SystemAgricultural Lending

The complete guide · October 2026

FSA guaranteed loan servicing, explained.

When the USDA Farm Service Agency guarantees a bank's farm loan, it promises to cover up to 90% of the bank's loss if the farmer cannot pay. The promise holds only if the bank keeps up its side for the life of the loan: reports on fixed dates, a meeting and a written decision when payments stop, and a claim built to the agency's rules. This guide explains that work, the dates that govern it and what a missed date costs.

This guide is for anyone who services, reviews, signs or pays for FSA guaranteed farm loans: guaranteed-loan coordinators, ag loan officers, special assets officers, ag lending managers, credit administration and loan review, and the leaders deciding whether to automate the work. No background needed.

See one case, screen by screen →
Watch with transcript →
A quick example · fictional

Imagine you are the guaranteed-loan coordinator at Lindmark Valley Bank in Storm Lake, Iowa: the person who keeps FSA's dates on the bank's 218 guaranteed farm loans. On your desk this Monday, October 12, 2026, is Brandt Ridge Farms: Owen and Leah Brandt, 1,640 acres of corn and soybeans and a 2,400-head hog barn in Sac County. Their $1,150,000 operating term loan is 90% guaranteed. A disease outbreak in the barn in March cut their hog sales by 2,900 head, and the $213,560 installment due June 15 was never paid.

The rules started a clock that day. The loan went into default on July 15, 30 days late. The loan officer met the Brandts on July 28, inside the 45 days. You filed the agency's default status report on July 29 and again on September 25. The decision to restructure or liquidate is due within 90 days of default: tomorrow. The Brandts' restocking plan arrived on Friday, so the file is finally complete.

Option 1 · Restructure
Debt to reschedule
$1,072,855
7-year payment
$200,810
2027 coverage
1.08 times
Bank's policy
1.10 times
Option 2 · Liquidate
Net recovery
$787,600
Loss
$285,255
Agency pays 90%
$256,730
Bank keeps
$28,525, no customer
Ready on day 89with every unpaid dollar counted, both options and the rule behind every date on one page.

The first draft of the package rescheduled $1,001,895, the $978,760 of principal plus $23,135 of interest since June 15, for a payment of $187,528 and coverage of 1.12 times. It left out the year of interest inside the unpaid installment: $70,960, at 7.25% on $978,760. The screens in Part B show that first draft.

Counted in full, seven years falls short of the bank's 1.10 policy. Eight years would reach about 1.13, past the bank's own seven-year limit and inside the 15 years the rule allows. Whether to grant that exception or liquidate is your ag lending manager's call, made a day before the deadline. Had the decision slipped, the other clocks would have kept running: a liquidation plan and estimated loss claim by November 12, day 150 after the missed payment, and no interest from the agency after January 11, 2027, day 210.

The work catches the dollars a rushed package leaves out: here, $70,960 of interest that moves a seven-year restructure from inside the bank's policy to outside it, found the day before the decision is due.

FSA guaranteed loan servicing guide
Part A · Understand it

The FSA guarantee after closing: status reports, consents, the default clock and loss claims under 7 CFR 762

The duties a lender owes the Farm Service Agency for the life of a guaranteed loan, the dates set by 7 CFR part 762 as amended on October 1, 2026, the consents, the default clock, liquidation and loss claims, how claims get cut, and the numbers, explained without selling anything. If you are new to FSA guaranteed lending, start here.

01 · In plain words

FSA guaranteed loan servicing for a newcomer: what keeps the guarantee payable after closing

The Farm Service Agency (FSA), part of the US Department of Agriculture, helps farmers who cannot quite qualify for an ordinary bank loan. In its guaranteed program the bank makes the loan, and FSA promises to pay most of the bank's loss if the farmer fails: up to 90% of most loans and up to 95% in some cases.1 The promise, the guarantee, is backed by "the full faith and credit of the United States".2

The promise comes with a long list of conditions, and most of them apply after closing. The bank must service "the entire loan in a reasonable and prudent manner", protect the collateral and stay the secured party of record.3

It reports every loan to FSA twice a year. It reviews the farm's finances each year on the loans that need it. It asks FSA before it releases certain collateral or lets someone else take over the debt. And when a payment is 30 days late, a fixed series of dates begins: a meeting with the farmer, a report on FSA's form, a decision to restructure or liquidate, a liquidation plan, a loss claim.4,5

Nobody checks most of this at the time. FSA reads the file closely when the bank asks to be paid. If the bank was careless and the carelessness cost money, the guarantee "cannot be enforced by the lender" to that extent, "regardless of when the Agency discovers the violation".2 FSA reduces the claim by what the mistake cost, refuses interest that piled up while nobody acted, or rejects the claim.5

That makes FSA guaranteed servicing a job of dates as much as of credit judgment. A bank with a few hundred guaranteed loans carries a few thousand dates a year. Most misses come from the calendar: the report that was due on a Saturday, the decision that drifted past day 90 while the farmer's plan was still coming, or the claim that left a piece of collateral out.

One guaranteed loan from closing to the final loss claim

  1. The guarantee is issued and the loan closesBrandt Ridge Farms borrows $1,150,000 on April 3, 2024, 90% guaranteed by FSA. The loan note guarantee sets the terms FSA will honor.
  2. Years of routine servicingPayments, status reports as of March 31 and September 30, annual analyses where required, collateral checks, consents for releases and transfers.
  3. A missed payment starts the default clockDefault at 30 days late, a meeting within 45 days of the due date, a default status report every 60 days, a decision within 90 days of default.
  4. Restructure, or liquidate and claimA rescheduled note with a feasible plan, or a liquidation plan and estimated loss claim by day 150, interest from FSA ending by day 210.
  5. The final loss claim and afterFSA checks the claim within 40 days and reduces it for any loss the bank's servicing caused. The bank reports collection efforts for three more years and shares any later recovery.

Steps 2 to 5 are the subject of this guide; step 1 is the subject of the companion guide on FSA guaranteed loan origination. The people, farms, bank and figures in the example are fictional.

What surprises bankers new to FSA guarantee servicing

The dates come from the regulation

The default status report every 60 days, the 90-day decision, the 150-day plan and claim and the 210-day interest limit are written into 7 CFR 762.141, 762.143 and 762.149. A bank can file early; it cannot move them.6,4,5

The rules eased on October 1, 2026

Lenders other than Preferred Lenders now analyze performing term loans only when the borrower's term balances exceed $500,000, up from $100,000, and send FSA fewer analyses. FSA still reviews every loss claim and can cut one where a skipped analysis contributed to the loss.7

A program with no money still has a clock

FSA's interest assistance, a program that helped guaranteed borrowers with their interest cost, was last funded in fiscal 2011, yet the rule still bars foreclosure until 60 days after FSA decides the borrower's eligibility for it, and the default report still asks whether it was considered.8,9,4,10

Some money never comes back

Default interest, late charges, servicing fees, packager and consultant fees are never paid under a loss claim, and interest after day 210 is the bank's own.5

FSA-2248 default reports, lender classes, advances and loss claims

Default status report

FSA form FSA-2248. The bank files it after meeting a borrower whose loan is 30 days past due, then every 60 days until the default is cured by restructuring or liquidation.10,6

CLP, PLP and SEL

The three kinds of guaranteed lender: Standard Eligible, Certified and Preferred. The more trusted the status, the fewer approvals the lender must ask FSA for.11

Protective advance

Money the bank spends to protect the collateral, such as unpaid property taxes. A Certified Lender needs FSA's prior written approval for any above $5,000.5,12

Estimated and final loss claim

Two filings on FSA form FSA-2254. The estimate, due by day 150, pays FSA's share of the expected loss early; the final claim settles the account after the collateral is sold.5,13

Fourteen terms are defined in the one-page summary.

02 · The rules and their dates

7 CFR 762 after October 1, 2026: the servicing rules FSA lenders work to now

Status as of October 2026

In shortOne regulation governs FSA guaranteed servicing: 7 CFR part 762, sections 762.140 to 762.149, with definitions in 761.2. It was last amended by a final rule published September 4, 2026 and effective October 1, 2026, which raised the annual analysis threshold, cut what lenders send FSA and ended prior approval for most new unguaranteed loans. FSA's Handbook 2-FLP carries the procedures and is amended from time to time; check the current amendment. Each lender's agreement with FSA, and for Preferred Lenders their credit management system, adds to both.

Two rules in two years changed what an FSA guaranteed servicer must do

The servicing regulation and the notices that set lender status

  1. Feb 12, 1999Part 762 rewritten

    The current guaranteed loan rules, with Certified and Preferred Lender programs; CLP loss rate limit 7%, PLP 3%.

  2. Feb 23, 2024Lender volume eased

    CLP and renewing PLP lenders need 10 guaranteed loans closed in the past 5 years.

  3. Sep 25, 20242024 rule in force

    All lenders, PLP included, need FSA's written approval for a transfer and assumption; balloon restructurings no longer need a lien on all assets.

  4. Oct 1, 20262026 rule in force

    Annual analysis threshold $100,000 to $500,000; fewer analyses sent to FSA; new unguaranteed loans documented in the file; electronic filing.

