What's the Dilly-o with commercial & SBA: a buyer's guide for credit unions

The Dilly-o

Most credit unions should pick a commercial and SBA system for how well it keeps up with rule changes and fits their core, not for its demo. We'd ask whether SBA rule updates come in the base price, because a change order for each one adds up. We'd also get written prices and exit terms before you sign.

How we'd size up a vendor

1. Credit analysis - does it pull figures from tax returns and financial statements into your credit memo, with a person checking the result? We'd ask to see it run on a sample file from your own credit union.
2. Core fit - which connections to your core and digital banking platform are live today, and who fixes them when they break? We'd ask for a live reference for each connection the vendor names.
3. Exit terms - what does it cost to leave, and will the vendor put deconversion fees in writing now? We'd raise exit terms in your first talks with each vendor.

What changed this year

SBA's latest lending rules brought back a written credit-elsewhere analysis covering the applicant and any owner of 20% or more.² SBA's rules also require collateral for all loans over $50,000.³ For 7(a) Small Loans, the debt service coverage ratio must be at least 1.1:1.⁴ The Consumer Financial Protection Bureau (CFPB) Section 1071 rule took effect June 30, 2026, with one compliance date of January 1, 2028.⁵⁶ Coverage requires 1,000 covered originations in each of two preceding years.⁷ CFPB estimates that 172 to 181 depository institutions will be subject to the rule.⁸ FinCEN's exceptive relief order, in effect since February 13, 2026, excepts covered institutions from verifying a business customer's beneficial owners each time it opens a new account.⁹ We'd look for a system that builds these rule changes into its checklists, so your lenders are not tracking them by hand.

Will it work with your systems?

We've seen Newgen Software listed for Symitar credit unions on the Jack Henry Fintech Integration Network, with the latest listing in November 2026.^C Ask your digital banking provider which lending vendors it already connects to. Then ask each vendor for references on your exact core.

What other credit unions did

NCUA has noted that some credit unions signed agreements with large buyout or termination penalties, believing them non-negotiable.¹⁰ In SBA lending, Washington's Department of Financial Institutions brought a statement of charges at a bank involving an SBA loan officer, the chief credit officer and the then-CEO.¹¹ The lesson we take is that controls and contracts deserve as much attention as features.

What your examiner will ask

NCUA's commercial lending rule says collateral must match the risk of a loan's size and type.¹² For an unsecured loan, you must document in the file what offsets the risk.¹² FinCEN's 2016 customer due diligence (CDD) rule still applies, including verifying beneficial owners when a business first opens an account.¹³¹⁴ NCUA also says it is prudent to have qualified outside legal counsel review third-party contracts.¹⁵ Have your loan file standards, your CDD process and that contract review ready to show.

What it costs

Most vendors here do not publish prices, and pricing stays quote-based until you get a written proposal.¹⁶ One range in Algebrik's pricing guide puts licensing at $80,000 to $300,000 or more a year and implementation at $100,000 to $400,000.¹⁷ Per-seat pricing is common for commercial platforms such as nCino, and one third-party estimate puts nCino at about $50,000 to $150,000 or more a year plus Salesforce costs.¹⁸¹⁹ We found no public figures for time to implement, so ask each vendor for a dated plan. NCUA notes that early termination, escape clause and default terms are often negotiable.²⁰

Food for thought

We think the next question your board and examiner will ask is who checks the machine's work on each credit decision.