Small Business Administration: Additional Steps Needed to Help Ensure More Timely Disaster Assistance
Released: 2015-07-08T00:00:00

Letter

Background

Administered by SBA’s Office of Disaster Assistance (ODA), the Disaster Loan Program is the primary federal program for funding long-range recovery for nonfarm businesses that are victims of disasters and is the only form of SBA assistance not limited to small businesses.

SBA can make available several types of disaster loans, including two types of direct loans: physical disaster loans and economic injury disaster loans.

Physical disaster loans are for permanent rebuilding and replacement of uninsured or underinsured disaster-damaged property. They are available to homeowners, renters, businesses of all sizes, and nonprofit organizations. These loans are intended to repair or replace the disaster victims’ damaged property to its predisaster condition up to a certain capped amount.

Economic injury disaster loans provide small businesses that are not able to obtain credit elsewhere with necessary working capital until normal operations resume after a disaster declaration. The loans cover operating expenses the business could have paid had the disaster not occurred.

Not all businesses are eligible for both types of loans. Businesses of all sizes may apply for physical disaster loans, but only small businesses are eligible for economic injury loans.

Congress enacted the Small Business Disaster Response and Loan Improvements Act of 2008 to expand steps taken by SBA after Hurricane Katrina and require new measures to help ensure that SBA would be prepared for future disasters. The act includes three provisions requiring SBA to issue regulations to establish new guaranteed disaster programs using private-sector lenders:

Expedited Disaster Assistance Loan Program (EDALP) would provide small businesses with expedited access to short-term guaranteed loans of up to $150,000.

Immediate Disaster Assistance Program (IDAP) would provide small businesses with guaranteed bridge loans of up to $25,000 from private-sector lenders, with an SBA decision within 36 hours of a lender’s application on behalf of a borrower.

Private Disaster Assistance Program (PDAP) would make guaranteed loans available to homeowners and small businesses in an amount up to $2 million.

Timeliness of Disaster Assistance and Challenges to Address

The following section discusses the extent to which SBA met goals for timely processing of business loan applications and factors affecting timeliness; changes SBA made to address processing issues; and challenges that business organizations identified to timely receipt of assistance.

SBA Did Not Meet Its Timeliness Goal for Application Processing and Backlog Grew Rapidly

Following Hurricane Sandy, SBA did not meet its goal to process business loan applications within 21 days from receipt to loan decision. SBA took an average of 45 days for physical disaster loan applications and 38 days for economic injury applications.

The average processing time for business loans peaked in March 2013 (5 months after the storm); business loans for which SBA reached a decision in March 2013 had spent nearly 60 days being processed, on average. One year after the storm, processing times for business loan applications still exceeded 21 days.

A backlog of applications that were “in processing” (meaning SBA had not yet made a loan decision) grew rapidly over the course of SBA’s response to the disaster (see fig. 1).

SBA Did Not Anticipate Early Timing and High Volume of Applications

SBA said that in the aftermath of Hurricane Sandy, it was challenged by a high volume of loan applications submitted at a faster rate than it had experienced in previous disasters. SBA’s initial estimates of when it would receive applications differed from when it actually received them.

To prepare for a disaster, SBA uses assumptions about the volume and timing of the applications it expects to receive based on historical data— known as the “application intake curve.” These assumptions serve as inputs to forecasting models that predict the staff levels necessary to meet processing needs.

According to the application intake curve for Hurricane Sandy, SBA estimated that application submission would peak about 7–9 weeks after Sandy. However, as shown in figure 2, SBA began receiving business applications earlier. According to SBA, the early spike in applications occurred because a majority of applications were submitted electronically rather than on paper, which resulted in a large volume of applications within a few days of the disaster. SBA stated that the earlier receipt of electronic submissions was caused by the convenience and speed of the Internet-based application as well as the elimination of postal handling time. While SBA created web-based loan applications to simplify and expedite the application process and encouraged electronic submissions, SBA noted that it did not anticipate receiving such a large volume of electronic loan applications early in its response to Hurricane Sandy.

Based on its experience in fiscal year 2012, SBA initially estimated that it would receive between 11,000 and 21,600 business disaster loan applications after Sandy and 36 percent of all applications would be submitted electronically. Following Sandy, SBA received 15,745 business disaster loan applications, and 55 percent of all applications were submitted electronically.