Source 3,14,15,16,7,17,18,1

Show the numbers
WhenWhat
Feb 12, 1999Part 762 rewritten
Feb 23, 2024Lender volume eased
Sep 25, 20242024 rule in force
Oct 1, 20262026 rule in force
Nov 30, 2026Form clearance expires
PendingFarm bill
TextWhat it asks of a servicerStatus
762.103 Full faith and creditThe guarantee cannot be enforced by the lender "to the extent that the loss is a result of" usury, negligent servicing, failure to obtain the required security, or using loan funds for unapproved purposes.2In force
762.140 General servicingPrudent servicing of the whole loan; borrower supervision; the annual analysis; monitoring construction; applying payments by lien priority or due date.3Amended October 1, 20267
762.141 ReportingThe default status form at 30 days past due and every 60 days; status reports as of March 31 and September 30; CLP and SEL extras; collection reports for 3 years after a final loss payment.6Paragraphs (c) and (d) revised October 1, 20267
762.142 CollateralInsurance, taxes, proceeds, inspections; partial releases, subordinations, transfers and assumptions, and when FSA must consent.19Amended September 25, 202416
762.143 Distressed accountsDefault at 30 days past due; the meeting within 45 days of the due date; the decision within 90 days of default.4In force
762.144 to 762.146Holders' repurchase demands; restructuring and write-down; additional loans, releases of liability, rate changes and consolidation.20,21,22762.145 amended September 25, 2024; 762.146 amended October 1, 202616,7
762.149 LiquidationMediation, the liquidation plan, estimated and final loss claims, protective advances, acceleration, foreclosure bids, and the grounds for reducing a claim.5Paragraphs (d)(2)(i), (f) and (i)(6) amended October 1, 20267
FSA Handbook 2-FLPFSA's procedures for guaranteed loan making and servicing, including detail the regulation leaves out, such as when a protective advance may go on an estimated claim.13Check the current amendment before relying on any paragraph

What the October 1, 2026 rule changed for servicers

FSA called the annual analysis of strong, performing loans a review of "limited benefit" that cost lenders and its own staff "considerable time".7 From October 1, non-PLP lenders must analyze term loans only when the borrower's term-loan balances add up to more than $500,000, plus every line of credit and every loan in monetary or non-monetary default.

The analysis stays in the bank's file. A Certified Lender sends FSA its written summary only for lines of credit and defaulted term loans; a Standard Eligible Lender sends statements and a farm visit report only for those loans.7,6

Two other changes matter after closing. A Standard Eligible or Certified Lender may now make an additional unguaranteed loan without FSA's prior written approval, provided it documents five things in the file: the account is in good standing, the farm runs to its plan, the cash flow is still feasible, the guaranteed loan's security stays separate or senior, and sale proceeds go by lien priority. Payments the bank takes on an unguaranteed loan that misses those tests, ahead of the guaranteed loan, come off the loss claim.7,22 Servicing documents can also now go to FSA "through any electronic means designated by the Agency".7

The October 2026 rule raised two thresholds fivefold and twofold

7 CFR 762.140 (non-PLP lenders) and 762.127 (all lenders), before and after October 1, 2026

Before October 1, 2026From October 1, 2026
Term-loan balances above which an annual analysis is required$100K$500K
Largest loan whose real estate may be valued by an evaluation instead of an appraisal$250K$500K

Source 7 · The evaluation limit is $500,000 or the current OMB threshold, whichever is higher. Lines of credit and loans in default need an annual analysis at any balance.

Show the numbers
Before October 1, 2026From October 1, 2026
Term-loan balances above which an annual analysis is required$100K$500K
Largest loan whose real estate may be valued by an evaluation instead of an appraisal$250K$500K
The handbook could not be read for this guide. FSA's website did not answer automated requests in October 2026, so Handbook 2-FLP, its latest amendment and FSA's servicing refresher materials were not read. This guide cites the regulation, FSA's form instructions and FSA's own filings with the Office of Management and Budget instead, and says where the handbook adds detail you should check.
03 · A loan that pays

Status reports, annual analyses and collateral: an FSA lender's routine on a loan that pays on time

In shortOn a performing loan the routine is light but fixed: a status report on every loan as of March 31 and September 30, an annual analysis where the rule requires one, collateral kept insured, taxed and accounted for, holders paid their share, and FSA asked before certain changes. What the lender must send FSA, rather than keep in its own file, depends on its status: Standard Eligible, Certified or Preferred.

Preferred Lenders send FSA the least, but every lender keeps the same duties

What each kind of lender sends FSA on a guaranteed loan, after October 1, 2026

Kept in file or set by agreementSome loansEvery loan it applies to
Standard EligibleCertifiedPreferredStatus report, March 31 and September 30Every loan it applies toEvery loan it applies toEvery loan it applies toDefault status report every 60 daysEvery loan it applies toEvery loan it applies toEvery loan it applies toAnnual analysis summarySome loansSome loansKept in file or set by agreementBalance sheet and income statementSome loansKept in file or set by agreementKept in file or set by agreementFarm visit or collateral inspectionSome loansKept in file or set by agreementKept in file or set by agreementLine of credit certificationSome loansSome loansKept in file or set by agreementCopies of restructured notesEvery loan it applies toEvery loan it applies toEvery loan it applies to

Our reading of the sources 6,3,11,7

Show the numbers
Standard EligibleCertifiedPreferred
Status report, March 31 and September 30Every loan it applies toEvery loan it applies toEvery loan it applies to
Default status report every 60 daysEvery loan it applies toEvery loan it applies toEvery loan it applies to
Annual analysis summarySome loansSome loansKept in file or set by agreement
Balance sheet and income statementSome loansKept in file or set by agreementKept in file or set by agreement
Farm visit or collateral inspectionSome loansKept in file or set by agreementKept in file or set by agreement
Line of credit certificationSome loansSome loansKept in file or set by agreement
Copies of restructured notesEvery loan it applies toEvery loan it applies toEvery loan it applies to

The status report, twice a year, on every loan

Every lender submits a guaranteed loan status report "as of March 31 and September 30 of each year".6 The form is FSA-2241. FSA's finance office usually sends it with the first 22 items already filled from the last report; the lender checks them, corrects what changed and completes the rest.23 FSA estimated in 2023 that 1,763 lenders filed it twice a year, at about 20 minutes a loan.8

The regulation sets the as-of dates but not a filing deadline; a lender that files late gives FSA cause to revoke its Certified or Preferred status (section 09).11

The annual analysis, where the rule requires it

Since October 1, 2026, a non-PLP lender analyzes a borrower each year when its term loans to the borrower total more than $500,000, when the borrower has a line of credit, or when a loan is in default. For loans secured only by real estate the analysis covers the balance sheet; for loans secured by personal property it also compares the year's actual income and expenses with the plan; and it accounts for "the whereabouts or disposition of all collateral".7 Preferred Lenders follow their own credit management system.3

The collateral, all year

Section 762.142 lists the steady work: income and insurance assignments, marketable title, inspecting collateral "as often as deemed necessary", making sure the borrower does not sell security and keep the money, applying sale proceeds by lien priority, keeping taxes paid and insurance adequate, and protecting the loan in foreclosure, bankruptcy or condemnation.19

When a guaranteed portion has been sold to an investor, the holder, the lender passes on the holder's share of each payment; if it does not within 30 days of receipt, or if the borrower has paid nothing for 60 days, the holder can demand that the lender buy the loan back.20

04 · Consents

Releases, subordinations, transfers and new money: when FSA must agree in writing

In shortA lender may release collateral on its own when it is sold for market value and the money goes to the loan, traded for a like item taken as security, or worthless. Releasing collateral for nothing needs FSA's written approval and passes only if the loan stays at or under 75% of the remaining security's appraised value. Subordinating basic security, transferring the debt to a new borrower and releasing a liable person also need FSA in writing. New unguaranteed loans no longer do, from October 1, 2026, if the file shows why they are safe.

Most changes to collateral or borrowers need FSA's written consent, and every one needs a reason in the file

Common servicing actions for Standard Eligible and Certified Lenders, after October 1, 2026

Not neededIn some casesRequired
FSA's prior written consentCopy or notice to FSAReason documented in the fileRelease: sold at market value, proceeds to the loanNot neededIn some casesRequiredRelease: traded for a like item taken as securityNot neededIn some casesRequiredRelease with no considerationRequiredRequiredRequiredRelease for improvements that add valueRequiredRequiredRequiredSubordinate crops or livestock for a production loanNot neededNot neededRequiredSubordinate basic security to refinance a prior lienRequiredRequiredRequiredTransfer and assumptionRequiredRequiredRequiredRelease a person who left the operationRequiredRequiredRequiredChange the rate on a performing loanNot neededRequiredRequiredNew unguaranteed loan or advanceNot neededNot neededRequiredRestructure (Standard Eligible Lender)RequiredRequiredRequiredRestructure, no write-down (Certified Lender)Not neededRequiredRequired

Our reading of the sources 19,21,22,7

Show the numbers
FSA's prior written consentCopy or notice to FSAReason documented in the file
Release: sold at market value, proceeds to the loanNot neededIn some casesRequired
Release: traded for a like item taken as securityNot neededIn some casesRequired
Release with no considerationRequiredRequiredRequired
Release for improvements that add valueRequiredRequiredRequired
Subordinate crops or livestock for a production loanNot neededNot neededRequired
Subordinate basic security to refinance a prior lienRequiredRequiredRequired
Transfer and assumptionRequiredRequiredRequired
Release a person who left the operationRequiredRequiredRequired
Change the rate on a performing loanNot neededRequiredRequired
New unguaranteed loan or advanceNot neededNot neededRequired
Restructure (Standard Eligible Lender)RequiredRequiredRequired
Restructure, no write-down (Certified Lender)Not neededRequiredRequired

Preferred Lenders follow their lender's agreement for most of these; transfers and assumptions need FSA's written approval for all lenders since September 25, 2024.16 A rate change on a sold loan also needs the holder's consent or a repurchase.22

The 75% test on a release for nothing

When collateral is released "outright with no consideration", FSA may approve it only if the total unpaid balance of the guaranteed loan is "less than or equal to 75 percent of the value of the security for the loan after the release", leaving out growing crops and planned production, on a current appraisal. The lender sends a current balance sheet, the appraisal and the purpose of the release.19 Significant income-producing property is not released unless it is replaced, and business assets are never released as a gift.19

A release for nothing passes FSA's test while the loan stays at or under 75% of what remains

A $600,000 guaranteed loan; a family asks to release a 40-acre parcel worth $150,000 to a son

Appraised security before the release$1M
Security left after the release$850K
Most the loan may be: 75% of what is leftthe test$637.5K
Unpaid balance of the guaranteed loanpasses, $37,500 to spare$600K
Most the loan may be if a $260,000 parcel goeswould fail$555K

Illustrative · replace with your own numbers · Figures are assumptions. Use a current appraisal that meets 762.127 and exclude growing crops and planned production.

