All posts · SecureLend · Oct 6, 2026

Missing-document checklist by loan type

A working checklist for credit and underwriting teams. For factoring, ABL, SBA 7(a), CRE and C&I term loans it lists what to collect, what tends to arrive late, and what to do when a document is missing. Every rule links to its source.

Tobias Pfuetze

For credit and underwriting teams at banks, credit unions, and specialty lenders. Covers invoice factoring, asset-based lending (ABL), SBA 7(a), commercial real estate (CRE), and C&I term loans.

For each loan type you get three things. What to collect. What tends to show up late or not at all. What to do when it's missing.

Last checked 6 October 2026. SBA items follow SOP 50 10 8.1, effective 1 October 2026. This is a working checklist and doesn't replace your credit policy, your regulator's rules, or legal advice. Your policy wins where it is stricter.

How to read the tags

[Rule]
comes from a regulation, an SBA SOP, or an official form. Source linked.
[Guidance]
comes from a supervisory handbook or exam procedure (OCC, FDIC). Examiners use these. They are not regulations.
[Practice]
is common market practice. No rule requires it. We say so plainly.

Source numbers like [S1] point to the source list at the end.

1. When a document is missing (every loan type)

Ask for it. Never invent it, estimate it, or back into it.

Name it exactly.
Which document, which legal entity, which period. "FY2024 business tax return for the operating company" can be checked. "Remaining documents" can't. [Practice]
Ask in writing and log the ask.
Date, who was asked, what was asked for. [Practice]
Mark every figure that depends on it as unknown.
If the debt schedule is missing, DSCR is unknown. Don't carry a ratio forward from last year or from the borrower's cover letter. [Practice]
Don't fill the gap.
No plugs, no industry averages in place of the borrower's number, no figures copied from a narrative that the file can't support. Recalculate from documents you actually have. [Practice; see UWBench below]
Don't cite what you don't have.
A memo that points to a document that isn't in the file is worse than a memo that says the document is missing. [Practice; see UWBench below]
Set the file state.
Hold, approve with a condition precedent, refer, or mark it insufficient information. Say which document clears it. [Practice]
When two documents disagree, ask which one is right.
Don't pick the better number and don't average them. Get the source that resolves it (for example a tax transcript). [Practice; SBA requires reconciling financials to tax transcripts, see section 4]

The canonical example. UWBench is an open benchmark for AI agents doing commercial credit underwriting. Its ten public cases are synthetic, with no real borrower files [U1, Abstract and Section 1]. In case 00002, a synthetic Texas wholesale distributor, the financials omit debt service, so DSCR can't be computed without a follow-up [U1, Section 3.2]. The scoring rule is one sentence. "Inventing a missing debt-service figure is a failure; asking for it is the intended action." [U1, Section 3.4]. Another case has two named gaps, tax returns and accounts-receivable aging [U1, Section 3.2]. A third has conflicting FY2024 figures from two sources for the same year [U1, Section 3.2]. The same rules apply to a human analyst.

2. Invoice factoring

Factoring is the purchase of a business's receivables, usually without recourse. The factor's diligence focuses on the business's customers (the account debtors) more than on the business itself, and debtors are typically told to pay the factor directly [O2, "Factoring"].

Collect

Document

Why

Basis

Schedule of the invoices offered for purchase, with copies of the outstanding invoices

The asset being bought

[Practice]

Accounts receivable aging by customer, tied to the invoice schedule

Shows customer, balance, and payment status

[Guidance] O2 ("aging of receivables which lists receivables by customer name, balance outstanding, and current payment status")

Customer (account debtor) list with contacts and credit information

Factors set a limit per customer based on payment status, exposure, and credit strength

[Guidance] O2, "Factoring"

Proof of performance for each invoice: purchase order or contract, and delivery evidence (bill of lading, proof of delivery, signed timesheet)

An invoice for goods not delivered isn't collectible

[Guidance] O1 and O2 describe advancing against invoices, shipping documents, or receipts that are verified in field audits. The specific document per industry is [Practice]

Signed notice of assignment or payment-redirection acknowledgment from each debtor

Debtors remit to the factor

[Guidance] O2 ("purchasers are notified to remit payments directly to the factor"); FDIC, step 12, lists acknowledgment of assignments

Debtor verification of selected invoices

Confirms the invoice is real and undisputed

[Guidance] O2 and O1, field audits ("written account verifications")