At the time of our report, SBA had not updated its key disaster planning documents—the Disaster Preparedness and Recovery Plan and the Disaster Playbook—to adjust for the effects that a Sandy-like surge in early applications could have on staffing, resources, and forecasting models for future disasters. Federal internal control standards state that management should identify risk (with methods that can include forecasting and strategic planning) and then analyze the risks for their possible effect. According to SBA’s Preparedness and Recovery Plan, the primary goals of forecasting and modeling are to predict as accurately as possible the application volume that will result from a disaster and the timing of application receipt. Without taking its experience with early application submissions after Hurricane Sandy into account, SBA risked being unprepared for such a situation in future disaster responses, potentially resulting in delays in disbursing loan funds to disaster victims. We therefore recommended that SBA revise its disaster planning documents to anticipate the potential impact of early application submissions on staffing and resources for future disasters, as well as the risk this impact might pose for timely disaster response.

In response to our recommendation, SBA has updated its Disaster Playbook. The changes SBA made include explicit recognition of the effects that high volumes of loan applications early in the response period could have on staffing and loan processing. Our review to determine if these changes addressed our recommendation remains ongoing.

Inaccurate Processing Expectations Also Delayed Decision to Increase Staff

Another factor that affected the timeliness of disaster assistance was inaccurate expectations for application processing rates, which caused SBA to delay its decision to increase staff levels. ODA officials said the agency’s processing and disbursement center communicated inaccurate production estimates to ODA headquarters, which led to delays in increasing staff levels to respond to the early influx of applications. ODA officials said that the center’s management projected a loan officer could process an average of 3 home loan applications and 1.5 business loan applications per day, for a combined average of 2.25 disaster loan applications. However, this expectation was not met over the course of the response. Because the estimates were based on production benchmarks established after Hurricane Katrina, ODA officials noted that they relied on the estimates and delayed their decision to increase staff. ODA officials said they later recognized the past rate was not an appropriate indicator of production for Sandy due to factors including differences in the types of businesses affected and the larger number of approved applications.

As shown in figure 3, ODA ultimately added loan officers to two agency locations (Buffalo and Sacramento) after the peak months of receipts.

We reported in September 2014 that ODA told us it subsequently made several changes regarding communication with the processing and disbursement center and staffing increases. The center was required to produce a new series of daily reports for ODA headquarters to improve communication during future disasters. Specifically, these reports include more detailed information on production rates, number of applications submitted, and size of the application backlog. ODA also created a standard template for requesting and justifying additional staff that included information such as current and expected performance. At the time of our report, SBA also was determining whether it needed to add permanent loan processing staff to offices other than the processing and disbursement center to respond to disasters.

SBA Took Actions to Address Other Processing Challenges

To address challenges with providing timely assistance following Hurricane Sandy, SBA made various changes to its loan processing approach, DCMS, and loan officer training. However, as we stated in 2014, because SBA has not received a large volume of applications since Hurricane Sandy, it is too early to determine whether these changes will improve the timeliness of SBA’s response for future disasters similar in magnitude to Sandy.

Loan processing approach: SBA used to process loans in the order in which they were received, regardless of whether the applicant was a business or homeowner. After Sandy, SBA received more than four times as many home loan applications as business applications, and these home loan applications were received earlier. As a result, business owners faced delays due to the large number of home loan applications submitted ahead of them. In October 2013, SBA put in place two separate application tracks for home and business loans.

DCMS challenges: Over the course of its response, SBA encountered various challenges with DCMS, including server hardware crashes and periods of system latency (slowness and freezing), which added to some delays faced by business owners in receiving disaster assistance. In 2014, we reported that according to SBA, the agency was taking steps to improve DCMS for future disasters. For example, SBA planned to institute a process for updating system equipment (including conducting a baseline inventory and implementing a plan to replace outdated hardware). SBA officials said the inventory had been validated and the plan completed. In addition, SBA officials said the agency made improvements to its DCMS Help Desk, which responds to loan officers who experience system issues.