Show the numbers
ItemValue
Appraised security before the release$1M
Security left after the release$850K
Most the loan may be: 75% of what is left$637.5K
Unpaid balance of the guaranteed loan$600K
Most the loan may be if a $260,000 parcel goes$555K

Transfers, releases of liability and subordinations

A transfer and assumption needs FSA's written approval, a full application from the new borrower, who must meet the program's eligibility and loan limits, and a current appraisal unless the lien position stays the same. FSA documents its approval with a modification of the guarantee; any holder must be told, and must agree if the rate or terms change.19

A person who has withdrawn from the farm can be released from liability only with FSA's written consent and only if, among other tests, the debt is no more than 0.75 of the remaining security's value or the person has nothing to collect from.22

A lender may subordinate its lien on crops or livestock for a production loan when no guaranteed money paid for them, and may subordinate basic security only with FSA's written approval, to refinance a prior lien with no new debt.19

05 · The default clock

The default clock, from a missed installment to day 210

In shortA borrower is in default at 30 days past due. A Standard Eligible or Certified Lender meets the borrower within 15 days of default, which is 45 days after the due date, and files FSA's default status report; it files that report again every 60 days. It decides to restructure or liquidate within 90 days of default. If it liquidates, the plan and the estimated loss claim are due within 150 days of the due date, and FSA pays no interest beyond day 210. Each date counts from the missed payment or from default; get the starting point wrong and every later date moves.

Brandt Ridge Farms: seven dates from one missed installment

The example loan, OL-24-0318, $1,150,000, 90% guaranteed; installment due June 15, 2026

  1. Jun 15Installment due

    $213,560 unpaid. Day 0 for the 45-, 150- and 210-day dates.

  2. Jul 15Default

    30 days past due. Day 0 for the 90-day decision.

  3. Jul 28 · by Jul 30Meeting with the borrower

    Within 15 days of default, 45 days after the due date; a balance sheet and cash flow prepared for it.

  4. Jul 29 and Sep 25Default status reports

    After the meeting, then every 60 days; the next is due by November 24.

  5. Tue, Oct 13Restructure or liquidate

    Within 90 days of default, unless FSA extends it for documented reasons.

Fictional example from this guide · Dates from this guide's fictional example; the rules are 7 CFR 762.141, 762.143 and 762.149.

Show the numbers
WhenWhat
Jun 15Installment due
Jul 15Default
Jul 28 · by Jul 30Meeting with the borrower
Jul 29 and Sep 25Default status reports
Tue, Oct 13Restructure or liquidate
Thu, Nov 12Plan and estimated loss claim
Mon, Jan 11, 2027FSA's interest ends
DateCounted fromWhat is dueRule
Day 30Payment due dateThe loan is in default (also on any violation of the loan documents)762.143(a)4
Day 45Payment due dateMeet the borrower; current balance sheet and cash flow; summarize on FSA's default status form762.143(b)(3)4
Every 60 daysThe last default status reportFSA-2248 again, until cured by restructuring or liquidation762.141(a)6,10
Day 60 unpaidThe missed paymentA holder may demand the lender repurchase the guaranteed portion762.144(a)20
Default + 90DefaultDecide to restructure or liquidate762.143(b)(3)(iv)4
Day 150Payment due dateLiquidation plan and estimated loss claim (or a final claim if already fully liquidated)762.149(b), (d)5
Day 210Payment due dateFSA pays no interest beyond this, apart from narrow bankruptcy and redemption exceptions762.149(d)(2)5

Two waits that can push a liquidation later

The lender may not start foreclosure until 60 days after FSA has determined the borrower's eligibility for interest assistance, a program last funded in fiscal 2011; if neither side wants to consider servicing options, the file should say so and liquidation can begin.4,8,9

In a state with a mandatory farmer-creditor mediation program the lender must take part before it enforces.5 In Iowa, a creditor with $20,000 or more of secured debt must request mediation and receive a mediation release before it forecloses or repossesses farm property; the initial meeting falls within 21 days of the notice and the mediation period runs up to 42 days.24 FSA's certified mediation program had 44 participating states in 2026.25

Preferred Lenders service defaulted loans "according to their lender's agreement", so their dates may differ. A borrower who is current but sees a missed payment coming can be restructured before it is due.4

06 · The FSA-2248

The FSA-2248 default status report, every 60 days until the default is cured

In shortThe default status report is a one-page FSA form: the borrower and loan, the date the loan became delinquent, unpaid principal, accrued interest and the amount past due as of the report date, a status code, whether interest assistance was considered, and comments on what is being done. The first follows the meeting with the borrower; the rest follow every 60 days. FSA estimated in 2023 that lenders filed about 5,400 a year.

ItemWhat goes in itWhere it comes from
1 to 7FSA borrower ID, borrower name, lender ID and branch, lender's loan number, FSA loan number (shown on the last FSA-2241)The loan note guarantee and FSA's status report10
8Date the loan became delinquentPayment history
9 to 12Unpaid principal, accrued interest, total past due, all as of the report date in item 12Core loan system
13Delinquent code; some codes require reports every 60 days, others end them unless the borrower defaults againServicing notes and status10
14Interest assistance considered and ruled out, or requestedThe meeting10
15Comments on the action taken to correct the default or the borrower's statusMeeting notes, servicing notes, the borrower's plan
16Signature, title and date of the lender's authorized representativeThe person who signs

The meeting summary belongs on this form: the lender "will summarize the meeting and proposed solutions on the Agency form for guaranteed loan borrower default status completed after the meeting".4 The form can be filed on paper, by fax or electronically by lenders with USDA access credentials.10 The arithmetic is simple. The judgment is in item 15: a short, true account of why the farm missed the payment and what is being done, which FSA will read again if a claim follows.

Default status reports are the most frequent servicing filing after the twice-yearly status report

FSA's own yearly estimates of lender filings and requests in the guaranteed program, from its 2023 Paperwork Reduction Act statement

Default status reports (FSA-2248)about 900 every 60 days5,400
Restructurings, all lenders768
Loss claim responses (FSA-2254)464
Liquidation plans435
Protective advance requests335
Partial release requests300
Acceleration notices sent to FSA300
Mediation meetings100

Source 8 · Restructurings: 627 by Standard Eligible Lenders, 70 by Certified Lenders and 71 copies from Preferred Lenders. Status reports, filed twice a year on every loan, are not shown; FSA counted 52,490 loans outstanding in April 2023.

Show the numbers
ItemValue
Default status reports (FSA-2248)5,400
Restructurings, all lenders768
Loss claim responses (FSA-2254)464
Liquidation plans435
Protective advance requests335
Partial release requests300
Acceleration notices sent to FSA300
Mediation meetings100
About 2 in 100 guaranteed loans were delinquent in FSA's 2023 estimate
1.70 in 100

FSA's 2023 statement put the guaranteed program's average delinquency rate, measured in loans, at 1.70%: about 900 default status reports every 60 days.

Source 8

Show the numbers
MeasureValue
FSA's 2023 statement put the guaranteed program's average delinquency rate, measured in loans, at 1.70%: about 900 default status reports every 60 days.1.7 of 100

FSA's newer delinquency figures sit on pages that could not be read for this guide. Its April 2026 notice says it now receives far fewer default status reports and loss claims than in fiscal 2022, and proposes 97,897 responses a year across the guaranteed program's forms, down from the 174,674 the Office of Management and Budget approved in July 2025.17,26

07 · Restructure or liquidate

Restructure or liquidate: the 90-day decision worked through with numbers

In shortWithin 90 days of default the lender chooses. A restructuring needs a feasible plan, current financial statements from everyone liable, verified debts and income, three years of history behind the projections, a security position no worse than before, and the holder's agreement. Operating loans may be rescheduled up to 15 years. A Certified Lender needs FSA's prior written approval only for a write-down and otherwise sends a certification and a narrative; a Standard Eligible Lender asks first for any restructuring. Liquidation means the collateral is sold and FSA pays its share of what is left.

The two options for Brandt Ridge Farms

Start with the example from the top of this page as the package's first draft counts it, the same figures the screens in Part B show. The draft adds the $23,135 of interest accrued since June 15 to the $978,760 of principal and reschedules $1,001,895 over seven years at the note rate of 7.25%, first installment December 15, 2027, after the restocked barn's first full year.

The 2027 cash flow leaves $437,600 for debt service. This loan's new installment is $187,528, a real estate loan with another lender takes $158,200 and equipment notes $46,300: $392,028 in all. Coverage is $437,600 ÷ $392,028 = 1.12, against the bank's 1.10 policy. The collateral is worth $1,428,000, so the loan is 70% of its value. Liquidation would net $787,600 after costs: a $214,295 loss, $192,866 from FSA at 90% and $21,429 for the bank.

