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COLEMAN: Small Business Lender News of the Day for Tuesday, October 14, 2025

Michigan Business Network: Coleman Report

SBA Hot Topic Tuesday: SBA Fraud and the Lender

by Bob Coleman

Founder & Publisher

This week’s Hot Topic Tuesday highlights a timely and growing concern in the SBA lending community: the rise of AI-generated fraud. With artificial intelligence tools now capable of producing convincing fake financial documents in seconds, lenders face new challenges in verifying authenticity and protecting the SBA program’s integrity.

 

In last week’s Coleman webinar Lance Sexton, Executive Vice President at Phoenix Lender Services and former SBA Deputy Director answered the following questions.

Q: Has there been an uptick in fraudulent documents being used, especially with the ease of generating them through AI?

Lance Sexton: That’s a great question — and absolutely, yes. When I first started in SBA lending back in 1983, everything was done on paper. I once received a business plan written in pencil on a Big Chief tablet. Projections were done the same way, and we physically carried stacks of documentation to the SBA.

Back then, it was much harder to falsify anything. Today, with the rise of AI tools and online resources, creating realistic fraudulent documents has become incredibly easy. We are seeing a clear uptick in fake tax returns, altered bank statements, and fabricated financials being presented in SBA loan files.

Q: What specific red flags should make a lender stop processing a loan immediately, rather than just asking for more information?

Lance Sexton: I always encourage lenders to ask for clarification when something seems questionable — but if a document is obviously fake, that’s when you stop the loan in its tracks. Don’t try to reconcile it or move forward; report it immediately to the SBA Office of Inspector General. Clear falsification is a hard stop.

Q: What are the penalties for lenders if they fail to report fraud?

Lance Sexton: As of now, I’m not aware of specific penalties for failing to report fraud. However, fraud has become a major focus of the SBA’s Office of Inspector General, so I wouldn’t be surprised if formal penalties or enforcement actions are introduced in the near future. Even without explicit penalties, not reporting suspected fraud puts a lender’s SBA guaranty — and reputation — at risk.

Q: When we’re provided with a check or bank statement that looks altered, what’s the best way to confirm if it’s authentic?

Lance Sexton: The best step is to contact the bank directly. You don’t need to ask for confidential details; simply verify whether the person or business actually holds an account there.

During PPP, I discovered a fraudulent bank statement myself. Borrowers had to prove they were in business before February 15, 2020. One applicant submitted a fake bank statement. I copied the routing number from the document and searched it on Google — it didn’t match the bank name on the statement. That’s how I confirmed it was fraudulent.

So, either make a phone call to the bank or do an online check to confirm the routing number and institution. It’s a quick step that can prevent your institution from funding a fraudulent loan.

Q: Any final advice for lenders on preventing or reporting SBA loan fraud?

Lance Sexton: Fraud awareness is essential. I work for a company that processed about 300,000 PPP loans, and I didn’t realize how extensive fraud could be until that experience. We’re still, even now, responding to subpoenas from federal agencies related to those loans.

Fraud also occurs in standard 7(a) lending — not as often, but it happens. As SBA lenders, it’s our responsibility to stay alert, report what we find, and follow proper procedures. Know how to identify red flags, know how to report them, and always act quickly. That’s how we protect both our institutions and the integrity of the SBA loan program.

Lender-Required Life Insurance for “Uninsurable” Borrowers: 2025 Update

by Ben Koplan

CLU, CFP®, LifeEase

Failure to Survive (FTS) insurance is a brilliant and forward-thinking series of products developed in the London market for use in the U.S. life/health industry. In recent years, this product category has evolved into a lifeline for commercial lending transactions that hinge on life insurance coverage—even for borrowers deemed uninsurable by traditional carriers. The FTS model has continued to gain traction among banks, SBA lenders, and insurance brokers seeking flexible solutions to complex lending challenges, especially as market and regulatory landscapes have shifted dramatically in 2025.

The Role of FTS Insurance in Commercial Loans

FTS insurance, sometimes called impaired risk term, non-medical issue, or special risk coverage, was designed to address a critical market gap: providing credible life insurance solutions in situations where the financial obligation of a business loan, buy/sell arrangement, or key person dependency would otherwise remain uninsured due to a borrower’s substantial health or background concerns. The instrument’s primary value lies in its ability to keep loan transactions moving forward, preserving business opportunity without exposing lenders to unmitigated loss.

