Portfolio review
Check a group of files
A fictional portfolio of 25 files; a random sample of 8, drawn the way an examiner would.
Findings by area 5
| PARRiS area | Findings | Exception categories |
|---|---|---|
| Portfolio Performance | 0 | none |
| Asset Management | 3 | closing, eligibility |
| Regulatory Compliance | 0 | none |
| Risk Management | 0 | none |
| Special Items | 0 | none |
The sample 8
| File | Type | Year | What we found |
|---|---|---|---|
| P-02 | Standard 7(a) | 2026 | Ready |
| P-04 | Standard 7(a) | 2025 | Missing Insurance evidence missing M3-AM-011 |
| P-07 | Standard 7(a) | 2025 | Needs attention Form 1919 not consistent with credit memo M3-AM-009 |
| P-09 | Small Loan | 2024 | Ready |
| P-12 | Small Loan | 2024 | Needs attention Form 1919 not consistent with credit memo M3-AM-009 |
| P-15 | Small Loan | 2024 | Ready |
| P-18 | Small Loan | 2024 | Ready |
| P-22 | Standard 7(a) | 2025 | Ready |
How the sample was drawn
Uniform random draw without replacement, seed 20260928, so the same sample can be drawn again in front of SBA.
The rule we checked against
M3-SI-001 · Policy Notice 5000-1940 (scope: SBA Supervised Lenders; applicability to bank 7(a)/PLP lenders UNVERIFIED) Rule status: VERIFIED
The rule, as our rulebook reads it: [PARRiS: Special Items | Exception: n/a] File-sampling expectation: examinations review loan files that may be random and judgmental, and may include past-due, delinquent, in-liquidation and in-purchase loans where those are areas of concern; the tool should pre-test all such loans.
Draft corrective-action list
A starting point for the written response SBA requires within 45 business days of a review report. A person edits and signs it.
- closing (1 in the sample): identify every file in the portfolio with the same gap, cure it, and record who did it and when.
- eligibility (2 in the sample): identify every file in the portfolio with the same gap, cure it, and record who did it and when.
The rule we checked against
M3-RC-003 · 13 CFR 120.1055; SOP 50 53(2) also states 45 business days Rule status: VERIFIED
The rule, as our rulebook reads it: [PARRiS: Regulatory Compliance | Exception: all] Written response to a review/exam report within 45 business days of receipt; corrective actions implemented within 90 calendar days unless SBA notifies otherwise.