The interest the first draft leaves out. The unpaid June 15 installment carried a year of interest, $70,960 (7.25% of $978,760), and that interest is still owed too. The draft, like the screens, counts only the $23,135 accrued since June 15. Counted in full, the debt to reschedule is $1,072,855; over seven years the installment would be about $200,810 and coverage about 1.08 times, under the bank's 1.10 policy (eight years would give about 1.13), and liquidation would lose about $285,255, FSA's 90% about $256,730. A real decision package counts all unpaid interest at the note rate, which 7 CFR 762.145 lets the lender capitalize.21
On the first draft's figures, liquidating costs FSA about $193,000 and the bank about $21,000

Brandt Ridge Farms, the two options as the first draft and the screens lay them out on October 12, 2026

Restructure, 7 yearsLiquidate now
Expected loss to FSA$0$192.9K
Expected loss to the bank$0$21.4K
Payment the farm owes each year$187.5K$0

Fictional example from this guide · The restructure's expected loss is zero only if the plan performs; the draft's coverage of 1.12 times leaves $45,572 of margin in 2027. Counted with the installment's $70,960 of interest, liquidation would lose about $285,255, FSA's share about $256,730 (the callout above).

Show the numbers
Restructure, 7 yearsLiquidate now
Expected loss to FSA$0$192.9K
Expected loss to the bank$0$21.4K
Payment the farm owes each year$187.5K$0
On the first draft's figures, only the seven-year term clears the bank's 1.10 policy

Brandt Ridge Farms: $1,001,895 rescheduled at 7.25%, annual installment by term, as the screens count it

$246K5 years
$211.8K6 years
$187.5K7 years

Fictional example from this guide · $437,600 is left for all debt service and other debts take $204,500 a year, so coverage is 0.97 times at 5 years, 1.05 at 6 and 1.12 at 7. The rule allows an operating loan note up to 15 years; 7 years is the example bank's own limit. Counting the installment's $70,960 of interest, 7 years gives about 1.08 and 8 years about 1.13.

Show the numbers
PeriodValue
5 years$246K
6 years$211.8K
7 years$187.5K
RequirementWhat the rule says
Feasible planThe borrower's ability to make the amended payment is documented by a feasible plan, current statements from all liable parties, verified nonfarm income and debts, credit reports and three years of history.21
TermsFarm ownership notes up to 40 years from the original note; operating notes up to 15 years from rescheduling; lines of credit up to 7 years, or 10 from the original note if less.21
InterestAccrued interest at the note rate may be capitalized within the loan limits; late fees and default interest may not. FSA modifies the guarantee when principal rises.21
Security and balloonsThe lender's security position may not be hurt. A balloon must leave the loan fully secured when it falls due, with at least 5 years to the balloon on real estate loans and 3 on others.21,16
HolderAny holder must agree to the new terms, or the lender repurchases the guaranteed portion first.21
Who approvesStandard Eligible: FSA's prior written approval, with FSA's refusal in writing within 14 days. Certified: approval only for write-down; otherwise a certification, a narrative and the calculations. Preferred: per agreement. All lenders send copies of restructured notes.21
Write-downOnly enough to permit a feasible plan, with FSA's calculations and approval; FSA estimated about 10 a year in 2023.21,8

A restructuring does not protect the lender from later scrutiny: a final loss claim "may be reduced, adjusted, or rejected as a result of negligent servicing after the concurrence with a restructuring action".21

08 · Liquidation and loss claims

Liquidation plans, protective advances and the estimated and final loss claims

In shortOnce the decision is to liquidate, the lender writes a plan within 150 days of the due date: balance sheets, how it will collect, an independent appraisal of all collateral and its net recovery value, the time it will take, expected costs and protective advances. FSA has 20 calendar days to approve or ask for changes. By the same day 150 the lender files an estimated loss claim on FSA-2254, and FSA pays its share of the expected loss. After the sale comes the final claim, which FSA must decide within 40 days.

What goes in the liquidation plan

A Standard Eligible or Certified Lender's written plan includes current balance sheets from everyone liable, a method for collecting the debt including any judgment, an independent appraisal of all collateral that meets 762.127 with a calculation of net recovery value, an estimate of time, reasonable liquidation expenses and expected protective advances. If the borrower sold collateral and kept the money, the plan must say whether civil or criminal action will follow.5

Net recovery value is market value less the costs of acquiring, holding, maintaining and selling the property; liquidation expenses include appraisals, environmental work and outside attorney fees, but never in-house costs.12 If FSA neither approves the plan nor asks for revisions within 20 calendar days of receiving it, the lender may assume it is approved.5

FSA's 2023 statement describes Standard Eligible and Certified Lenders submitting the plan "within 30 days of the decision to liquidate"; the regulation's outer limit is 150 days from the due date. Check the current Handbook 2-FLP for the timing FSA applies.8,5

The estimated loss claim, worked through

The estimate pays "the guaranteed percentage of the total outstanding debt, less the net recovery value of the remaining security, less any unaccounted for security", and interest accrual stops when FSA pays it, never later than day 210.5

Take the example's Kessler Dairy, a $1,326,400 farm ownership loan at 6.875%, 90% guaranteed, whose June 1 installment went unpaid. Interest to the claim date, day 150, is $1,326,400 × 6.875% ÷ 365 × 150 = $37,475. Liquidation costs are an appraisal ($4,800), legal fees ($18,500) and sale commissions ($43,800). The land, parlor and barns are appraised at $1,118,000 and the dairy equipment, under a separate lien, at $96,000.

Leaving the dairy equipment out would have overstated Kessler's loss by $96,000

Kessler Dairy's estimated loss claim as the bank drafted it: what is owed and spent, and how it is covered

Principal and interest to day 150Tax advance and liquidation costsLand, parlor and barnsDairy equipmentEstimated loss
Owed and spent, $1,439,395$1.4M
Covered by, $1,439,395$1.1M$225.4K

Fictional example from this guide · The draft's estimated loss is $225,395, FSA's 90% share $202,856. Without the equipment the loss would read $321,395. On FSA's form a protective advance such as the $8,420 tax advance is normally left off the estimate and paid with the final claim; without it the estimate is $216,975 and FSA's share $195,278.

Show the numbers
Principal and interest to day 150Tax advance and liquidation costsLand, parlor and barnsDairy equipmentEstimated loss
Owed and spent, $1,439,395$1.4M$75.5K$0$0$0
Covered by, $1,439,395$0$0$1.1M$96K$225.4K

Protective advances

A protective advance protects or preserves the collateral: paying the real estate taxes, insuring a building, feeding livestock held as security.12 It may be made only when the borrower is in liquidation, liquidation is imminent or the lender owns the property after foreclosure, only when it is in both the lender's and FSA's interest, and never in place of a new loan. It must be a debt of the borrower secured by the security instrument. Legal fees are not protective advances.5

Above $5,000 for a Certified Lender, or $3,000 for a Standard Eligible Lender, the lender needs FSA's prior written authorization; FSA pays its share of the advance and its interest "when the final loss claim is approved, except in bankruptcy actions".5 FSA's form instructions say the advance lines "should not be completed on an estimated loss claim" except as Handbook 2-FLP allows.13

From the decision to liquidate to the last report, a claim passes through six steps
  1. 1Plan written

    Balance sheets, collection method, independent appraisal of all collateral, net recovery value, time, costs, advances.

    Special assets officerBy day 150
  2. 2FSA reviews the plan

    Approve or ask for revisions; silence for 20 calendar days counts as approval.

    FSA farm loan officer20 days
  3. 3Estimated claim paid

    FSA-2254 report type 01; FSA pays its share of the expected loss; interest stops.

    Lender, then FSABy day 150 to 210
  4. 4Collateral sold

    Mediation release, acceleration notice copied to FSA, foreclosure bid at least the lesser of net recovery value or the guaranteed balance.

    Special assets and counselMonths
  5. 5Final claim decided

    FSA-2254 report type 02 with accountings and the loan ledger; FSA decides within 40 days or pays extra interest.

    Lender, then FSA40 days
  6. 6After the claim

    Repay any overpayment with interest; report collection efforts yearly for 3 years; share later recoveries.

    Lender3 years

Our reading of the sources 5,13,6

Show the numbers
StepWhat happensWhoTime
Plan writtenBalance sheets, collection method, independent appraisal of all collateral, net recovery value, time, costs, advances.Special assets officerBy day 150
FSA reviews the planApprove or ask for revisions; silence for 20 calendar days counts as approval.FSA farm loan officer20 days
Estimated claim paidFSA-2254 report type 01; FSA pays its share of the expected loss; interest stops.Lender, then FSABy day 150 to 210
Collateral soldMediation release, acceleration notice copied to FSA, foreclosure bid at least the lesser of net recovery value or the guaranteed balance.Special assets and counselMonths
Final claim decidedFSA-2254 report type 02 with accountings and the loan ledger; FSA decides within 40 days or pays extra interest.Lender, then FSA40 days
After the claimRepay any overpayment with interest; report collection efforts yearly for 3 years; share later recoveries.Lender3 years

The final loss claim

When the collateral has been sold and every dollar applied, principal first, the lender files the final claim with an accounting of the use of loan funds, an accounting of the collateral and its proceeds, and "a copy of the loan ledger" showing advances, rate changes, protective advances and every payment, with a running balance.5

FSA must notify the lender of any discrepancy, or approve or reject the claim, within 40 days; if it takes longer, it pays additional interest for each day over 40.5 If the final loss is less than the estimate, the lender repays the difference "plus interest at the note rate from the date of the estimated loss payment". It returns the original guarantee marked paid, and for three years after the final payment it reports its collection activity on each unsatisfied account.5,6

09 · How claims get cut

Negligent servicing: the lapses for which FSA cuts or rejects a loss claim, and what a month of delay costs

In shortFSA "will reduce a final loss claim based on its calculation of the dollar amount of loss caused by the lender's negligent servicing". Negligent servicing includes "failure to act or failure to act in a timely manner". The regulation names the usual causes: collateral not secured after default, interest that built up while the lender took no action, unauthorized releases of proceeds, ownership of security never verified, and collateral not inspected. Deficiencies that did not materially add to the loss do not reduce the claim.

