Compliance Requirements for Borrower Monitoring and Portfolio Reporting

Elevating the Lender’s Approach to Compliance

Since 2020, SBA lenders have experienced a quickly shifting lending environment. From the rapid rollout of PPP and EIDL programs in response to COVID-19, to an increase in instances of fraud with often limited lender guidance.

The current era of SBA lending might be characterized as one where lenders are seeing increased demand for capital, fraudulence is down due to improved tools for mitigation and increased scrutiny, however SBA default rates have increased YOY as small businesses face economic headwinds.

As lenders move forward, hoping to continue serving the demand for working capital and commercial real estate, they will need to find ways to mitigate portfolio risk while providing a more seamless and digitized loan process internally and for their borrowers.

How TOD Helps Lenders Stay Compliant and Efficient

A recent Deloitte study showed a 60% surge in operating costs spent on regulatory compliance. Increasing compliance-related pressures are coming from all directions.

TOD provides lenders with ongoing access to IRS transcripts for 3 years with just one borrower signature.

This means simplified access to verified tax data– like income, unemployment, and civil penalty filings– through one secure platform. TOD eliminates the need for manual transcript requests and borrower follow-ups.

TOD alerts lenders to changes in borrower tax profiles and issues financial health reports, making compliance monitoring timely, accurate, and automated.

This saves lenders hundreds of hours in manual processes.

Regulatory Compliance & Reporting

The SBA reports a 7% increase in loan origination in 2025, which means more work for compliance and reporting personnel.

Lenders are required to submit regular reports to regulatory bodies such as the FDIC, USDA, and SBA. These reports must reflect accurate borrower status, loan performance, and risk classification.

TOD supports this by:

  • Automating transcript retrieval with one borrower authorization
  • Providing secure, organized access to IRS transcripts for up to 3 years
  • Alerting lenders when transcript access is lost or disrupted


This means lenders can meet reporting deadlines with confidence, reduce manual errors, and maintain compliance across their entire portfolio.

Borrower Monitoring & Risk Management

Since 2022, early loan defaults on SBA loans have tripled.

Regulators expect lenders to monitor borrower financial health continuously, not just at origination. But without real-time data, lenders are often working with outdated or incomplete borrower profiles. TOD solves this by offering continuous access to IRS tax transcripts, including real-time alerts for:

  • New tax liabilities
  • Missed filings
  • IRS notices or changes in taxpayer status

For example, if a borrower incurs a new tax lien mid-year, TOD alerts the lender, allowing for timely outreach, risk reclassification, or loan restructuring.

Audit Readiness & Documentation

When regulators audit your institution, they expect clear documentation of borrower monitoring and compliance actions.

TOD helps lenders stay audit-ready by:

  • Centralizing borrower tax data in one secure platform
  • Providing a searchable 10-year archive of tax payment history
  • Offering automated alerts and logs of borrower changes

This means lenders can demonstrate compliance with ease– no scrambling for paperwork or manually assembling borrower histories.

Portfolio Organization That Supports Strategic Decision-Making

TOD’s intuitive dashboard and search tools allow lenders to segment their portfolio by borrower type, business name, or loan officer.

This makes it easier to:

  • Identify trends across industries
  • Flag high-risk borrower groups
  • Prepare for audits or internal reviews

In large commercial portfolios, where data is vast and interconnected, this level of organization is essential for informed decision-making.

Risk Mitigation & Proactive Compliance

TOD isn’t just a tool, it’s also a safeguard. By automating access to verified tax data and alerting lenders to changes, TOD helps institutions:

  • Detect borrower risk early
  • Adjust loan terms or classifications proactively
  • Avoid regulatory penalties and reputational damage

With TOD, compliance becomes a proactive strategy, not a reactive burden.

The Lender’s Compliance Advantage

TOD offers lenders a major compliance advantage.

By offering ongoing monitoring and instant access to IRS tax transcripts, lenders can:

  • Stay ahead of regulatory requirements
  • Submit accurate portfolio reports
  • Detect borrower risk early
  • Maintain audit-ready documentation

And they can do it all without increasing overhead or chasing paperwork.

Ready to strengthen your compliance strategy?

If you’re a lender looking to streamline borrower monitoring, improve regulatory reporting, and reduce risk exposure, TOD is the solution.

With TOD, you’re not just managing tax data, but leveraging it to protect your institution, support your borrowers, and stay ahead in a rapidly evolving regulatory landscape.

Contact our partnership team to explore how TOD can transform your compliance operations and empower your lending practice.

Speak with the team to learn more