May 6th - SSBCI Capital Program Disbursement Review Training Part 2

Grace uh so we are going to do a uh portal demo today uh and before we get started I am logging in and uh setting up my testing environment I have put a link to the portal inside the chat I also put our SSB Sal for information treasury.gov email address there uh while we're loading up my test environment we would encourage that anyone that has not logged into the portal in a while or has any changes in your email address or id.me account uh please attempt to log in right now just to make sure you're good to go uh again it's going to take me a minute or two to set up my environment so if there any other questions while I get this set up uh please come off meute and uh ask those questions thank you okay if we do not have any questions my uh environment actually loaded pretty quickly today uh so I did encourage ones that have not logged in in a while or had some issues in the past logging in uh to try to log in if you are a new user uh we encourage you to uh get added to your jurisdiction's account before clicking this link because you're going to have to log in and create an id.me account or if you have an existing id.me account you can use that to to go into the portal and I'll show everyone how to add new users in a couple of minutes so I am ready to share screen uh and the link that we have inside of the chat is the link that would take you straight to this page here if uh for whatever reason you have link that does not have the ssbci D home- page as a suffix uh you might have one that has carac Dash or slash S that will take you to this page here where you have the ability to read and dismiss the warning and then scroll down to the ssbci green tile to enter the ssbci portal once you're inside of the portal uh everything is exactly like uh everything else that you interacted with the portal where you have a left-hand navigation and you're going to navigate down to Capital program dispersement requests click that and then you will have a blue table for your dispersement request with all of your dispersement requests uh listed here if it is your first one you're going to have a report type of first trunch once you've completed that first trunch and you're uh gearing up towards your second trch then you will have a second trch item uh and then subsequently you will have a third trch once you're second trch uh item has been submitted and and cleared so essentially to get started with your dispersement request you would click the uh blue pencil and that's going to take you into your dispersement record and just like everything else in the portal you have a leftand navigation where you're able to select each one of these sections and move through you also have at the bottom of the page you have a back and then you have a back or next if you're any of the internal Pages I.E section two or section three you're also going to have a widget that does stay sticky and it shows your jurisdiction it also shows the status of your dispersement request so we're going to jump back to section one which is a user instructions it's a lot of good information here we just uh advise you to the browse through this and read everything uh we do have a user guide for the dispersement Crest uh within this third paragraph in the top section and then we have our privacy act statement towards the bottom we'll move to the next section by clicking next and that will take us to section two which is going to be the participating jurisdiction information again this is my testing environment so this is not going to look like your information uh but your jurisdiction will have your uh implementing entities information in here and if you have any issues with that or anything looks incorrect uh we ask you to reach out to us at the email address that I put into the chat we also have the uh ssbci information email address at the bottom of this contacts paragraph and speaking about the contacts area we do realize it may be some uh parts of your jurisdiction that uh may be uh interacting with the dispers request and they may not be interacting with the the application itself uh so we do give the ability for you to add uh contact records to your account and you will click this page here and that will take you over to our Co relief or covid-19 relief Hub where you have the ability to add uh users so you're going to have your first page which gives a brief description of the users uh inside of the portal you have a certification form where you would need to submit this uh and this just a test that you are the person that is able to add individuals to the account for access to the portal once you type your name in hit submit and then you're going to have it designation form if it's first time you're not going to see this designation form until you actually type your name in and click submit moving on to designation form and this is where you can edit uh existing users or you can add a new contact and again if this is a individual that you're adding to your account is the first time logging into the portal you would add this person here first uh and then you have the ability to give them the link and then they can click on to the id. me or create an id.me account because we need you associated with your account uh before uh you are are able to log into the portal what I'm going to do real quick is if you are and this is the self-service uh we encourage that uh if for some reason you're not having the ability to do that you're having some issues to do that we do have a form that you can fill out and I'm looking forward now see if I can add it into the chat uh and this is the account contact update form that you can use uh in order to request assistance with adding new users to your account by clicking add new user or add new contact you for first enter all the information for the individual that you're adding to your account first name last name uh title a name of organization email address phone number anything with the as is required and then as Samari mentioned a little earlier there are three levels of access you're going to have your account admin access which has the ability to view and download the the template you have the account PC uh that can view download and upload the completed template inside of the portal and then the authorized representative can view download upload and certify and submit your dispersement request and again as Samari uh mentioned earlier please don't conflict this user role of authorized representative inside of adding a new contact with the authorized official that's on uh your application here's just a role for access to the portal authorize official on your application the one that has the authority to sign on behalf of your jurisdiction so you can come down you can select whichever role that you desire uh that is most importantly for the individual that you're adding you select that role and you click on add new contact again I'm in my Tes environment so this is not totally linked so it will not work for me but once you have everything filled out with an as and you select your role you click