What went wrongHow FSA measures itRule
No contact, no action after defaultThe claim "will be reduced by the amount of interest that accrues" while the lender fails to contact the borrower or act; interest from "excessive delays in collection" is not paid762.149(i)(6)(i)5
Collateral not secured after defaultReduced by the loss the failure caused762.149(i)(6)(i)5
Proceeds released without authorityReduced or rejected762.149(i)(6)(ii)5
Collateral not inspected; ownership not verifiedReduced or rejected where it let the security deteriorate or disappear762.149(i)(6)(ii)5
Security unaccounted forDeducted from the estimate; no reduction if the lender searched as hard as it would for its own loan762.149(d)(1), (i)(7)5
Unapproved loans paid ahead of the guaranteed loanThose payments are deducted from the claim762.149(f)7
Origination under delegated authorityFrom October 1, 2026, loans a Preferred Lender made with delegated authority that missed eligibility, feasibility or security rules762.149(i)(6)(iii)7
Interest after day 210, default interest, late charges, servicing feesNever payable762.149(d)(2), (i)(8)5

What a month of delay costs

Interest is where slow servicing shows up first. On a $1,326,400 loan at 6.875%, each day adds about $250 of interest. While the lender acts on time, FSA covers 90% of it up to day 210. Interest that accrues while the lender "fails to contact the borrower or takes no action to cure the default" comes off the claim, and after day 210 none is paid.5

Each month a defaulted $1.3 million loan sits idle adds about $7,500 of interest FSA can refuse

Interest at 6.875% on $1,326,400 of principal, by days of delay

30 days$7,495
60 daysone missed default report cycle$15K
90 days$22.5K
120 days$30K

Illustrative · replace with your own numbers · Daily interest = $1,326,400 × 6.875% ÷ 365 = $249.83. Whether FSA deducts a given period depends on its finding that the lender failed to act; FSA would otherwise have paid 90% of it.

Show the numbers
ItemValue
30 days$7,495
60 days$15K
90 days$22.5K
120 days$30K

The cost to the lender's status

Repeated slips cost more than one claim. FSA may revoke a Certified or Preferred Lender's status for "Failure to submit status reports in a timely manner", for deficiencies "that indicate an inability to process or service" guaranteed loans, or for a loss rate above the maximum FSA sets.11

The 1999 notice still on record set that maximum at 7.00% for Certified Lenders and 3.00% for Preferred Lenders, with the loss rate defined as net loss claims paid on loans made in the previous seven years divided by the amount of those loans.14,12 A lender that drops to Standard Eligible status must ask FSA's approval before every restructuring and send more paper with every annual analysis.21,6

10 · The numbers

FSA's guaranteed portfolio in 2026: 31% fewer loans, larger new loans, more farms behind on payments

In shortFSA counted 35,984 guaranteed loans outstanding in fiscal 2025, 31% fewer than three years earlier, while fiscal 2025 lending rebounded: $2.09 billion of guaranteed farm ownership loans, up 41%. Farm credit is weakening. In the Seventh Federal Reserve District, which includes Iowa, 3.7% of farm loans at agricultural banks had major or severe repayment problems in the second quarter of 2026, the highest share since 2020. Fewer loans, larger ones and more of them in trouble means more defaulted dollars per servicer.

FSA's guaranteed book shrank by almost a third in three years

Counts from FSA's own Paperwork Reduction Act filings

Earlier countLater count
Guaranteed loans outstanding (fiscal 2022, then fiscal 2025)52,49035,984
New guaranteed loans in a year (fiscal 2019, then fiscal 2022)7,6116,137

Source 8,17 · FSA's April 2026 notice gives both loan counts and the 31% fall; its 2023 statement dated the 52,490 count April 5, 2023. FSA's estimate of lenders filing in the program was 5,072 in 2026.

Show the numbers
Earlier countLater count
Guaranteed loans outstanding (fiscal 2022, then fiscal 2025)52,49035,984
New guaranteed loans in a year (fiscal 2019, then fiscal 2022)7,6116,137
3.7%

of farm loans at Seventh District agricultural banks had major or severe repayment problems in the second quarter of 2026, up from 2.9% a year earlier and the highest since 2020. Lenders expected more FSA-guaranteed loans in the third quarter.27

Federal Reserve Bank of Chicago, August 2026
$2.09B

of guaranteed farm ownership loans obligated in fiscal 2025, up 41% in dollars and 24% in count; 2,291 guaranteed operating loans, up 21% in count.1

American Farm Bureau Federation, September 2026
1.50%

of loans at the FDIC's agricultural banks were past due 30 days or more or on nonaccrual on June 30, 2026; 0.87% were noncurrent.28

FDIC Quarterly Banking Profile, Q2 2026

The pressure comes from margins. USDA's Economic Research Service forecast 2026 net farm income at $158.4 billion, down 2.6% from 2025 before inflation and 5.5% after it, with farm debt up 4.6% to $605.1 billion.29

Kansas City Fed lenders reported in August that credit conditions kept tightening, though most repayment problems stayed minor; about 2% of farm loans at the largest agricultural banks were 30 days or more past due in the first quarter, under 1.5% at smaller ones.30,31 In the Chicago Fed's survey, renewals and extensions of operating loans rose and 27% of lenders reported lower repayment rates, none higher.27

Nearly nine in ten bankrupt FSA guaranteed borrowers chose Chapter 12, the farmers' chapter

Bankruptcy filings by FSA guaranteed loan borrowers, 2015 to 2025, by chapter

Chapter 12: 87%Chapter 13: 8.3%Chapter 11: 3%Chapter 7: 1%
157filers
  • Chapter 1287%
  • Chapter 138.3%
  • Chapter 113%
  • Chapter 71%

Source 32 · FSA learns of a guaranteed borrower's bankruptcy only if the lender reports it, so the count may be low. Wisconsin had 24.5% of filers; dairy farms about a quarter.

Show the numbers
PartValue
Chapter 1287%
Chapter 138.3%
Chapter 113%
Chapter 71%

Bankruptcy is rare among guaranteed borrowers, who tend to run larger operations: 157 filed between 2015 and 2025, peaking at 22 in 2018, against roughly 2,900 FSA direct borrowers.32 Each filing changes the servicing: a stay on collection, the bankruptcy rules on interest and estimated claims, and a different settlement date on FSA's claim form.5,13

11 · How teams do it today

The coordinator, the loan officer and special assets: how ag banks keep FSA's dates today, and where a default's hours go

In shortAt most ag banks one coordinator keeps FSA's dates for the whole guaranteed book, with loan officers, special assets, the lending manager and loan operations each holding part of the work. The dates live in calendars, spreadsheets and paper files; the filings are typed from the core system and servicing notes. The routine reports are quick. The hours go into defaulted loans: the cash flow and the decision, the plan and the claim, and keeping every date on time while gathering documents from the farm.

GC

USDA guaranteed-loan coordinator

Keeps FSA's dates for every guaranteed loan; prepares status reports and default status reports; is the bank's contact with the FSA county office.

Cares about: no date missed across a few hundred loans.
LO

Ag loan officer

Owns the farm relationship: annual analyses, farm visits, the meeting with a borrower in default, the plan and its numbers.

Cares about: keeping the family farming if the plan works.
SA

Special assets officer

Works liquidations: mediation, appraisals, auctions, counsel, the liquidation plan and the loss claims.

Cares about: a claim FSA pays as filed.
LM

Ag lending manager

Approves restructure-or-liquidate decisions and claims; owns the bank's FSA lender status and its loss rate.

Cares about: the guarantee being there when the bank needs it.
OP

Loan operations

Posts payments, remits holders' shares, keeps balances and rates in the core, produces the loan ledger for a claim.

Cares about: numbers that match the core.
FS

FSA farm loan officer

Outside the bank: receives the filings, approves plans, restructurings and claims, and reviews the lender's servicing.

Cares about: a complete file the first time.
A defaulted guaranteed loan crosses five desks and FSA before it is settled
  1. 1Payment missed

    The core shows the installment unpaid; the date is copied to a calendar or spreadsheet.

    Loan operations, coordinatorDay 0
  2. 2Meeting and first report

    The officer meets the borrower; the coordinator types the FSA-2248 from the officer's notes.

    Loan officer, coordinatorBy day 45
  3. 3Reports every 60 days

    Each report rebuilt from the core and new notes, signed and sent.

    CoordinatorEvery 60 days
  4. 4Decision

    Statements gathered, cash flow built, options compared, the manager approves.

    Loan officer, analyst, managerBy default + 90
  5. 5Plan and claim

    Appraisal, auctioneer, counsel, mediation; the plan and FSA-2254 assembled with attachments.

    Special assets, coordinatorBy day 150
  6. 6FSA decides

    Plan approval, the estimated payment, later the final claim and its 40-day review.