Loan officer training: Most of the additional processing staff, particularly in Sacramento, were new hires, but SBA found that the new officers were not effectively trained to quickly respond to the backlog of business applications. In 2014, we reported that SBA revised its loan officer training for future disasters. For instance, all loan officers had to complete a revised training course for processing business loans. SBA officials also noted that the agency reorganized loan officers into two groups that specialize in processing home and business loans based on the previously mentioned changes to the loan processing approach.

Organizations Identified Challenges Businesses Faced in Receiving Timely Assistance

Select Small Business Development Centers and local business organizations in New York and New Jersey with which we met in 2014 identified two main challenges (from the perspective of small businesses) that affected the timeliness of assistance: time-consuming loan documentation requirements and lack of SBA follow-up. We reported on steps SBA said it would take to address these two challenges.

Nearly all 14 development centers and local business organizations noted that meeting documentation requirements for applications was time- consuming and onerous to business owners. SBA officials said that the agency was taking several steps to streamline the documentation requirements for applicants. Specifically, SBA examined the entire loan application process to identify and eliminate documents that did not help loan officers make a decision on an application. According to SBA officials, the proposed changes to the required documentation were drafted and would be incorporated by the end of 2014 in the disaster loan program’s standard operating procedures. Furthermore, SBA took steps to reduce documentation requirements for applicants with strong credit scores by amending regulations to allow the agency to rely on credit scoring rather than cash flow when determining an applicant’s ability to repay.

More than half of the entities with which we met said that business owners noted a lack of SBA contact after submitting their applications, and many owners were unaware of the status of their application throughout the process, including whether or not it had been received at the processing center. Additionally, five entities noted a lack of continuity with loan officers or case managers over the course of the application process. Two of these five entities said that some business owners had had up to eight different loan officers or case managers. In addition, these five entities reported that submitted documentation and information were lost when loan officers and case managers changed.

According to SBA officials, due to the physical damage caused by Hurricane Sandy, it was difficult for loan officers and case managers to contact applicants by telephone or e-mail despite their efforts. SBA officials told us that an applicant might have more than one loan officer or case manager for several reasons, such as when application numbers increased or if current loan officers or case managers had to supervise newer staff. SBA officials also told us that some documents could be misplaced due to the multiple ways applicants could submit information to the processing and disbursement center. In addition, some documents may not have been misplaced; rather, they may not yet have been entered into DCMS and thus were unavailable for loan officers to view.

According to SBA officials in 2014, efforts to process electronic application submissions more effectively would address these issues. The officials said SBA expected to create an electronic portal that would share information with applicants on the status of their applications and documents received, thus increasing transparency and communication during the loan application process.

Loan Approval, Withdrawal, and Cancellation Rates in Selected Disasters

As explained previously, for our 2014 report we compared SBA’s approval, withdrawal, and cancellation rates for business loans after selected disasters. In comparison with the other disasters, the approval rate after Sandy was not consistently higher or lower, but withdrawal and cancellation rates were consistently higher.

Approval rates. The approval rate for business loan applications for Hurricane Sandy (42 percent) was lower than for Hurricanes Katrina, Rita, and Wilma, higher than for Hurricane Ike, and comparable to the rate for Hurricane Irene. However, when taking home loan applications into account, Sandy resulted in the highest total approval rate (53 percent) in comparison to the five other disasters.

The primary reasons for which SBA declined business loan applications after each of the disasters remained the same: lack of repayment ability and unsatisfactory credit history. Following Hurricane Sandy, SBA received 14,938 business loan applications and declined 5,663 as of January 31, 2014. Of the declined applications, SBA cited lack of repayment ability as at least one of the reasons on 2,644 applications (47 percent), and unsatisfactory credit history as at least one of the reasons on 2,317 applications (41 percent).

Withdrawals. Application withdrawal rates were higher after Sandy than after the other disasters. Of the 14,558 original business loan applications that had reached a decision status by January 31, 2014, 4,715 (approximately 32 percent) had been withdrawn by SBA or the applicant. The withdrawal rates for the previous disasters ranged from approximately 18 percent (Ike) to approximately 23 percent (Katrina and Wilma). For Hurricane Sandy, SBA withdrew approximately 60 percent of the 4,715 applications, while applicants requested withdrawal for the remaining 40 percent. The 60 percent figure for SBA-initiated withdrawals was higher than for two of the other disasters and lower for three. The leading reason for withdrawals after Sandy was the applicant’s failure to provide SBA with all requested information (1,542 withdrawals or approximately 33 percent of all withdrawn applications).