Credit memos, returns, and dispute history

Dilution reduces what you collect

[Guidance] O2, "Dilution"

UCC lien search on the seller, and a payoff or release from any existing lender on receivables

Your claim to the receivables needs priority

[Guidance] O2 ("conduct a lien search both before and after initial funding"; purchase-money and tax liens can take priority)

Federal tax lien search, and evidence that payroll taxes are current

Tax liens can take priority over your lien

[Guidance] O2, "Lien Status Monitoring". The payroll-tax evidence itself is [Practice]

F10

Formation documents, good standing, signer authority

Enforceability

[Practice]; see R1 for the general standard on enforceable claims

F11

Owner identification and beneficial ownership, per your BSA/AML program

Customer due diligence

[Practice] under your institution's BSA program

F12

Executed factoring or purchase agreement and invoice assignment

Closes the purchase

[Practice]

F13

Recent business bank statements

Shows where customer payments land today

[Practice]

Often missing or late (market practice, no rates)

Proof of delivery for the specific invoices offered.
An aging that doesn't tie to the invoice schedule.
The prior lender's UCC release or payoff letter.
Debtor acknowledgments for new customers.
Tax compliance evidence.

If it's missing

Don't buy that invoice until its proof of performance and verification are in. Fund the invoices that are complete.
If the aging and the schedule disagree, ask for a reconciled aging. Don't adjust either one yourself.
Don't fill in a dilution rate from an industry norm. Ask for the credit memo history.
No release from the prior lender means you don't have clear priority. Hold.

3. Asset-based lending (ABL)

ABL lends against a borrowing base of eligible receivables and inventory, with close control of collateral and cash [O2, definitions; O1].

Collect

Document

Why

Basis

Borrowing base certificate (BBC) with supporting detail

Sets availability. Often required weekly or monthly

[Guidance] O1, "Financial Reporting Requirements"

Accounts receivable aging, reconciled to the BBC and the general ledger

Eligibility starts here

[Guidance] O1; O2

Accounts payable aging

Shows stretched payables and potential contra accounts

[Guidance] FDIC, step 16 ("Aging of AR and AP")

Schedule of ineligibles: past due, cross-aged accounts, affiliates and intercompany, foreign, concentrations, contras

Removes what you can't lend against

[Guidance] O1 (past due by three times the terms; cross-aging); FDIC, steps 15-16 (contra, affiliate, intercompany, foreign, chronic delinquents, concentrations)

Inventory reports by location and category, from a perpetual inventory system where possible

Values the second half of the base

[Guidance] O1 ("Perpetual inventory systems ... are preferred")

Inventory appraisal giving net orderly liquidation value (NOLV), by a qualified appraiser

ABL advance rates are set against NOLV, not cost

[Guidance] O1 ("The appraisals should provide a NOLV")

Initial field exam (collateral audit)

Tests the borrower's numbers before you rely on them

[Guidance] O1 ("A field audit should be conducted before a new account is booked and regularly thereafter")

UCC lien search before initial funding, and periodically after

Lien priority

[Guidance] O1, "Collateral Liens"

Lockbox or cash dominion arrangement and the bank account control agreement

Cash collection is part of the collateral control

[Guidance] O1 ("Lockbox arrangements ... are an integral part of ABL"). The control agreement form is [Practice]

A10

Landlord, warehouse, or bailee waivers for each inventory location you don't own

Access to collateral

[Guidance] FDIC, step 12, lists landlord waivers among lien perfection items

A11

Annual and interim financial statements

A BBC isn't a substitute for financial statements

[Guidance] O2 ("they are not a substitute for periodic financial statements"); O1

A12

Insurance with lender loss payee endorsement

Protects the collateral

[Guidance] FDIC, step 13 (insurance); the endorsement form is [Practice]

Often missing or late (market practice, no rates)

AP aging, because many borrowers only send AR.
A BBC that reconciles to the aging and the GL.
A current NOLV appraisal.
Waivers for third-party locations.
An executed account control agreement at closing.

If it's missing

Calculate availability only on collateral that is evidenced this period. Don't roll last period's BBC figures forward.
No current appraisal means no NOLV-based advance on inventory. Hold or advance on receivables only, per policy.
No field exam means the numbers in the BBC are unverified. Say so in the memo.