    FSA farm loan officer20 and 40 days

Illustrative · replace with your own numbers

Show the numbers
StepWhat happensWhoTime
Payment missedThe core shows the installment unpaid; the date is copied to a calendar or spreadsheet.Loan operations, coordinatorDay 0
Meeting and first reportThe officer meets the borrower; the coordinator types the FSA-2248 from the officer's notes.Loan officer, coordinatorBy day 45
Reports every 60 daysEach report rebuilt from the core and new notes, signed and sent.CoordinatorEvery 60 days
DecisionStatements gathered, cash flow built, options compared, the manager approves.Loan officer, analyst, managerBy default + 90
Plan and claimAppraisal, auctioneer, counsel, mediation; the plan and FSA-2254 assembled with attachments.Special assets, coordinatorBy day 150
FSA decidesPlan approval, the estimated payment, later the final claim and its 40-day review.FSA farm loan officer20 and 40 days
On a defaulted loan, the plan and claim and the decision take most of the hours

Estimated hours for one defaulted guaranteed loan, from default to a filed claim, done by hand

Liquidation plan and loss claimCash flow and the decisionKeeping the datesDefault status reportsReview and signatures
About 41 hours by hand16 h12 h6 h4 h

Illustrative · replace with your own numbers · An estimate from the solution's own design data; no public source measures it. FSA's own figure for completing an FSA-2254 is 25 hours a response. Time one defaulted loan of your own.

Show the numbers
Liquidation plan and loss claimCash flow and the decisionKeeping the datesDefault status reportsReview and signatures
About 41 hours by hand16 h12 h6 h4 h3 h

Spreadsheets, core ticklers or outside help for FSA dates

ApproachHow it worksWhere it strains
One coordinator, spreadsheetsDates in a calendar and a spreadsheet; forms typed from the core and notes; officers send what is asked for.Several defaults at once; vacations; the rules changing, as on October 1, 2026.
Ticklers in the core or loan softwareReminder codes for status reports and annual reviews; default dates entered by hand.A tickler sends the reminder; someone still counts each date from the right event and types the filing.
Outside helpConsultants, correspondent banks or counsel for complex liquidations and claims.Consultant and packager fees are never paid under a loss claim.5

No public survey shows which tools ag banks use to keep FSA's dates. The approaches above are the common patterns, and nobody has measured their shares.

Part B · See it working

Botminds FSA Guaranteed Loan Servicing at Lindmark Valley Bank, a fictional Iowa Certified Lender

Part A described the work without naming a product. This part shows how Botminds does it at Lindmark Valley Bank, a fictional Certified Lender in Storm Lake, Iowa, with 218 FSA guaranteed loans, $187.4 million of principal and $166.9 million guaranteed. Every bank, farm, person, number and document on these screens is sample data. Where a screen cites a paragraph of 7 CFR 762 differently from the regulation, the caption gives the correct one.

12 · One Monday, start to finish

One Monday at Lindmark Valley Bank: a default report signed five days early, the Brandt decision on day 89, a Kessler claim corrected

In shortRenee Albrecht, the bank's USDA guaranteed-loan coordinator, starts the day on a board of countdown clocks, one for every FSA date in the next 30 days. Overnight one turned red and its default status report was filled in from the loan's documents. She looks three weeks ahead, signs that report five days early, prepares the 90-day decision on Brandt Ridge Farms with her manager's approval, and stops a loss claim for Kessler Dairy that left $96,000 of collateral out.

1

Every FSA date as a clock, re-counted at 5 a.m.

Each tile is one deadline: the days left, the due date, the rule or the FSA form, the borrower, the guarantee at stake and the state of the filing. At 5:00 a.m. the guarantee clock keeper re-counted 1,284 dates on 218 loans from the loan note guarantees, the payment history and 7 CFR 762. Pettibone Orchards' second default status report went from six days to five and turned red; at 5:02 a.m. its FSA-2248 was filled in. A clock turns amber inside the bank's 10-business-day lead time and red at its five-day reminder.

Brandt Ridge Farms leads the board: its restructure-or-liquidate decision is due tomorrow.

The clock board. One tile per FSA date in the next 30 days, red at five days, with the night's run log above and the selected filing beside it.
2

Three weeks ahead, before signing anything

Renee moves the board forward 21 days, to Monday, November 2. If nothing were signed by then, 15 clocks would run out, 43 filings, with $4.40 million of guarantee exposed on 7 loans; 14 of those filings are already prepared and waiting for a signature today. The look-ahead turns a list of dates into a list of signatures.

A note on the annual analysis tiles: they count the bank's own review list. Under the rule in force since October 1, 2026, a Certified Lender analyzes performing term loans only above $500,000 in aggregate, and sends FSA summaries only for lines of credit and defaulted loans.7

Three weeks ahead. What would run out unsigned, and the guarantee it would put at risk.
3

The default status report, every line with its source

Pettibone Orchards' operating term loan, OL-23-0207: principal $641,200, 90% guaranteed. The $148,900 installment due July 6 is unpaid; on October 12 the loan is 98 days past due with $12,051 of accrued interest. The cause comes from a servicing note: a spring freeze on April 21 cut the apple crop by 55%. Cooperation comes from the August 13 meeting at the farm market.

The planned action lists fall market sales of $212,400 to October 10 and an $86,400 crop insurance claim, with the restructure-or-liquidate decision due November 3. Each line links to the payment history, the note or the claim it came from.

The FSA-2248, filled in. Every line carries the document it came from, and the next report date.
4

Signed five days early, with the meaning of the signature

Renee reads it and signs with the meaning "I reviewed this report and its sources". The report goes to Dana Kroeger, the FSA farm loan officer at the Storm Lake service center, five days before Saturday's due date.

Sign and send. Who it goes to, when the next report falls due, and what the signature means.
5

The next 60-day clock starts at once

The red tile becomes a fresh clock to the next report, Wednesday, December 16, and the form shows who signed, where it went and that it was five days early. Every signature lands on the audit trail.

Filed, and the clock restarted. The next report is due 60 days after this one would have been.
6

Brandt Ridge Farms: the loan on its own clock

Renee opens the decision due tomorrow. Unpaid installment $213,560, due June 15; principal $978,760 at 7.25% with $23,135 of interest accrued over 119 days; guaranteed share $880,884, or $901,706 with interest. The screen counts interest only from the June 15 due date; the year of interest inside the unpaid installment, $70,960, is owed too (section 07 gives the full figures).

The clock runs from the due date through default (July 15), the meeting (July 28, deadline July 30) and two default reports to the decision on October 13, then the plan and claim date, November 12, and the end of FSA's interest, January 11, 2027. Each step shows its rule.

One loan's guarantee clock. Every date from the missed payment to day 210, today marked at day 119.
7

The decision package, built from nine documents

The Brandts' restocking plan arrived on Friday, completing the file. Renee presses "Prepare decision package" and in 1 minute 17 seconds four agents read the guarantee, the note, the payment history, the meeting notes, both default reports, the 2025 statements, the veterinarian's letter, the plan and the collateral inspection. They confirm the dates, read the statements (net worth $1,836,400, current ratio 0.92, 2025 net farm income $96,400), build the 2027 cash flow with the barn restocked in January, compare the two options, check the security and draft the filings.

The run, step by step. What each agent read and found, in seconds, with the comparison flagged for a person to decide.
8

Two options side by side; a person decides

Restructure: reschedule $1,001,895 over 7 years at 7.25%, first installment December 15, 2027, $187,528 a year, covering debt 1.12 times against the bank's 1.10 policy at 70% loan-to-value. Liquidate: $787,600 net recovery, a $214,295 loss, $192,866 from FSA and $21,429 for the bank.

The 2027 cash flow beneath shows every line with its source document. The term buttons show why seven years: five years covers 0.97 times and six 1.05. Seven is the bank's own limit; the rule allows an operating note up to 15 years.21 These are the first draft's figures. On the full debt, with the installment's $70,960 of interest, seven years covers about 1.08 times, under policy, and liquidation loses about $285,255 (section 07).

Restructure or liquidate. Both options with the numbers behind them; the coordinator signs and the ag lending manager approves.
9

Approved a day early, filings drafted

Renee signs the restructure; Curt Vandermolen, the ag lending manager, approves it. Three documents go out: the restructuring filing with the cash flow, an updated default status report marked "restructuring proposed", and a letter to Owen and Leah Brandt that is sent when FSA agrees. For a Certified Lender, FSA's prior written approval is needed only for a debt write-down; for a rescheduling like this one the bank sends a certification that each requirement of 762.145 is met, a narrative and its calculations, which is what the drafted "restructuring request" carries.21

Approved and sent. Two signatures, three drafted documents and the record of who did what.
10

Kessler Dairy's claim, and two gaps found before filing

Kessler Dairy's June 1 installment went unpaid; the bank decided to liquidate on September 22, inside the 90 days. The liquidation plan and estimated loss claim are due Thursday, October 29, day 150. The loss claim assembler built the worksheet line by line and stopped it twice.

The October 9 appraisal values the land, parlor and barns only, but the bank also holds a lien on the dairy equipment, which an auctioneer estimated at $96,000: left out, the claim shows a $321,395 loss instead of $225,395. And the county treasurer's receipt for the $8,420 tax advance is in the loan file but not the claim package.

Two gaps found before filing. Each with the documents that prove it and a button to fix it.
11

Fixed, checked, ready for signatures

Tamsin Hale, the special assets officer, adds the equipment and attaches the receipt. The estimate falls to $225,395 and FSA's 90% share to $202,856, and eight checks pass, from the 150-day date to the interest inside the 210-day limit. Renee signs, Curt approves, and it goes to the FSA office.