Cancellations. Of the 4,180 business loan applications SBA approved for Hurricane Sandy, 1,578 (38 percent) had been cancelled as of January 31, 2014—a rate higher than for the other disasters. The other cancellation rates ranged from approximately 22 percent (Wilma) to approximately 30 percent (Ike and Katrina). Of the business loans cancelled after Hurricane Sandy, borrowers requested cancellation of 1,171 loans (74 percent), while SBA cancelled 407 (26 percent). The most common reason for SBA-initiated cancellations was “failure to complete and return all loan closing documents,” representing 336 cancellations (21 percent).

According to SBA, factors affecting the withdrawal and cancellation rates for Hurricane Sandy included higher rates of insurance coverage in the footprint of the disaster area and the availability of alternative sources of recovery aid (such as grants). Officials told us that the rollout of programs funded by the Department of Housing and Urban Development’s Community Development Block Grant program began earlier than in past disasters, and that state grantees—specifically New Jersey and New York—obtained those funds and accepted applications for their respective state grant programs shortly after the disaster struck.

Half of the entities with which we spoke—selected business development centers and local business organizations in New Jersey and New York— provided perspectives on the most common reasons why applications were withdrawn after Sandy. For instance, business owners commonly withdrew applications because they had changed their plans for funding their recovery (for example, they may have received insurance claim proceeds or state grants). Entities also noted other reasons, such as frustration with waiting times for loan processing and a desire not to incur additional debt.

SBA Has Not Implemented Three Guaranteed Disaster Loan Programs Required by Law

In 2014 we reported that 6 years after Congress passed the Small Business Disaster Response and Loan Improvements Act of 2008, SBA had not piloted or implemented three guaranteed disaster loan programs, which therefore had not been available after Hurricane Sandy. As previously discussed, the act mandated the creation of the Immediate Disaster Assistance Program (IDAP), the Expedited Disaster Assistance Loan Program (EDALP), and the Private Disaster Assistance Program (PDAP). According to SBA officials, the agency opted to implement IDAP first, because the loan limit was lower than in the other two programs and SBA received appropriations to pilot this program.

We had examined SBA’s implementation plans before 2014. In a July 2009 report, we noted that SBA was planning to implement requirements of the 2008 act, including pilot programs for IDAP and EDALP. SBA requested funding to carry out requirements for the two programs in the President’s budget for fiscal year 2010 and received subsidy and administrative cost funding of $3 million in the 2010 appropriation, which would have allowed the agency to pilot about 600 loans under IDAP. The agency issued regulations for IDAP in October 2010. In May 2010, SBA told us that its goal was to have the pilot for IDAP in place by September 2010. We concluded that because the implementation process already was behind schedule, it would be important for SBA to ensure it had a plan to implement remaining requirements of the 2008 act and report on its progress to Congress. We therefore recommended that SBA develop an implementation plan and report to Congress on progress in addressing all requirements within the act and include milestone dates for completing implementation and any major program, resource, or other challenges the agency faced.

However, as of August 2014, the pilot program for IDAP had not yet started. According to SBA officials, the program had not been implemented for two primary reasons: (1) information technology challenges and (2) feedback from lenders indicating that program requirements might hinder lender participation.

First, the electronic systems that would be used to process IDAP applications did not interface smoothly. According to SBA officials, IDAP’s readiness was in part based on the ability of E-Tran, the loan processing system for the 7(a) program, to interface with DCMS, the loan processing system for the Disaster Loan Program. Officials said that a new information technology system was being developed—SBA One. They also said that for IDAP application processing, it would be more efficient to make DCMS interoperable with the new system than to enhance E-Tran. At the time of our 2014 report, SBA anticipated that SBA One would be operational by early 2015.