new contact and that new contact will be added to this table right here so we're going to go back to the dispersion request so once you have that new user again they would click on the portal link and then they were able to access if they have an existing id.me account if not that portal link will prompt a new uh id.me account so we're going to move over to section three in section three we ask you and this is the data file upload section we ask you just to make sure that you're uh reading everything here there's a lot of good descriptive information uh on a high level of what already been discussed with Samari and Grace uh and if you slowly scroll down you see please download the optional template of the dispersion request before uh form here and this may uh uh alluded to a little earlier we advise you logging in clicking this form downloading it make sure that everything is prepopulated uh and this form is available at all times so once you've downloaded your form and you've inserted all information that is required uh you would save it to your file explorer on your computer and then you have a upload file section right here you click that and it's going to navigate to uh your Windows Explorer or your file explorer and you just navigate to where you've saved your template you click on it and hit open it's going to give a dialogue of uploading and then once this turned blue done you click done and that is going to populate in the table down here um and don't be alarmed we do have a user or a naming convention where we add final uh test record uh um to the name of the file as it's been uploaded so it may not look exactly like you've named it but this is how the forming or the uh the uh nameing convention uh changes that name once you have everything uploaded you jump over to section four for your certification and submission and I always advise to copy your name from here and paste it into here I say that because this section is case and space sensitive so if I change that to a lowercase s and hit certifi submit it's going to give me a red error up top uh so copy and paste it exactly as you see your name here and in this case is all caps with one space in between my first and last and once you have that there you're going to click certify and submit you'll get a green success over here and then you'll see the status change the E signature pending this is still e signature pending because this form has been routed to the authorized official that has been named on your application and they will still need to go into their email address and docy sign uh the dispersement request for everything to be finalized and with it that is the end of the demo I'll uh believe I'll send it back over to Risa thank you Jay all right so I recognize that we're basically over time but I do hope that you guys can stay and complete the presentation I'll try to go as fast as I can this information is really helpful um okay so we're going to start with the dispersement request best practices so at this point ssbci compliance we've gone through several dispersement requests several second Chun requests and a few third TR requests as well so based on those we've compiled some best practices that we think will be helpful for you all as you fill out your um disp request forms so first when you're submitting your supporting documentation you're going to send it via via a secure file transfer method so ssbci is going to be receiving the supporting documents and as you know it's going to contain some personal information so when you're sending it it should be through a secure file transfer and it should also ssbci staff should also only be granted temporary access to those reporting documents until the time that the comp dispersement request process is complete okay before submitting your documentation for the sample TR transactions um the PJ should review the documentation and make sure that the loan documents are complete make sure that there are no prohibited terms and limits for ssbci transactions that are included in the documentation because as you know those will send up red flags for us and it will increase the time that we have to request supporting documentation maybe have some meetings and things like that so the more you can get ahead of and know what's in these documents prior setting the fpci will make the process a little bit more smooth um also for the dispersement date we are looking for the date per the Capital program policy guidelines the date should be the date which the funds were received by the borrower or investe so make sure that you're using that date when you're filling out your form all right on to the next slide please sticking to the dispersement date topic um the dispersement date that's reported in the dispersement request form should also match the prior Year's annual report dispersement date um that's also something we're going to be looking for so for SSP chped transactions you should confirm that it's for an eligible business purpose as well as for an eligible borrower again this goes to reviewing the documentation um ensure that the primary and secondary purpose can be verified through the supporting documentation and for VC transactions the supporting documentation should include a proor a cap table all right and for instances where there are multiple sources of private Capital we should be able to look at the supporting documentation and differentiate between the lenders andore investors that are associated with that ssbci supported transaction um and also for VC transactions the documents that you provide should show that the transaction is per the the per Pursuit requirement has been met one way that it can be met is that the private investors sign the same same agreements as the ssbci program um all right we are going to the next slide all right for FTE like Grace had mentioned during her demo if you're reporting multiple loans or Investments to one business be sure not to double count um the ftes that you have reported all right for SE for transactions that qualify as supporting SE on businesses based on category 4 uh which is the business address please ensure that there is some documentation to support this um as you know for categories one two and three those are uh certified those are self certif certified by the borrower or investe but for category 4 that is on the jurisdiction to provide confirmation and documentation so on the actual study start there's a link to the cdfi fund investment area map so if you take a screenshot of the current business address um that would be sufficient documentation to show that they are qualified based on category 4 and con current private financing just be sure that that's not included in the total loan or investment amount on the in the CL one okay next slide so these are some best practices specifically for loan transactions so for loan transactions we have the minimum National Consumer Protections so for the total upfront fees as you know this is a change that was made last year we should be able to look at the documentation and know that the UPF front fees or charges paid by the small business