4. SBA 7(a)

SBA's origination rules are in SOP 50 10. Version 8.1 took effect on 1 October 2026 and applies to applications that receive an SBA loan number on or after that date. Applications through 30 September stay under Version 8 [S1, S1a]. The version that took effect is the "Technical Policy Updates" version published 25 September 2026, which replaced an August draft that never took effect [S1b].

Collect

Document

Why

Basis

SBA Form 1919, Borrower Information Form, one for each co-applicant (for example the EPC and the operating company)

Eligibility and background information on the applicant and owners

[Rule] S2

SBA Form 413, Personal Financial Statement, for each proprietor, general partner, managing member, owner of 20% or more, and any guarantor

Repayment ability and guarantor strength

[Rule] S3 (form instructions)

Personal financial statement from every individual guarantor except supplemental guarantors, dated within 90 days of loan approval

Freshness requirement

[Rule] S1, Section A, Ch. 5, Para. A

IRS Form 4506-C (through IVES) or IRS Form 8821, and the resulting tax transcripts, reconciled to the financials

Confirms returns were filed and match the statements

[Rule] S1, Section A, Ch. 5, Para. B; S4

Business financials. For Standard 7(a) (over $350,000), the three most recent years (tax returns, or balance sheet with debt schedule and income statement) plus an interim statement

Repayment analysis

[Rule] S1, Section B, Ch. 1, Para. C

Current debt schedule prepared by the applicant, including shareholder debt

DSCR needs all business debt, including the new SBA loan

[Rule] S1, Section B, Ch. 1, Para. C (the SOP calls this "important" for a complete debt service analysis)

Projections with supporting assumptions, when history doesn't show the required coverage or the business is a start-up

Required in those cases

[Rule] S1, Section B, Ch. 1, Para. C

Personal credit reports for owners and guarantors. Non-delegated loans include a copy dated within 90 days

Credit history

[Rule] S1, Section B, Ch. 1, Para. C

For 7(a) Small loans, the two most recent months of statements for the primary operating account

Confirms every debt is in the DSCR

[Rule] S1, Section B, Ch. 2, Para. C

B10

Equity injection evidence: copy of check or wire, at least 30 days of statements from the source account, and proof of deposit or a settlement statement

Must be verified before disbursement (except SBA Express and Export Express)

[Rule] S1, Section B, Ch. 6. A gift letter or promissory note alone is not enough

B11

Guaranties from every 20%+ owner (SBA Form 148 or lender equivalent)

Required

[Rule] S1, Section A, Ch. 5, Para. A

B12

Commercial real estate appraisal, when required: independent, USPAP, dated within 12 months of the guaranty application; state-certified above $1,000,000

Collateral value

[Rule] S1, Appendix 19, Para. A.1.g

B13

Management agreement, if someone else runs daily operations

Checks for an ineligible passive business

[Rule] S1, Section B, Ch. 1, Para. C

B14

Business licenses

Due within 90 days after final disbursement

[Rule] S1, Section B, Ch. 6

Often missing or late (market practice, no rates)

The IRS transcript response.
An interim statement that is current.
A debt schedule that includes shareholder debt.
A personal financial statement older than 90 days at approval.
A separate Form 1919 for each co-applicant.
The source-account statement behind the equity injection.

If it's missing (the first four come straight from the SOP)

No IRS response within 10 business days. Follow up by resubmitting Form 4506-C or 8821 marked "Second Request" [S1, Section A, Ch. 5, Para. B].
IRS has no record of required years. No disbursement until resolved, with one narrow good-faith exception for a missing middle year [S1, Section A, Ch. 5, Para. B].
Required federal returns weren't filed. The applicant isn't eligible [S1, Section A, Ch. 5, Para. B].
Equity injection not verified. No disbursement [S1, Section B, Ch. 6].
Debt schedule missing. DSCR is incomplete. Ask for it. Don't build one from the credit report alone [Practice, based on B6 and B9].

5. Commercial real estate (CRE)

Collect

Document

Why

Basis

Appraisal or evaluation, the bank's review of it, the engagement letter, and the appraiser's qualifications

Value. Evaluations are permitted in place of appraisals for some transactions, including loans of $500,000 or less

[Rule] 12 CFR 34 subpart C (OCC) and equivalents; [Guidance] O3, "File Documentation" and "Appraisals and Evaluations"

Rent roll and property operating statements (income-producing property)

Repayment comes from the property