The underlying mechanics of FTS remain similar to term insurance, but application protocols are streamlined for speed and accessibility. Unlike traditional fully underwritten life products, which may take months and are often barred by medical impairment, FTS insurance usually requires only a brief digital application, third-party electronic health record reviews, and attestation from a licensed agent that conventional coverage has been declined or priced prohibitively. This expedited process aligns with lender timeframes, particularly under the collateral assignment requirements common to commercial and SBA lending environments.

The 2025 Regulatory Backdrop

The regulatory context in 2025 is especially relevant for FTS users. At the federal level, SBA loan guidance (SOP 50 10 8, effective June 1, 2025) has re-emphasized the importance of life insurance as both a risk mitigator for lenders and a condition for loan approval wherever the death of a key owner-operator would materially affect loan repayment.

Key regulatory points include:

• Owner Dependency: Life insurance is required when the borrower business is wholly or substantially reliant on one owner’s active participation for success and loan viability. In all such cases, the death of the principal without an insurance solution exposes the loan to default—a risk now squarely addressed in SBA reviews and audits.

• Uninsurability Documentation: When owners or principals are uninsurable due to medical or background issues, lenders must collect written, formal documentation from licensed life insurance providers confirming the inability to secure conventional coverage or that such coverage is prohibitively expensive. This documentation must be kept with credit files and may be referenced in future regulatory or guarantee reviews.

• Collateral Assignment: If FTS or any alternative coverage is arranged, it must be assigned to the lender as collateral, not as beneficiary, to comply with assignment protocols. Lenders are charged with monitoring that coverage remains in force and will be notified of any risk of lapse or cancellation.

Alongside federal rules, 2025 also saw continued regulatory review at the state level and by the National Association of Insurance Commissioners (NAIC), particularly around consumer disclosure, data privacy, and anti-fraud controls for lender-required life products. There is heightened scrutiny of high-fee, lender-placed, or force-placed products, with requirements for clarity of borrower charges, fee limits, and robust borrower consent…

Read full LifeEase white paper here.

Learn about LifeEase here.

10 Tips to Streamline the SBA Credit Memo for Loans $350,000 and Under — Webinar 10/17

For SBA lenders, the credit memo is one of the most time-consuming and risky parts of the loan process. Even small loans require thorough documentation, and with SOP 50 10 8 in effect, the stakes are higher than ever. Stricter equity injection rules, updated collateral standards, and new SBSS thresholds make the memo feel like a regulatory obstacle course.

Coleman’s webinar will show lenders how to cut through the complexity. Bob Coleman and Lance Sexton will explain SBA requirements, common pitfalls, and practical shortcuts that simplify compliance without cutting corners. Attendees will leave with a clear action plan to speed up preparation, reduce errors, and present confident credit decisions.

Read more and register here

Avoid the Top Ten Equity Injection Mistakes That Put Your SBA Guaranty at Risk — Webinar 10/22

Equity injection documentation continues to be one of the most heavily scrutinized areas in SBA lending. Examiners, reviewers, and auditors consistently flag the same issues, and lenders who fail to meet the SBA’s exact requirements risk repairs or denials of their guaranty.

In this webinar, former SBA Little Rock Servicing Center Deputy Director Lance Sexton provides an industry-level presentation on equity injection compliance. Lance will cover exactly what reviewers look for, where lenders often go wrong, and how to document equity injection so your files pass SBA and third-party audits without exception.

Read more and register here

SBA Leadership: Lender Servicing & Portfolio Strategy with New SOP 5057 4 — Webinar 10/30

The SBA’s new SOP 50 57 4 goes into effect November 1, 2025. With major changes to liquidation deadlines, servicing standards, PPP record retention, and lender liability, now is the time to make sure you’re prepared

Coleman Webinar on October 30 – For your SBA Leadership Team

What sets Coleman training apart? Lance Sexton, Coleman’s SBA training expert and former Deputy Director of SBA’s Little Rock Servicing Center, leads both sessions. Lance has walked in your shoes and sat on SBA’s side of the table—bringing a rare dual perspective. He knows where lenders trip up, how SBA evaluates servicing and liquidation decisions, and what practical steps protect the guaranty.

