The borrower's reference library.
Free, downloadable documents that explain how the SBA COVID EIDL program works, how Treasury Cross-Servicing operates, and what governs whether a file can be returned to SBA. Public information, gathered in one place.
What the Loan Authorization & Agreement says about file return.
The Loan Authorization and Agreement (LA&A) is the contract between the borrower and the SBA. It governs the loan from origination through servicing, default, and any return from Treasury back to SBA.
Many borrowers do not realize that the LA&A contains specific language addressing when and how a file can be returned to the SBA from Treasury Cross-Servicing. The handbook below summarizes what Treasury and SBA say about the recall process, what triggers a return of the file, and the borrower's rights throughout.
Critically, every borrower retains the right to dispute any debt the borrower does not believe is accurate. This right exists regardless of where the file currently sits in the collection process. Disputes can be filed for procedural defects in referral, mathematical errors in the certified balance, identity theft, bankruptcy stays, or several other recognized grounds.
The handbook is provided as an educational reference and is publicly available information that is subject to change at any time without notice. For in-depth legal advice on your specific situation, seek an attorney that specializes in SBA matters.
Educational use only. SmallBiz Recon™ is not a law firm and does not provide legal advice. For legal counsel on your specific situation, consult a licensed attorney that specializes in SBA matters.
Why you can't reach anyone at the SBA — and a free package to fix that.
The SBA's COVID EIDL Servicing Center (CESC) went from over 2,000 employees handling everything from servicing (release of collateral, subordination, change in ownership, relocation), to business liquidation, to legal and fraud reviews, to a large customer service and hardship team — down to roughly 200 employees covering all of that work.
That is the reason for unreturned calls, slow response times, and automated cookie-cutter email replies. SmallBiz Recon put together a FREE outreach package to dramatically improve the chance of actually getting someone to contact you and get a Loan Specialist assigned to your file.
This package is designed to help borrowers stop chasing random phone numbers and start sending a clear, organized request through the channels SBA is most likely to recognize. It does not guarantee a response, but it gives your request a better structure, a stronger record, and a cleaner path toward review.
How the package works.
- 1
Write a brief letter
Explain in your own words the purpose of your contact request and why you need a Loan Specialist assigned.
- 2
Fill out SBA Form 2518
The Borrower's Authorization. If a third party (attorney, accountant, family member, our staff) needs to be able to discuss your file with SBA, list them. If there is no third party, write "NONE" in the party line — you still need to submit it.
- 3
Include proof of insurance
Insurance is a requirement of the LA&A. If you are not in operation, work from home, or have another reason there is no active insurance, send an additional "In Lieu Of Insurance" letter explaining in your own words why no insurance is in place. Insurance is required, but exceptions are recognized.
- 4
Use the contact log
Track every call, email, and outreach attempt. A clean log dramatically helps if you ever need to demonstrate good-faith communication efforts.
- 5
Send and wait
Once your package is sent through the proper channel, the SBA will work their way to you. They will almost certainly contact you once you are assigned a Loan Specialist.
Know your lender.
The U.S. Small Business Administration was created in 1953 under the Small Business Act. Its mandate is to aid, counsel, assist, and protect the interests of small business concerns, and to ensure that small business gets a fair share of federal contracts and surplus property sales.
The agency's core programs include 7(a) and 504 lending, disaster loans, government contracting assistance, and small business counseling. The COVID EIDL program was a temporary expansion of the SBA's existing disaster loan authority, run during 2020–2022 to support small businesses through the pandemic. It was not a forgivable loan program.
Servicing of those COVID EIDL loans — including default, referral to Treasury, recall requests, and disputes — is now handled through the COVID EIDL Servicing Center (CESC). Two free SmallBiz Recon™ guides cover the orientation a borrower needs to operate inside that system.
What a UCC is, and why it matters.
A UCC-1 Financing Statement is a public notice filed with a state Secretary of State office that establishes a creditor's security interest in a debtor's property. UCC stands for Uniform Commercial Code, the body of state laws that standardizes how secured transactions are recorded across the United States.
For COVID EIDL loans over $25,000, the SBA filed a blanket UCC lien against the business's tangible and intangible assets. That lien is what gives the SBA a secured position in your business property and is one of the reasons the SBA can pursue collection — and why borrowers want to understand their lien status before making decisions about business changes (relocation, sale, ownership transfer, closure).
Every UCC filing is publicly searchable through your state's Secretary of State business search portal. You do not need a lawyer to look up your own UCC — you just need to know where to look.
The SOP 50 52 2, current Policy Notice, and OIG oversight.
The SBA SOP 50 52 2 ("Standard Operating Procedure 50 52 2") is the official SBA manual that governs how loan servicing decisions are made — release of collateral, subordination, change in ownership, relocation, hardship accommodation, payment plans, recall requests, and the entire path of a defaulted loan. It is the rulebook the CESC operates under.
The Policy Notice 5000-857729 is the current extension and revision layered on top of the SOP. Together they represent the operating instructions every recall request and dispute references directly.
The SBA Office of Inspector General Report 25-23 is the independent audit of how SBA has actually executed COVID EIDL servicing. Knowing what the OIG found gives borrowers context for why certain procedural defects come up, and why disputes that cite documented SBA shortcomings tend to land harder than disputes that don't.
More from the resources tab.
Additional SmallBiz Recon resources to help you understand the SBA EIDL landscape.
Need help with any of this?
Free consultations. No commitment. We will read the facts of your file and tell you whether your situation may fit our work.
Or just contact us.
All documents and policy information on this page are publicly available and subject to change at any time without notice. SmallBiz Recon™ is a DBA of Recon11 Global Systems, LLC. SmallBiz Recon™ is not a law firm, does not provide legal advice, and is not affiliated with the U.S. Small Business Administration or the U.S. Treasury. For legal counsel, consult a licensed attorney that specializes in SBA matters.