CBA Letter to SBA on COVID-19 Emergency Small Business Lending Measures

March 28, 2020

Administrator Jovita Carranza
Small Business Administration
409 Third Street, SW
Washington, D.C.


RE: COVID 19 - Emergency Small Business Lending Measures


Dear Administrator Carranza:

America’s small businesses, and the millions of men and women who work at them, are the foundations of communities across the country. These businesses and their employees now face immediate economic threats related to the COVID-19 pandemic.


Of the 100 most active Small Business Administration 7(a) lenders, members of the Consumer Bankers Association make the majority of the total volume. Our members are ready to do everything humanly possible to support U.S. small businesses and would like to express support for the SBA’s immediate efforts to implement small business assistance provisions in the Coronavirus Aid, Relief, and Economic Security (CARES) Act.

We do, however, have concerns that without proper implementation of these expanded programs, banks will be hard-pressed to deliver the volume of assistance necessary in a timely manner.


To help address this concern and ensure banks can serve small businesses across the country, CBA urges the SBA to implement, to the extent possibly, a fully digital process. This would eliminate the collection of documents, the validation of borrower circumstances, and would leverage the existing bank systems in place for loan origination and data tracking – all critical considering the current circumstances.


Without these provisions and removing burdensome requirements, assistance will be unnecessarily delayed and American workers could face lengthy delays in receiving paychecks.


In order to help SBA implement a seamless system for the new stimulus provisions, CBA submits the following recommendations for your immediate consideration. We believe these are threshold issues that will need to be addressed prior to effective funding from the CARES Act.


We look forward to working with the SBA on this critical issue.



Richard Hunt
President and CEO
Consumer Bankers Association