Exhibit_4_-_Sample_PARRiS_Report.pdf

Exhibit 4

THIS DOCUMENT IS STRICTLY CONFIDENTIAL

This review plan is the property of the U.S. Small Business Administration, Office of Credit Risk Management. Under no circumstances shall any recipient of this plan disclose or make public this document or any portion thereof. Unauthorized disclosure of any of the contents of this document is subject to the penalties in 18 USC 641. The Office of Credit Risk Management must be notified immediately if the examined entity receives a subpoena or other legal process calling for the production of this document.

U.S. Small Business Administration Office of Credit Risk Management

7(a) Loan Program

PARRiS (PFR) Review

Bank Name

FIRS #

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EXECUTIVE OVERVIEW

REPORT DASHBOARD

Lender Reviewed

Associated FIRS

Total SBA Loans

Total SBA Share Dollars

Total Gross SBA Dollars

Lender Asset Size

SBA Peer Group

SBA Lender Risk Rating^

Delegated Authorities

SBA OCRM Fee(s) Overdue

EXISTING 7(a) BALANCE SHEET

Gross Active Balance

Active Loans

Current Balance

Past Due Balance

Deferred Balance

Delinquent Balance

Liquidation Balance

Non-Current Balance

Active Purchases

Total Exposure

RESULTS OF THE PARRiS REVIEW

Review Assessment

Component Assessment

Performance

Asset Management

Regulatory Compliance

Risk Management

Special Items

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RESULTS OF THE FILE REVIEW

Specific Weaknesses by

Category

# of Files

Reviewed

# of

Deficiencies Notes

Underwriting

Collateral

Closing

Servicing

Liquidation

Eligibility

Findings:

Comments and Concerns:

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Executive Summary

This report provides an overview of the Review activities, analysis and discoveries related to the

SBA operations of Bank Name during the field visit week of XX. The Report focused on the production, servicing and liquidation of the 7(a) loan portfolio. Specific to the SBA guaranteed loans held by Bank Name, this Review focuses on Performance, Asset Management (origination, servicing and resolution), Regulatory Requirements, Risk management and Special Items. The components are commonly referred to by the acronym “PARRiS”.

Summary Review Assessment

Background

Lender Authorities

Program Contact:

Report Prepared by:

Signature of Reviewer in Charge Date

Report Reviewed by:

Signature of SBA Financial Analyst Date

Report Concurrence:

Signature of SBA Team Leader Date

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Portfolio Performance PARRiS

Review Objective and Procedure

The objective of the Portfolio Performance review is to assess the degree of financial risk to the

SBA, largely based upon the lender’s ability to meet quantitative metrics defined by the Office of

Credit Risk Management. The over-arching metric is the calculated risk rating from the Loan and Lender Monitoring System and the Cumulative Net Cash Flow impact resulting from 7(a) lender cash impact to the SBA. This assessment includes an analysis of portfolio characteristics and comparisons of SBA, Lender and industry data, as applicable. A Lender must maintain satisfactory SBA performance as determined by SBA in its discretion.

Lender Risk Rating

Cash Flow/Loan Volume

Performance Metrics

Delivery Methods

Loan Approvals

Assessment

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ASSET MANAGEMENT

Review Objective and Procedures

The objective of the Asset Management review is to assess the quality of key origination, servicing, and workout practices of the lender’s SBA portfolio. This assessment considers both qualitative and quantitative factors to assess the lender’s ability to manage SBA loans through the origination, servicing, and resolution stages of the lending lifecycle. It also includes an assessment of the effectiveness of the management and staff in managing these risks related to the lender’s SBA program. The review procedures utilize the lender’s loan policies, procedures and individual file reviews to determine if loan originations, loan monitoring and collection activities are in accordance with the lender’s discretionary policy, SBA policy and prudent lender practice.

Credit Policy Summary

Origination Risk

Servicing Risk

Resolution Risk

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Regulatory Compliance

Review Objective and Procedures

The objective of the Regulatory Compliance review is to assess the Lender’s compliance with

1502 Reporting and SBA Loan Program Requirements. The assessment will focus on the

Lender’s ability to underwrite eligible SBA loans in compliance with CFR and SOP requirements. This assessment also considers the lender’s payment of SBA fees, as well as capitalization requirements of the primary federal regulator. The review procedures may include an assessment of sample loan files reviewed for compliance issues. The procedures also include an analysis and reconciliation of lender reporting documents to program requirements as applicable.

Financials

Federal Regulator/Capital Adequacy

Borrower Eligibility

1502 Reporting and Payments to SBA

Recoveries Remittances

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Risk Management

The objective of the Risk Management review is to assess the lender’s use of an effective governance model to identify, understand, and mitigate risk exposure to the SBA. This assessment considers the lender’s corporate governance structure, SBA business plan, and internal controls. This assessment is conducted through a review and analysis of the lender’s corporate governance documents; structure of SBA program governance; operational and management policies and procedures; underwriting and loan monitoring policies and procedures;

and exception to policy processes. This assessment is then tested through observations and interviews with the lender’s SBA program management staff.

Corporate Organization and SBA Management

Internal Reporting/Internal Controls

Operating Plan

Risk Classification System

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Special Items

The objective of the Special Items review is to identify and assess any additional high risk lender behaviors. This assessment is a catch-all for specific risks that do not fall into one of the other four categories. Special items include, but are not limited to, use of loan agents and lender service providers, secondary market sales, other sales/securitizations/participations, portfolio concentrations, and mergers/acquisitions of SBA portfolios.

Use of Loan Agents

Secondary Market Sales/ Securitizations/Pledges

Lender Service Providers

Franchise Lending

Mergers/Acquisitions

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Appendix A

FINDING AND CORRECTIVE ACTION

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Appendix B

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Appendix C

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Appendix D: Loan Sample Selection