPC vs. Little Rock Discrepancy
The different treatment you experienced is not a policy conflict. The SOP is a single national standard. The discrepancy likely stems from administrative factors:
Enforcement Gap
NGPC, as the national center, likely has more rigorous enforcement. The charge you received is probably the correct application of the rule, while past experiences may have been an oversight.
Different Paths
You may be comparing apples and oranges. Fees for purchased loans are settled automatically from the payout (no invoice), while terminated loans require a separate collection action (an invoice).
Admin Error
It's possible that a regional center's historical process simply missed the step of billing for accrued fees on terminated loans—an error a specialized center like NGPC is designed to prevent.
Strategic Recommendations
Arguing that the fee is invalid is a losing battle against the SOP. Instead, formally acknowledge the rule and state your intent to conduct an internal audit to verify the SBA's calculation. This reframes the dispute to be about numbers, not policy.
For each loan in the $200,000 assessment, calculate the precise accrual period: from the day after the last paid-through date to the official date of termination. Your argument must be focused on factual accuracy, e.g., "Our audit shows an accrual period of 365 days, but your invoice is for 450 days."
Use your past experience as a point of inquiry, not a legal defense. Frame it as seeking to align your procedures with national standards. This positions you as a cooperative partner, which is more likely to lead to a productive dialogue and potential resolution.
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