Overview
Over the past several months, a significant share of small business borrower inquiries has shifted from standard SBA COVID EIDL servicing questions, things like release of collateral and change in ownership, to a far more urgent question: what happens when a COVID EIDL loan is referred to the U.S. Department of the Treasury's Cross-Servicing program, and what, if anything, can be done about it.
This page exists because the answer is buried. The full picture is technically public, but it lives across at least seven different federal documents on at least four different agency websites, in regulatory chapters, policy notices, OIG audit reports, and TFM volumes that most borrowers never see and most novice internet users have a hard time locating, let alone assembling. The agencies that produced this material did not publish it as a coherent borrower-facing guide. We have.
Everything below is sourced from publicly available SBA, Treasury, Office of Inspector General, and Code of Federal Regulations materials. Every link in the References section is live and verifiable. We have not added private interpretation, predictions, or opinions about any specific borrower's situation.
Who we are, and what we are not
SmallBiz Recon™ is a DBA of Recon11 Global Systems, LLC, a Florida-based company headquartered in Brevard County. The company is led by Timothy Ellison, who served six years at the SBA, including five years as a Supervisory Team Lead and CME in the Release of Collateral, Subordination, Relocation, Hardship, and Fraud Review areas, and contributed to procedures in the SBA Realty and Servicing Department. Timothy holds an MSLB in Sports Law and Business from Arizona State University's Sandra Day O'Connor College of Law and brings ten years of combined business and legal experience.
"We are an educational document preparation and administrative packaging company. We are not a law firm."
- +Educational consultations on how SBA COVID EIDL servicing and Treasury Cross-Servicing work as a general matter, using publicly available federal sources.
- +Document organization assistance. We help borrowers assemble their own records and build a clean factual timeline.
- +Administrative packaging. We prepare submission-ready document packets based on the borrower's own stated facts. Every submission is signed and sent by the borrower in the borrower's own name.
- +Free initial consultation and a free follow-up with Timothy directly when borrowers want one.
- ×We are not attorneys. We do not represent borrowers in any legal or administrative proceeding.
- ×We do not provide legal advice, tax advice, or financial advice.
- ×We do not negotiate with SBA, Treasury, Fiscal Service, DOJ, or any private collection agency on behalf of any borrower.
- ×We do not analyze any specific borrower's facts and tell them whether they "have a case."
- ×We do not guarantee outcomes. Nobody can.
If a borrower has litigation exposure, fraud allegations, bankruptcy issues, asset protection questions, tax issues, or any matter requiring legal representation or active negotiation with a federal agency, we recommend they consult a licensed attorney. We are less expensive than most law firms, but we are not a substitute for one.
Recall vs. return.
Recall.
Initiated by the creditor agency. The notification to Fiscal Service by the creditor agency that Fiscal Service must cease its debt collection efforts and that servicing responsibility has been transferred back to the creditor agency.
Return.
Initiated by Fiscal Service. Fiscal Service may return a transferred debt to the creditor agency when certain factors are met, including unreliable certification, inability to locate the debtor, or invalid or unenforceable debt status.
Treasury's public statement that it "cannot return" COVID EIDL debts is a statement about Treasury's own discretion under the return mechanism. The recall mechanism, which is initiated by the creditor agency, operates on different rules and is not foreclosed by that statement.
The borrower is not asking Treasury to send the debt back. The borrower is asking SBA to evaluate whether one of the TFM 5030.50d recall conditions applies and, if so, to act on its TFM obligation.
The seven recall conditions
Treasury's Financial Manual states that the creditor agency must recall a transferred debt immediately if any of the following apply. These are quoted from the TFM and listed verbatim.
The debtor has filed for bankruptcy and the automatic stay is in effect.
The debt is not enforceable.
The debt is not delinquent.
The debt is not valid.
The federal agency discovers that it incorrectly certified the debt.
The federal agency discovers any other reason that would render its certification invalid.
The federal agency, after consultation with Fiscal Service, agrees the federal agency should service the debt.
None of these conditions guarantee SBA will agree that they apply in a given case. SBA reviews each request on its own facts. But the conditions exist in the public manual, and the borrower's right to request review under them is grounded in the regulatory and TFM framework, not in advocacy.
The SBA servicing framework
COVID EIDL servicing is not generic federal debt collection. SBA's published servicing and liquidation procedure for disaster loans is SOP 50 52 2, "Disaster Loan Servicing and Liquidation." COVID EIDL operates inside that framework with COVID EIDL-specific extensions.
SBA Policy Notice 5000-857729, "Extension and Revision of COVID EIDL Servicing and Liquidation Policy," effective August 5, 2024, extends and revises the special servicing policies for COVID EIDL loans. It operates within the SOP 50 52 2 framework and applies COVID EIDL-specific provisions where they differ from the standard SOP.
What SBA still handles, even on referred loans
SBA's own COVID EIDL servicing page lists the following servicing actions:
SBA instructs borrowers to email completed servicing action requests to COVIDEIDLServicing@sba.gov. Treasury and private collection agencies are not set up to process these.
Monetary default vs. non-monetary default
Monetary default generally means missed payments. Non-monetary default involves other obligations under the Loan Authorization and Agreement, such as unauthorized sale or transfer of collateral, failure to maintain required insurance, relocation without required notice, ownership changes, or failure to comply with other loan conditions.
The OIG findings.
On August 12, 2025, the SBA Office of Inspector General issued Audit Report 25-23, "SBA's Collection Efforts on Delinquent COVID-19 EIDLs."
- ◆SBA did not perfect its security interest on borrower deposit accounts.
- ◆SBA did not conduct post-default site visits.
- ◆SBA did not report all delinquent obligors to credit bureaus.
- ◆SBA did not refer debts to the Department of Justice for litigation.
