If the collateral property is not on SBA's NAICS code list, then the SBA environmental investigation required depends on the loan amount – it will either start with an environmental questionnaire for loans under $150K, or a more in depth Records Search with Risk Assessment or “RSRA” report. If an environmental concern is identified during these initial stages, then the level of due diligence increases – in some cases to the Phase I Environmental Report or even Phase II Environmental Testing. For a helpful guide to the SBA's environmental policy, check out our Steps of an SBA Environmental Investigation flowchart.

New Jersey has a long history of environmentally sensitive industries as well as a unique regulatory landscape. For example the Industrial Site Recovery Act or ISRA was enacted back in the 80s to help the state assess the impacts of industrial properties. In fact my colleague Brian Mende used to work for the New Jersey Department of Environmental Protection (NJ DEP) early in his career assessing these industrial sites. Sites listed on the ISRA database often have very large files detailing long histories of industrial operations, and these files should be reviewed during environmental due diligence. There is also the NJ Licensed Site Remediation Professional (LSRP) program that governs how site investigations and cleanups are done in New Jersey.