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You are here: Home » Resources » Articles » What’s New in SBA’s SOP 50 10 6: A Review of Environmental Policy Updates

September 10, 2020

What’s New in SBA’s SOP 50 10 6: A Review of Environmental Policy Updates

By Janet Annan

NAVIGATING SBA’S ENVIRONMENTAL POLICY SOP UPDATES

The long wait for SBA’s new SOP is over! Effective October 1, 2020 the SBA SOP 50 10 6 will replace the SOP 50 10 5(K). The look of the new SOP is different, as they have tried to make it much more user friendly with bookmarks in the Table of Contents and format changes. However, there are several more changes throughout the document and should be reviewed by lenders.

Per the SBA Information Notice, dated August 28, 2020, the format of SOP 50 10 6 has been reorganized to consolidate guidance for the 7(a) and 504 loan program requirements. In summary, Part 1 (formerly Subpart A) contains the SBA Lender participation and portfolio requirements and Part 2 (formerly Subpart B and C) is now divided into Sections A, B and C. Section A reviews the core requirements for both 7(a) and 504 loans; Section B covers 7(a) program specifics; and, Section C reviews the 504 loan program requirements.

The predominant changes outside of formatting has been added clarifications. But overall, the way Environmental Professionals conduct assessments will remain the same.

Below is a table showing a side-by-side comparison of the changes within the Environmental Policy Section from SOP 50 10 5(K) to SOP 50 10 6.

SOP 50 10 5(K) to SOP 50 10 6 Comparison

About the Authors

Janet Annan

Janet Annan

Client Manager, Principal
Janet Annan is a Principal and Client Manager, who is specialized in environmental due diligence and other services supporting Partner including institutional and private equity clients, Fannie Mae, Freddie Mac, and SBA. She provides technical expertise and senior review to ensure ASTM, AAI, and SBA requirements are completed for the client requirements on all levels of environmental due diligence. Her responsibilities include project and team oversight, report review, client liaison, education to internal and external clients, and technical expertise. Specifically, Ms. Annan has nearly 20 years of experience and has performed and supervised Phase I and Phase II Site Assessments, Baseline and Exit Assessments, SBA Farm Loans, TSAs, Subsurface Investigations, RSRAs, Peer Reviews, Limited Compliance Overviews, Asbestos Surveys, Radon Measurement and Mitigation Surveys, National Environmental Policy Protection Act (NEPA), “hands-on” field investigations, remediation projects, formerly-used defense (FUD) sites, CERCLA sites with Community Involvement, and hazardous material emergency response.

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