The 7(a) Lender charges an extraordinary servicing fee only for genuinely extraordinary work (construction draws, asset-based monitoring), within the SOP's annual cap, no higher than on its comparable non-SBA loans and not at all if it charges none there; it records the fee in the credit memorandum (delegated: enters it and certifies it reasonable) and reduces and refunds it if SBA finds it excessive. Installment changes, collateral releases and modifications of repayment terms are not extraordinary servicing. Out-of-pocket costs are itemized and kept for review; legal fees are charged hourly for work by or under a licensed attorney, with in-house counsel costs capped at outside counsel cost. Late fees are limited to the SOP's percentage of the payment after the stated days of delinquency; assumption fees match its non-SBA practice and stay within the SOP cap. For loans of 15 years or more, the Lender applies SBA's subsidy recoupment fee on large voluntary prepayments in the first three years and documents death-related prepayments as involuntary. SBA's guaranty covers none of these fees.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.