Chapter
THE SENATE-PASSED VERSION OF THE SBLF
ARGUMENTS FOR AND AGAINST THE SBLF
THE SBLF’S IMPLEMENTATION
Treasury’s Roll Out of the Program
Small Business Lending Progress Reports
Chapter 2 SMALL BUSINESS LENDING FUND: USE OF FUNDS REPORTS
BACKGROUND AND METHODOLOGY
Definition of Small Business Lending
Changes in Small Business Lending
Definition of Business Lending
Changes in Business Lending
Non‐SBLF Bank Comparison Group
INCREASES IN SMALL BUSINESS LENDING OVER BASELINE LEVELS
COMPARISON OF LENDING BY SBLF BANKS AND NON‐SBLF BANKS
Overall Increases in Business Lending and Other LendingComparing the level of loans outstanding as of December 31, 2011 to their
Overall Increases in Business Lending and Other Lending
Distribution of Increases in Business Lending
Increases in Business Lending by Regional Geography
Increases in Business Lending by Institution Size
Increases in Business Lending by Loan Category
LENDING BY FORMERCAPITAL PURCHASEPROGRAM (CPP) PARTICIPANTS
Lending Increases by Institutions that RefinancedCPP Investments
Dividend Rates Payable by Institutions that RefinancedCPP Investments
Chapter 3SMALL BUSINESS LENDING FUND: ADDITIONAL ACTIONS NEEDED TO IMPROVE TRANSPARENCY AND ACCOUNTABILITY
SBLF Goals, Considerations, and Eligibility Requirements
SBLF Application Process and Requirements
SBLF Funding and Incentives for Small Business Lending
TREASURY’S APPLICATION REQUIREMENTS AND DECISIONS WERE NOT ALWAYS TRANSPARENT
Treasury’s Review Process Required Additional Steps to Evaluate Some Applicants
Time to Review Applications Was Affected by Implementation Challenges and Funding Deadline
Lack of Clarity about Program Requirements and Transparency of Some Decisions Created Confusion
Program Requirements and Dividend Restrictions
CHARACTERISTICS OF APPLICANTS AND PARTICIPANTS AND FACTORS AFFECTING SBLF PARTICIPATION
Comparison of SBLF Applicants and Banks to Non-SBLFPeer Banks
Banks Frequently Cited Lack of Demand as the Most Important Reason for Not Applying to the Program
TREASURY HAS NOT FINALIZED PLANS TO MONITOR SBLF PARTICIPANTS OR TRACK SBLF’S IMPACT
Credit Conditions Remain Challenging for Small Businesses
Treasury Has Not Finalized Plans for Monitoring SBLF Participants and the Program’s Impact Because Focus Has Been on Implementation
RECOMMENDATIONS FOR EXECUTIVE ACTION
AGENCY COMMENTS AND OUR EVALUATION
APPENDIX I.OBJECTIVES, SCOPE, AND METHODOLOGY
APPENDIX II. RESPONSES TO QUESTIONS FROM GAO’S SURVEY ON THE SBLF PROGRAM
Chapter 4 SMALL BUSINESS LENDING FUND: INVESTMENT DECISION PROCESS FOR THE SMALL BUSINESS LENDING FUND
SMALL BUSINESS LENDING FUND
Investment Decision Process
Initial Eligibility Check
FBA Supervisory Consultation
State Banking Regulator Review
Application Review Committee
Treasury Application Review
SBLF Investment Committee Recommendation
Final Investment Decision Approval
THE PROGRAM TARGETS INSTITUTIONS WITH ADEQUATE CAPITAL FOR LENDING AND REPAYMENT, BUT SMALL BUSINESS LENDING POTENTIAL WILL NOT BEFULLY ASSESSED
Capitally-Impaired Banks Are Ineligible for the Program
Potential for Growth in Small Business Lending Will Not be Fully Assessed
SBA LENDING HISTORY WILL NOT BE CONSIDERED
OTHER OPPORTUNITIES FOR IMPROVEMENTS
Supervisory Consultation Memo Does Not Require thorough Disclosure
Criteria for Determining Whether Matching Funds Will be Required Has Not Been Defined
The Non-Cumulative Treatment of Dividends May Result in Institutions Not Fully Paying Dividends Owed on Treasury’s Investment
MATTER FOR CONGRESSIONAL CONSIDERATION
APPENDIX 1.OBJECTIVES, SCOPE, AND METHODOLOGY
APPENDIX 2. COMPARISON OF TARP – CPP/CDCI AND SBLF