As 2014 unfolds, it brings with it new opportunities and challenges. The compliance burden continues to mount, however, now regulators are taking an increasingly hard line on your bank's responsibilities and liability when it comes to using service providers.
In fact, the Federal Reserve has released new guidance that stresses how financial institutions need to be aware of the potential risks in outsourcing functions which includes business lending through the Small Business Administration. (Click here for a downloadable PDF of the Federal Reserve's guidance letter).
Essentially, the guidance letter reminds lenders that using a service provider does not relieve the responsibility of the bank or its board or its senior managers for the activities performed by its contracted service provider.
We're happy to assure you that Business Development Corporation of South Carolina (BDC) is not a typical vendor in that sense. We have both bank members and bank stockholders and your bank is a participant in transactions with BDC, as opposed to a contractor or sub- contractor. We take full responsibility for the process from beginning to end and offer a BDC buyback of all SBA guaranteed participations at any time, creating both security and liquidity for our 39 member banks.
Business lending through the SBA can be a complicated matter, and we — along with our associated company, Certified Development Corporation — have been financing small businesses in South Carolina for more than 50 years.
If I can help clarify these provisions, please don't hesitate to contact me at ELesley@BDCofSC.org or at (803) 744-0301.
Edwin O. Lesley
President & CEO
President, CEO & Treasurer