COVID-19 & Cares Act Data Reporting

1) Coding for COVID-19 impacted loans:

Reporting of existing accounts/borrowers which are designated by the contributor as being impacted by the COVID-19 pandemic (or other future natural/declared disasters):

• Members are encouraged to continue contributing all small business credit accounts and use the following account status codes to denote an account/borrower has current impact:

• 020 - Business Affected by Natural/Declared Disaster: This would be the code most appropriately used at this time. It notes that a small business borrower has been affected by this crisis and/or requested relief during this crisis.

• If a deferment has been approved by your institution or as a result of the Small Business Debt Relief Program, we advise including an account status code of 019 - Payment Deferred, if adding a second code is possible in your contribution file.  If your institution can report only one code, SBFE suggests using code 020.

• 021 - Reporting Suspended Due to Natural/Declared Disaster: This would only be used in rare instances where the lender felt they could not report account information due to system or other failures at the lending institution or where the true information or status of a small business borrower cannot be represented, such as due to total loss of a business’ location during a natural disaster. If using this code, the expectation would be that payment elements would not be reported for this account. This code may also be utilized to communicate that this will be the last time this account will be reported, at least for some length of time.

• If Members are unable to contribute codes 020 and 021 as part of their submission files, they can contact the SBFE Data Warehouse (dwsupport@sbfe.net) to discuss their options.
• Members, when making decisions on how to report accounts, should consider the potentially negative effect of reporting derogatory information (without using a disaster code) on small business customers during this unprecedented time.

2) Coding for Paycheck Protection Program loans:

• Account Type of 001 (Term Loan)
• Government Guarantee Flag set to ‘Y’ (Yes)
• Government Guarantee Category coded as ‘600’ (SBA PPP)
• Portion of Account Guaranteed by Government set to 100 (%)
  NOTE: SBFE encourages Members to consider the impact that these types of loans will have in their risk management solutions and have discussions with their Certified Vendors to ensure these are treated as they would intend.  

3) Changes to SBFE’s data processing in response to COVID-19:

• SBFE and the SBFE Data Warehouse will monitor submissions received in the upcoming months to detect unexpected changes to Member contributions.  If detected, SBFE will contact those Members and determine if the changes were intended and/or if they would like to have the SBFE Data Warehouse assist them in modifying how their contributions are loaded to most accurately represent current status of accounts/borrowers.
• Beginning in early May, the SBFE Data Warehouse will hold all submissions for a limited time to perform enhanced review to identify any shifts in reporting. SBFE will strive to limit delays in release of contributed data to Certified Vendors.