SBA Disaster Loan Program: Accounting Anomalies Resolved but Additional Steps Would Improve Long-Term Reliability of Cost Estimates

In response to our recommendation, during fiscal year 2007 OMB revised the Credit Subsidy Calculator (CSC) that OMB provides to agencies for use when calculating subsidy cost re-estimates and financing account interest. The new version of the calculator, referred to as CSC2 is a "one-stop" tool for making required calculations for Federal credit programs. It built upon the existing functions of the previous CSC and incorporated the reestimate and financing account interest functions of other tools. The revised CSC2 corrects agencies' financing account interest calculations consistent with our recommendation. The CSC2 was intended to help agencies more easily integrate all of the processes involved in subsidy and interest calculations over the life of the loans, and resolve discrepancies between budget and accounting data.

In response to our recommendation, during fiscal year 2007 OMB revised the Credit Subsidy Calculator (CSC) that OMB provides to agencies. The new version of the calculator, referred to as CSC2 is a "one-stop" tool for making required calculations for Federal credit programs. It built upon the existing functions of the previous CSC and incorporated the reestimate and financing account interest functions of other tools. The CSC2 was intended to help agencies more easily integrate all of the processes involved in subsidy and interest calculations over the life of the loans, and resolve discrepancies between budget and accounting data. The methodology used in the CSC2 allows agencies to calculate interest on the financing account balances, as well as interest adjustments going back to the initial disbursement date for the cohort.

In response to our recommendation, during 2006 SBA's Disaster Loan Program Office collected information related to the credit scores of disaster loan borrowers. SBA conducted an analysis of individual borrowers' credit scores. SBA found that, as of the date of the analysis, credit scores had an insignificant impact on whether or not a loan ultimately defaulted. SBA also developed policies and procedures that summarize how the agency would continue to routinely test possible data that could be used in the model, including credit scores.

In response to our recommendation, SBA developed polices and procedures over the agency's credit subsidy process during fiscal year 2006. These policies and procedures include steps to test the disaster loan program credit subsidy model's ability to predict future loan performance by comparing actual and estimated cash flows. These procedures were developed based on an analysis that was first performed during fiscal year 2006.

SBA implemented several steps to simplify the estimation process. The estimation process was revised to use data from one source data system, instead of multiple systems. The cash flow model was revised to reduce the number of manual steps in the reestimate process. In addition, SBA developed Policies and Procedures to document the process to update, enhance, review, validate, and run the cash flow model. Further, a SAS operating interface is being developed, which will allow for reestimates to be completed with the push of one button.

SBA developed Policies and Procedures to update and enhance the cash flow model. This document included procedures to test and document the reliability of data used in cash flow models. For example, SBA revised the model to use data from only the ELIPS system instead of multiple systems. The data in ELIPS is updated daily and reconciled daily with the general ledger. In addition, data pulled from ELIPS to use in the cash flow model is validated against data in other systems and differences greater than one percent and researched and the cause is documented. Further, because subsidy estimates are prepared with 9 months of actual data and projected data for the final 3 months of the current year, SBA developed procedures to test the projected data with actual performance to determine if adjustments are needed.

SBA's Office of the Chief Financial Officer developed Policies and Procedures for the Office of Financial Analysis (OFA). OFA is responsible for the preparation of SBA's credit program subsidy estimates. The policies developed relate to performing and documenting tasks associated with the preparation of budget formulation estimates and re-estimates for SBA's credit programs. These policies include procedures for a cash flow model update/enhancement cycle. Specifically, there are procedures that describe planning for model updates, an evaluation process, a review process, and a validation process. These procedures are intended to control modeling changes and to maintain the integrity of the models. OFA also developed separate "desktop procedures" that describe in detail the process to update and run the model.