The OIG also reported SBA was attempting to collect on an additional 96,745 COVID-19 EIDLs totaling $14.7 billion that had been delinquent for 90 days or more. The audited population excluded loans with confirmed or suspected fraud.
The April 2024 to September 2025 timeline gap
One of the more confusing pieces of the public record involves the timeline of Treasury referrals. The OIG report and Treasury's current public update do not cleanly reconcile, and we have not located a public document that closes the gap.
OIG Report 25-23 states that Treasury granted SBA a two-year exemption from referring all delinquent COVID-19 EIDLs to Cross-Servicing regardless of dollar value or litigation status.
Per OIG, all delinquent COVID-19 EIDLs SBA had already sent to Treasury for Cross-Servicing were returned to SBA for servicing through this date. SBA was still required to refer debts to the Treasury Offset Program.
Treasury's current public COVID EIDL update states that SBA began referring delinquent COVID EIDL debts to Cross-Servicing as of September 2025.
If there was a policy reversal or modification between April 2024 and September 2025, we have not located a public document that explains it. The reconciliation matters because the answer affects how borrowers should understand the basis for their own referrals.
The April 2026 SBA referral announcement
On April 24, 2026, in coordination with the White House Task Force to Eliminate Fraud, SBA announced that it had referred 562,000 suspected fraudulent loans to Treasury for collection, tied to $22.2 billion in delinquent PPP and COVID EIDL loans previously flagged for suspected fraud. SBA described this as its largest referral package on record.
"The wording "suspected" matters. Suspected fraud is not a final fraud finding."
That distinction is critical for public reporting and for borrowers who received notices in this referral wave. Some files may involve serious fraud allegations. Others may involve documentation mismatches, tax transcript discrepancies, business-status questions, identity concerns, or other administrative flags that require review. A "suspected fraud" classification is a starting point for further investigation, not a conclusion.
The channel map.
Sending the wrong question to the wrong agency wastes time and sometimes triggers additional collection activity. Three lanes, three sets of authority.
SBA
The loan file. Servicing actions: release of collateral, relocation, change in ownership, assumption, substitution, release of guarantor, subordination, general assistance. Recall review requests under TFM 5030.50d. Payment assistance enrollment and continuation.
Treasury / Fiscal Service
Cross-Servicing collection activity once the debt has been referred. Treasury Offset Program activity. Administrative wage garnishment (up to 15% of disposable pay for non-tax debts). Cross-Servicing dispute and validation requests.
Private collection agency
Collection contact and payment processing on behalf of Treasury after Cross-Servicing assignment. The PCA does not replace SBA as the creditor agency and does not have authority over the underlying loan file.
Red flags
A surge of confused borrowers attracts a surge of predatory operators. These warnings apply equally to consultants, debt-relief firms, and law firms.
Anyone who guarantees a recall, a settlement amount, or any specific outcome
Nobody can guarantee these outcomes. Not SmallBiz Recon, not a law firm, not a consultant, not a debt relief company. SBA and Treasury control their own decisions.
Percentage-of-loan-balance pricing
Fees tied to a percentage of the debt amount, or to the size of any reduction, are a sign the firm is selling outcomes it cannot control. Flat-fee pricing for actual document and educational work is more honest.
Promises to "make the SBA debt disappear" or "erase" it
SBA debt does not disappear administratively. Borrowers can request review, can dispute, can ask for recall, can seek compromise, can pursue legal options. Nothing about that process erases the debt outside SBA's own decision channels.
High-pressure sales tactics or refusal to provide written engagement terms
Legitimate document preparers and attorneys provide engagement letters, scope of work, and clear pricing in writing. Pressure to sign immediately is a sign the firm is not operating in your interest.
Anyone claiming to negotiate on your behalf without being a licensed attorney
Active negotiation with federal agencies is generally legal practice. Document-preparation companies prepare documents. Borrowers negotiate. Attorneys negotiate on behalf of clients.
We say this knowing it applies to us too. If anything in this page or in any conversation with SmallBiz Recon ever looks like a guarantee, an outcome promise, or a representation that we will negotiate or advocate for a borrower, please stop and ask for clarification. We will correct it immediately.
We make
the process
simple.
A scrivener-model engagement, written in plain language so a borrower knows exactly what to expect before they say yes. Four steps from first call to agency response. No mystery, no surprise charges, no pressure.
Free educational consultation
Schedule a free initial conversation, and a free follow-up with Timothy directly if you want one. We walk through how SBA COVID EIDL servicing, Treasury Cross-Servicing, and the TFM recall framework work as a general matter.
We do not analyze your specific facts, advise you on what to do, or tell you whether you have a case.
Engagement and document intake
If you decide to engage us, we provide a written engagement scope and a flat-fee quote. Pricing scales with complexity. You provide your records, your factual timeline, and your own statements about what happened.
Every fee is disclosed in writing before any work begins.
Package preparation in your name
We organize your materials and prepare the document package in the borrower's name, based on the borrower's own stated facts. Every submission is signed by the borrower and sent by the borrower.
You review and approve every word before anything is finalized.
Borrower submits, agency responds
Once you have reviewed and approved the package, you submit it to the relevant agency under your own signature and from your own contact information. The agency response comes directly to you.
We are available for document-organization questions after submission.
No representation. No negotiation. No outcome promises.
References.
Every claim on this page is grounded in a publicly available federal source. Each reference below is linked. If a link breaks or an agency updates a source, we update this page.
The free consultation exists because nobody should pay for information that is already public.
If, after reading this page, you decide you want help organizing your own documents and preparing a submission in your own name, we offer a free initial educational consultation and a free follow-up with Timothy directly. No pressure. No outcome promises. Just a clean conversation about how the process works.