Two corrections to this screen. FSA pays a protective advance "when the final loss claim is approved", and its claim form says the advance lines should not be completed on an estimated claim except as Handbook 2-FLP allows. Left off, the estimate is $216,975 and FSA's share $195,278, with the $8,420 and its interest claimed at the end.5,13

The interest limit is 7 CFR 762.149(d)(2) and the plan rule 762.149(b), where the screen prints 762.149(i), (a) and (d); FSA's 20-day review applies to the liquidation plan.5 The screen labels the $43,800 sale commission 4%, which does not match the appraised values (4% of $1,214,000 is $48,560); read it as the sample's quoted fee.

Fixed and checked. Every figure tied to its document; on FSA's form the tax advance would wait for the final claim.
13 · The rest of the book

Three more screens: thirty days of FSA dates, the September 30 status reports and the 7 CFR 762 clocks the bank cannot edit

In shortThree more screens carry the rest of the work. The deadline monitor lays every date in the next 30 days on a timeline by kind. The reports screen holds the September 30 status reports and the default status report cycle. The settings show FSA's dates as fixed, each with its rule, and the bank's own lead times, thresholds and approvers as choices.

1

Thirty days of dates, by kind

Forty-five dates in the next 30 days, 11 of them on default clocks; 12 prepared and waiting for Renee's signature; 9 waiting on a borrower's statements or cash flow; none missed this year. The timeline sorts them into decisions, loss claims, default reports, meetings, a holder's repurchase demand, status reports, line of credit certifications, annual analyses, farm visits and lien continuations. The list beneath gives each date's rule, days left, who prepared it and its state, and exports to a calendar.

The 30-day deadline monitor. Every date by kind, with counts of what is ready and what waits on the borrower.
2

Status reports as of September 30, and the default report cycle

212 of 218 status reports as of September 30 were filed by October 9; the status report preparer drafted the last six from the core system, each with what changed since March 31, ready to sign. Below, the eight loans in default, each with its default date, last report, next report and state. The screen shows the sample bank's measure, 4 minutes to review a drafted status report against 35 by hand; FSA's own estimate for completing the form is about 20 minutes.8

Reports to the agency. The twice-yearly status reports and the 60-day default report cycle on one page.
3

FSA's dates fixed; the bank's choices editable

The agency's clocks are read-only, each with its rule. The bank's lead times (prepare 10 business days ahead, remind at 5 and 2), its target for status reports, when an undecided default goes to the manager, its lender status, the protective advance threshold, the restructuring coverage policy and the approvers are settings, versioned on the audit trail.

Corrections to this screen's citations: the 210-day interest limit is 762.149(d)(2), where the screen prints (i), and the protective advance rule is 762.149(e), where it prints (f). The annual analysis switch cites 762.141(c) as a summary for each borrower; since October 1, 2026 a Certified Lender sends summaries only for lines of credit and defaulted term loans.5,7

Settings. Regulatory dates locked with their rules; the bank's lead times and thresholds as choices.
14 · Agents and who signs

The guarantee clock keeper, the loss claim assembler and four more agents, and the two signatures on every decision and claim

In shortSix agents share the work: one keeps every date, two draft the reports, one builds the restructuring analysis, one assembles liquidation plans and claims, and one watches collateral and covenants. Each has a written limit. No agent moves a regulatory date, chooses between restructuring and liquidation, waives a requirement or sends anything to FSA. The coordinator reviews and signs every filing with its meaning recorded; the ag lending manager approves every decision and every loss claim before it leaves the bank.

Clock keeper, report preparers, restructuring analyst and claim assembler

Guarantee clock keeper

Computes every loan's dates from the loan note guarantee, the payment history and 7 CFR 762 each night, and re-dates them when a payment or event lands.

Never moves a regulatory date; only the bank's own lead times are settings.

Status report preparer

Drafts the status reports as of March 31 and September 30 from the core system, with what changed since the last one.

Never files without the coordinator's signature.

Default status reporter

Drafts the FSA-2248 after the borrower meeting and every 60 days, from servicing notes, the meeting and the payment history, with a source on every line.

Never states a borrower fact that is not in a note or document.

Restructuring analyst

Reads the borrower's statements, builds the cash flow and lays restructuring beside liquidation: new installment, coverage against policy, loan-to-value, net recovery and the loss split.

Never chooses; the coordinator signs and the ag lending manager decides.

Loss claim assembler

Builds the liquidation plan and the estimated and final loss claims with every attachment, and checks appraisal coverage, the 210-day interest limit and protective advance authorizations.

Never lets a claim with a missing attachment or an unsupported figure go to signature.

Collateral and covenant watcher

Tracks annual statements, farm visits, insurance, lien continuations and holders' repurchase demands, and checks the security when a decision is prepared.

Never waives a requirement or marks one met without its document.

Who signs each FSA filing, decision and loss claim

What leaves the bankWho signsWhat goes on the record
Status reports and default status reportsThe guaranteed-loan coordinator, with the meaning of the signatureThe form, each line's source, the name and the time, where it was sent
Restructure-or-liquidate decisionsThe coordinator signs; the ag lending manager approves before anything is sentBoth options, the cash flow, the chosen terms, both signatures, the filings
Liquidation plans and loss claimsPrepared by special assets, signed by the coordinator, approved by the managerEvery figure with its document, the checks passed, the signatures
Changes to lead times, thresholds and approversThe named owner in settingsEach change versioned on the audit trail

The four-eyes rule sits where the money is: a decision and a loss claim each carry two signatures, the coordinator's and the manager's, and nothing goes to the FSA office unsigned.

Dated by rule, cited, signed, and kept for FSA's claim review

1

Every date shows its rule

Each clock counts from the event the regulation names, and shows the section it comes from.

2

Every figure cites its document

Balances from the core, causes from the notes, values from the appraisal, each linked.

3

People decide and sign

Agents count, read and draft. People meet the borrower, choose, sign and send.

4

The file FSA reads at claim time

Every report, decision, signature and attachment on one loan's record, from the first missed payment.

15 · What goes in and out

From loan note guarantees and payment history to signed FSA-2248s and loss claims: inputs, outputs and connected systems

In shortIt reads what an ag bank already holds: the loan note guarantees and promissory notes, payment history and balances from the core, servicing and meeting notes, borrowers' statements and plans, appraisals and auctioneers' estimates, lien filings and insurance, and the bank's lead times and approvers. It produces a clock on every FSA date, drafted status and default status reports, decision packages, liquidation plans and loss claims, and a look-ahead of guarantee at risk. The core stays the system of record. It scales from one coordinator's book to a whole ag department with roles, maker-checker signing and a full audit trail.

From your systems and files

  • Loan note guarantees, promissory notes and loan agreements
  • Payment history, balances and holder remittances from the core
  • Servicing notes, meeting notes and farm visit reports
  • Balance sheets, income statements, cash flows and farm plans
  • Appraisals, auctioneers' estimates, lien searches and insurance

From the bank's policy

  • Lender status: Standard Eligible, Certified or Preferred
  • Lead times, reminders and escalation
  • Restructuring coverage policy and terms
  • Who signs filings; who approves decisions and claims

What it produces

  • A clock on every FSA date, per loan and for the book
  • Drafted FSA-2241 status reports and FSA-2248 default status reports
  • Decision packages: cash flow, options, coverage and loss split
  • Liquidation plans and estimated and final loss claims with attachments
  • A look-ahead of filings due and guarantee exposed
  • An audit trail of every date, draft and signature

Core, imaging, ag analysis and FSA systems, and what each exchanges

SystemWhat it exchanges
Core loan systemPayments, balances, rates and holder remittances in; nothing posted back without a person
Document imagingGuarantees, notes, statements, appraisals and notes read where they are kept
Ag financial analysis softwareSpreads and cash flows read or exported for the decision package
Calendars and emailDates exported; reminders to signers and loan officers
FSA's electronic submissionSigned filings produced for the means FSA designates; since October 1, 2026 servicing documents may go electronically7

Design targets: no missed guarantee dates, claims accepted as filed

0

guarantee deadlines missed: every date prepared before it is due. A design target, measured in a live deployment.

Design target
1st time

loss claims accepted as filed, every figure tied to its document. A design target.

Design target
210 days

after the missed payment, FSA stops paying interest: the date every claim must beat.5

7 CFR 762.149(d)(2)
Part C · Are you ready to automate?

Deciding whether to automate FSA guaranteed loan servicing, and how to start

Written to you, the person who would own the decision. What missed dates and returned claims cost, a calculator for your own numbers, a readiness check, the questions to put to any vendor (us included), a pilot plan and the questions people ask most.

16 · What misses cost you

Claim cuts, interest lost after day 210 and coordinator hours: what late FSA servicing costs a lender

In shortMost of the cost stays hidden until a loan is liquidated. Then FSA measures what your servicing lost it and keeps that share of the claim, interest that piled up while nobody acted goes unpaid, and everything after day 210 is yours. The steady costs are hours: FSA itself estimates 25 hours to complete one loss claim. Nobody publishes how often FSA cuts claims, or by how much. Your own claim history, one defaulted file timed end to end and a count of dates met late will tell you yours.