Second, SBA told us that it received feedback from lenders on challenges that could discourage lenders from participating in the program, but documentation of the feedback was limited. In March 2010, SBA organized a forum with 11 lenders in the Gulf Coast to obtain their views on IDAP. Lenders stated the program had to have a simple eligibility determination and confirmation that a potential borrower had applied for an SBA disaster loan before the lender would approve an IDAP loan. Lenders also expressed concerns about the possibility of guarantee denials if an applicant did not take out an SBA disaster loan. According to SBA, in 2010 the agency also conducted conference calls with Iowa lenders who expressed similar concerns about IDAP. However, SBA did not document either the Gulf Coast forum or the conference calls at the time of the events. Instead, SBA officials relied on the memory of staff present for these discussions. In response to our request for information on these efforts, in July 2014 SBA provided a one-page summary. The summary included a list of the Gulf Coast lenders but not of Iowa lenders, and the discussion of lenders’ concerns was minimal.

In addition, according to SBA officials, in November 2012 the agency solicited informal feedback from lenders in Hurricane Sandy-affected areas about the usefulness of IDAP and its features. According to SBA officials, lenders were concerned about the statutory requirement that provides an applicant a minimum of 10 years to repay the IDAP loan if a loan through the Disaster Loan Program was not approved. Lenders expressed disinterest in servicing a small loan amount (up to $25,000) for a term that long. SBA officials noted that lenders typically did not offer small-dollar loans such as those made under IDAP. SBA’s IDAP regulations allow a lender to charge a borrower an optional application fee to recoup some of the loan processing costs, but the one-time fee may not exceed $250 and an IDAP lender generally may not charge a borrower any additional fees. According to SBA officials, they also did not document lender feedback from this outreach effort. SBA officials told us that they obtained feedback on IDAP requirements from three banks, although officials could recall the identity of only one bank.

In July 2014, SBA officials told us that the agency was still trying to conduct the IDAP pilot by attempting to identify solutions to increase lender participation. However, officials noted that the lenders with which they met were not willing to participate in IDAP (or an IDAP pilot) without changes to the statutory servicing term and the SBA regulatory fee. Based on lender feedback, SBA officials said that the current statutory requirements, such as the 10-year loan term, made a product like IDAP undesirable and that lenders were not likely to participate in IDAP unless the loan term were decreased to 5 or 7 years, for example. Congressional action would be required to revise statutory requirements, but SBA officials said they had not discussed the lender feedback with Congress. SBA officials also told us the agency planned to use IDAP as a guide to develop EDALP and PDAP, and until challenges with IDAP were resolved, did not plan to implement these two programs.

As a result of not documenting, analyzing, or communicating lender feedback, SBA might have lacked reliable information to guide its own actions and to share with Congress about what requirements should be revised to encourage lender participation. Such information could be obtained by conducting further outreach to lenders and documenting this outreach in accordance with federal internal control standards, which state that all transactions and other significant events should be promptly recorded to maintain their relevance and value to management in controlling operations and making decisions. We concluded that not sharing information with Congress on challenges to implementing IDAP might perpetuate the difficulties SBA faced in implementing programs intended to provide assistance to disaster victims. Therefore, in September 2014, we recommended that SBA conduct a formal documented evaluation of lenders’ feedback to inform both itself and Congress about implementation challenges and about statutory changes that might be necessary to encourage lenders’ participation in IDAP, and then report to Congress on the challenges SBA faced in implementing IDAP and on statutory changes that might be necessary to facilitate implementation.

SBA officials recently provided us with a two-page summary of a discussion conducted with 23 lender and service provider participants in SBA’s 7(a) program—17 bank lenders, 3 certified development companies, and 3 lender service providers—at a National Association of Government Guaranteed Lenders conference in October 2014. Participants were provided general information on IDAP, and were asked to comment on specific statutory and regulatory requirements related to loan terms, maximum allowable interest rates, and restrictions on lender- imposed application fees. According to SBA’s summary, participants expressed unwillingness to participate in a program with these requirements. While SBA thus has taken one step to solicit and document lender feedback, it has not adopted a plan for the steps the agency will take to implement IDAP (and by implication, the other two loan programs) or to reach a determination on whether IDAP or the other loan programs should be implemented.

Chairman Chabot and Ranking Member Velázquez, this concludes my prepared statement. I would be happy to answer any questions at this time.

GAO Contacts and Staff Acknowledgments

For further information on this testimony, please contact William B. Shear at (202) 512-8678 or shearw@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this statement. GAO staff who made key contributions to this testimony are Marshall Hamlett (Assistant Director), Vaughn Baltzly (analyst-in- charge), John McGrail, and Barbara Roesmann.

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