don't exceed 3% for loans greater than 25,000 or $750 for loans under 25,000 and for the prepayment fees we're going to be looking at the original principal amount to determine whether it's in compliance or not so as you know if it's under 100,000 there can be a prepayment penalty but if it's over it cannot include that okay repeat business and purpose transaction so one loan cannot be enrolled in more than one approved program at the same time A lender may not divide one loan into multiple agreements or notes and each enrolled each enrolled in an approved program for the same loan purpose and for single transactions with multiple draw Downs like uh line of credits ssbci where ssbci funds have been dispersed to the lender you should report the full amount of both the lender and ssbci allocated funds under the loan transaction amount and the full amount of ssbci portion of the loaner credit uh or note under ssci allocated funds expended okay next slide these are some specifics for VC transactions specifically in regards to the onetoone requirement so for fund investment programs the oneto One requirement is met at the fund level um so you should know that the private investment in that specific fund must be equal to or greater than the ssti investment in that fund and the private investment should constitute private financing as it's defined in the capital program policy guidelines for direct investment programs the Ono one is met at the transaction level so that means that the private capital in the transaction must be per pursue with or Junior to the ssbci investment to comply with the capital at risk requirements for Equity investors also to keep in mind for direct investment programs if the equity investor is a fund or similar entity the fund or Equity man entity manager must have exposure to risk in its portfolio in a manner that is consistent with industry standards and lastly for the 171 fees to cover portfolio companies IES ssbci funds may be used to support a venture capital funds and it must be certified annually that these services are provided so there should be an agreement in place between the fund and the portfolio company and that agreement should include the identification of the services to be provided to the portfolio companies and disclosure of these services offered by the portfolio company's fund manager all right next slide Grace so this slide as well as the next two slides are a list of the documents that we're going to be looking for when we request your sample transactions so once you receive um once you submit your dispers request form we're going to send you a list of sample transactions that we've selected for sampling as well as these same lists for what documentation that we're looking for these lists are not comprehensive we may also request additional documentation that we need this is the Baseline that we're going to be looking for so just be sure that you review these documents here on this um on this slide here to know what we're going to be looking for when we sample our transactions and graceon next slide please and these are what we're going to be looking for as it relates to EPC OC transactions okay and next slide and for VC funds these are the documentations that we're going to be looking for and also keep in mind like I mentioned for the ones 71 there's also a SE annually that we're also going to be looking for okay next slide all right and here is our resources and references that we've used throughout this presentation so I'm gonna pass it back to MMA thank you thank you raisha thank you Grace um thank you Jay and thank you Samari um and thank you everybody for allowing us to take more of your time than we allowed for we just want to make sure that we cover all of these slides um I just want to add a quick reminder I know we have some good questions so feel free to come up mute if you have any questions we can stay on for the next seven minutes if you have time um I mean eight minutes but we just want to it is seven minutes but we just want to flag that when you are ready to complete your dispers requests or our completed dispersement request we are available to um to jump on a call like some R mentioned our goal is to make sure that you have clean submission to reduce the back and forth and to make sure that you receive your dispersal request in a timely manner so the better documentations that you have it's better for us so um let us know if you have any questions please come off mute if you do and if you're shy today because we already took we're taking more of your time than we allowed for we can jump on the call just reach out to your Outreach manager or through the mailbox information that Grace I mean that Jay um enter in the chat um I'll stop talking and hopefully folks have some questions oh just want to drop hey George how are you uh good afternoon I'm doing well how are you doing today I'm fine thank you is and I know every situation is going to be different but um based off of what you're seeing thus far uh on average is there a a general time frame that we should plan for assuming things um are in order for how long it takes to get that next dispersement yeah generally we try to complete the dispersement Within days um compliance drives most of the process but there's other processes such as the payment procedure that's not driven by us so generally we've seen some jurisdictions based on the documentation we've able to complete dispersement request within 30 to 45 days but it really is heavy heavily driven on the um jurisdiction I think Grace Illustrated we um Incorporated some data validation because one thing we've kind of we've seen in our review thus far is the of data issu which require a lot of back and forth so my suggestion and just jumping on the call before you submit is probably the best option to ensure that we can complete that your dispersement request within that 90day time frame okay thank you very much thank you George appreciate the question sorry we will share the deck with everybody after this call we do encourage you to also share the deck with your partners that may not be available on this call your provider um and again we are happy to jump on the call um we do encourage discussions within jurisdiction so if you know a jurisdictions that may have gone through the dispersement request they might help you with some best practices that we may not have communicated on this deck so feel free to reach out to your Irish manager of course it's up to that jurisdiction to decide they want to communicate any best practices but we do encourage discussion among amongst yourself in those working groups and via your Irish managers and again we really appreciate everybody's staying extra thank you so much we um the compliance team is still working on getting a good feel of our time and the questions that might come in for these various processes that we support so we appreciate you Pati and if we have no more questions I think the team and I we're happy to drop um but um again we encourage any questions VI the mailbox or through your a managers um and we really appreciate your time today