General Management Advisory SBA’s Use of Vendors Without a Contract

OIG is issuing this Management Advisory to notify management of a significant matter we identified during our audit of Small Business Administration’s (SBA’s) management of foreclosed properties, project number 20810. We discovered that SBA had been using three vendors without a contract since fiscal year 2012. As of February 18, 2020, SBA had paid these vendors an estimated combined total of more than $10.8 million in unauthorized commitments.

We considered management’s comments on the draft of this report when preparing the final report. Management agreed with recommendations 1 and 2 and disagreed with recommendation 3. We recommend the Administrator to direct the Associate Administrator for the Office of Capital Access to:

1. Require responsible personnel to execute a contract for foreclosure and real estate services to ensure the procurement of services are obtained and authorized in accordance with the Federal Acquisition Regulation requirements.
2. Ensure that vendors used to provide foreclosure and real estate services are registered in SAM, as required.
3. Ratify the over $10.8 million in payments in accordance with the FAR and 48 C.F.R. § 1.602-3.