Coleman’s webinars go beyond reading rules. They deliver clear explanations, real-world examples, and lender-focused strategies your team can use immediately. Don’t wait until November to adjust—get ahead of the curve with Coleman’s trusted training.

Coleman’s SBA Franchise Risk Grade Report — $295 Per Report

The Coleman Franchise Report is the only franchise intelligence tool built specifically for SBA loan underwriters. Packed with up-to-date SBA loan data, FDD analysis, and impartial Coleman Franchise Risk Grades, it delivers the transparency and confidence underwriters need to make better lending decisions.

This report is tailored to your specific needs and evaluates franchises using key SBA criteria, saving you countless hours of research. Empower your underwriters with precise, reliable data and our simple Grading Scale (AAA to F), helping you determine the viability of a franchise with confidence!

Read more and order here

Leverage AI Tools to Craft SBA 7(a) Credit Memos — Onsite Workshop in Oakland, CA on 11/18

Bob Coleman will lead a full-day workshop teaching how to use AI tools like ChatGPT and Microsoft Co-Pilot to streamline SBA 7(a) credit memo preparation. Attendees will receive hands-on training, work through real loan examples, and get ready-to-use templates to improve their underwriting process.

The event takes place on November 18 from 8AM to 4PM PT at TMC Financing in Oakland, CA, with a networking dinner the evening before. It is designed for SBA underwriters, credit analysts, lending managers, and bank executives looking to boost efficiency and accuracy. Registration is $795 per attendee, and seats are limited.

Read more and register here

SBA Secondary Market Summit — December 4, 2025

Coleman’s SBA Secondary Market Summit is back for 2025! For our 18th year, we’re excited to partner with the National Rural Lenders Roundtable (NRLR) to bring you two premier events under one roof in Washington, DC. Bob Judge will bring his decades of industry knowledge and expert insight to give us a glimpse of what to expect in 2026. Bob Coleman will moderate and put together the only program that brings together the Big Four of the SBA secondary market: Brokers, Investors, Sellers and SBA.

Early registration for the Summit is now open with a special early bird offer — one seat for just $995 if purchased by August 15. Don’t miss this opportunity to save!

Read more and register here

PREVIOUS REPORTING

The Keys to the Kingdom — Blueacorn’s Stephanie Hockridge SBA PPP Loan Fraud

NADCO Names 2025 Board of Directors

A Coleman Conversation: McCune Construction Funds Management

UPCOMING COLEMAN WEBINARS

10 Tips to Streamline the SBA Credit Memo for Loans $350,000 and Under — 10/17

Avoid the Top Ten Equity Injection Mistakes That Put Your SBA Guaranty at Risk — 10/22

SBA Leadership: Lender Servicing & Portfolio Strategy with New SOP 5057 4 — 10/30

Lending Conference Schedule 2025

B2B Finance Expo – October 28-29 (Las Vegas, NV)

America West – November 12-14 (Santa Rosa, CA)

Leverage AI to Craft SBA Loan Credit Memos – November 18 (Oakland, CA)

National Rural Lenders Roundtable – December 3 (Washington DC)

SBA Secondary Market Summit – December 4 (Washington DC)

COLEMAN LIBRARY

“Easy Money, Hard Time: 19-Covid PPP Loan Fraud Stories” by Bob Coleman

eBook Available for $14.95

Paperback available for $24.95

Hardcover available for $49.95

SBA 5010 8 (6/25) SBA Loan Policy

Paperback available on Amazon for $29.95

SBA 5057 4 (10/25) SBA Loan Servicing and Liquidation

Hardcover available on Amazon for $39.95

SBA 5056 1 (11/23) SBA Lender Policy

Hardcover available on Amazon for $39.95

 

COLEMAN YOUTUBE

Blueacorn’s Stephanie Hockridge SBA PPP Loan Fraud (10/10/25)

A Coleman Conversation: McCune Construction Funds Management (10/8/25)

Law Firm Office Manager Embezzles, Commits PPP Loan Fraud (10/3/25)

A Coleman Conversation: Beau Eckstein (10/1/25)

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