25 hours

is FSA's own estimate of the time to complete one FSA-2254 report of loss, against about 20 minutes for a status report or a default status report.8

FSA supporting statement, OMB 0560-0155, 2023
210 days

after the missed payment, FSA pays no more interest on a defaulted loan; interest that builds up while a lender takes no action can be cut sooner.5

7 CFR 762.149(d)(2) and (i)(6)
7.00%

is the highest loss rate FSA's 1999 notice allows a Certified Lender, 3.00% for a Preferred Lender; late status reports are separate cause to revoke either status.14,11

64 FR 7404 and 7 CFR 762.106
Most of a defaulted loan's hours go to the plan, the claim and the decision

Estimated hours for one defaulted guaranteed loan, from default to a filed claim

By hand (estimate)With automation (estimate)
Liquidation plan and loss claim with attachments16 h5 h
Cash flow and the restructure-or-liquidate analysis12 h4 h
Keeping the dates in calendars and files6 h0.5 h
Default status reports every 60 days4 h1 h
Review, signature and approval3 h3 h

Illustrative · replace with your own numbers · Both columns are the solution's own design estimates; no public source measures them. Review and signature time is the same in both: people still read and sign. Time one defaulted file of your own.

Show the numbers
By hand (estimate)With automation (estimate)
Liquidation plan and loss claim with attachments16 h5 h
Cash flow and the restructure-or-liquidate analysis12 h4 h
Keeping the dates in calendars and files6 h0.5 h
Default status reports every 60 days4 h1 h
Review, signature and approval3 h3 h
What nobody publishes. FSA does not publish how many loss claims it reduces or rejects, the dollars involved, or the reasons; nor does any public source measure a coordinator's hours per guaranteed loan. FSA's own filings give the counts of reports, plans and claims, and its estimates of time per form. The rest you measure.

Five years of claim cuts and dates met late

CostWhere it hidesHow to find your number in a week
Claim reductions and rejectionsFSA's decision letters on final loss claims, often booked as a loss with no reason keptList every final loss claim of the last five years: amount claimed, amount paid, and FSA's stated reason for any difference
Interest after day 210The gap between interest accrued and interest claimed on liquidated loansFor each liquidation, count the days between day 210 and the date FSA paid the estimate, times the daily interest
Dates met lateDefault status reports, decisions and plans filed after their date, with no record of whyPull your last ten defaulted loans; list each date the rule set and the date you filed
Returned filingsPlans and claims FSA sent back for missing appraisals, receipts or ledgersAsk the FSA office or check your files for returned plans and claims, with the reason
Staff timeCoordinator and special assets hours on reports, analyses, plans and claimsTime one defaulted file and one status report cycle; divide by loans
Lender statusYour loss rate and FSA's comments at renewal of CLP or PLP statusCompute your loss rate the way 761.2 defines it and read FSA's last review letter

The farm a day-89 decision saves, and lender status at risk

The farm that could have been savedA restructuring decided on day 89 with a full cash flow keeps a customer that a late decision turns into a liquidation.
Certified or Preferred statusLosing it means FSA's approval before every restructuring and more paper with every report.21,6
The FSA office's patienceA county office that receives complete files the first time answers faster the next time.
Knowledge that walks outWhen the one coordinator who knows the dates retires, the bank's memory of them goes too.
A rule change missedThe October 1, 2026 rule changed which analyses go to FSA; a book run from last year's checklist sends the wrong ones.7
17 · Your return

Coordinator hours, defaulted-loan hours and claim cuts avoided: the return on automating FSA servicing

In shortPut in your own numbers. The calculator values the hours released on routine reports and on defaulted loans, adds the claim reductions and lost interest you expect to avoid, and subtracts what the tool and your testing cost. Every default is an assumption marked illustrative; the claim default is one 90-day delay on a loan like the example's, from section 09.

Dates counted, reports drafted and claims checked

Dates

Every date counted from its event

Clocks start from the payment history and the rule; nobody copies dates into a spreadsheet.

dates met late a year, before and after
Reports

Status and default reports drafted

The FSA-2241 and FSA-2248 arrive filled in from the core and the notes, each line sourced.

loans × routine hours saved per loan × hourly cost
Decisions

The 90-day decision prepared early

The cash flow, both options and the coverage test ready while there is still time to choose.

defaulted loans × hours saved per loan × hourly cost
Claims

Claims complete the first time

Collateral, receipts, authorizations and the 210-day limit checked before signing.

claim cuts and lost interest avoided a year
Status

A loss rate and a record FSA trusts

On-time reports and complete files support Certified or Preferred status at renewal.

late status reports a year, before and after
Rules

Rule changes applied once

When FSA changes a threshold, as on October 1, 2026, the setting changes for every loan.

loans reviewed under the right rule, before and after

Routine and default servicing hours on your FSA book

Every input marked illustrative is an assumption to replace with your own.

Your book
Routine servicing, per loan a year
Defaulted loans
Claims
Your cost
Illustrative yearly value
Servicing time today, valued$0
Staff time released, valued$0
Claim cuts and lost interest avoided$0
After your yearly cost$0
Staff hours released a year0
Hours released per defaulted loan0

Formulas, per year:
Time today = (loans × routine hours today + defaulted loans × hours per defaulted loan today) × hourly cost
Time released = (loans × (routine hours today − with automation) + defaulted loans × (hours today − with automation)) × hourly cost
After your cost = time released + claim cuts and lost interest avoided − yearly cost

The hourly default is a loaded cost; use your own. The hours per defaulted loan are the design estimates in the chart above. The claim default, $22,485, is 90 days of interest at 6.875% on $1,326,400, the illustration in section 09; set it from your own claim history. Released hours are value only when you decide what they are for: more loans per coordinator, earlier decisions, or complete files.

18 · Readiness check

Eight checks on your FSA guaranteed loan desk, from a written list of dates to five years of claim history

In shortAnswer for your desk as it is today. Eight questions score 0 to 2; the last is for reflection. The meter adds up your score as you go, and each question says why it matters and what a strong answer sounds like.

1
Size of the book

How many FSA guaranteed loans do you service, and how many are in default today?

Why it mattersEach loan carries its own dates; each default adds a reporting cycle and a decision. A few defaults at once are where dates slip.
A strong answer"About 200 loans, six to ten in default at any time, rising with the farm economy."
2
A written list of FSA dates

Do you have a written list of every FSA servicing date, what starts it, its rule and its owner, updated for October 1, 2026?

Why it mattersSoftware can only keep the dates you can name, and the list becomes its settings.
A strong answer"Yes, by section of 762, with our lead times, reviewed when FSA changed the annual analysis rule."
3
Documents you can reach

Can you get each loan's guarantee, note, statements, appraisals and servicing notes in electronic form?

Why it mattersEvery drafted line needs its source; a paper file becomes an open item on day one.
A strong answer"Imaged and indexed by loan number, notes in the loan system, appraisals attached."
4
Payment data

Can you export transaction-level payment history from the core, including holder remittances?

Why it mattersEvery default date counts from the payment history; a status flag can lag it.
A strong answer"A nightly file of every posting and reversal, by FSA loan number."
5
Your claim history

Do you know, for the last five years, what you claimed, what FSA paid and why any difference?

Why it mattersWithout a baseline a pilot cannot show a change, and the case rests on claims.
A strong answer"Eleven final claims, two reduced for interest during delay, one returned for a missing appraisal."
6
Your policies in writing

Are your lead times, restructuring coverage policy, terms and approvers written down?

Why it mattersA decision package tests the plan against your policy; an unwritten policy cannot be tested.
A strong answer"Coverage of 1.10 times, operating terms to seven years, the manager approves every decision and claim."
7
Ownership

Is there one named owner with a budget for FSA guaranteed servicing?

Why it mattersThe work crosses the coordinator, loan officers, special assets and operations; one owner settles the hand-offs.
A strong answer"The ag lending manager, with the coordinator leading day to day and a budget line."
8
Governance for new tools

Do your vendor and model risk teams have a path for approving software that reads documents and drafts filings?

Why it mattersThe April 2026 model risk guidance covers quantitative models and leaves generative and agentic AI to each bank's own governance; a known path for both saves months.33,34,35
A strong answer"Yes: a vendor review, our AI use policy, and a rule that a named person signs every filing."
9
Vision · for reflection

If FSA asked tomorrow for the full servicing file of a loan you liquidated last year, what would have to be true for you to send it with every date met, every report signed and every claim figure tied to a document?

Why it mattersYour answer lists the gaps. Each gap is a candidate job for software: counting, reading, drafting or checking.
A strong answerA short, specific list, for example: "every default report filed on time with its notes, the decision inside 90 days with the cash flow, the plan's appraisal covering all collateral, and no interest claimed past day 210."

A written FSA date list, then a pilot on your loans

0–6

Explore

Write the list of FSA dates and your policies first, name an owner, and count five years of claims and the dates you met late. Start narrow, for example with the default status report cycle.

7–11

Ready to pilot

Run a measured pilot on 40 to 80 of your own guaranteed loans, including every loan now in default and one recent liquidation. Compare dates found, false alarms and hours with your current process, and keep your people signing every filing.

12–16

Ready to implement

Plan the whole book: your lead times and approvers as settings, maker-checker signing, the core and document feeds, the status report cycle, special assets hand-offs, and the claim file FSA will read.

19 · Questions for any vendor

What to ask a vendor of FSA servicing software: how it counts each date, drafts the FSA-2248 and checks a loss claim

In shortAsk every vendor the same questions, us included. The answers show which FSA dates the tool keeps and how it counts them, what it drafts and from what, how it handles the October 2026 rule and your lender status, what it checks in a claim, and who stays responsible.

A

How the vendor counts each 7 CFR 762 date

A1

Which 7 CFR 762 dates do you keep, and from which event does each one count?

Why it mattersThe 45-, 150- and 210-day dates count from the due date, the 90-day decision from default; one wrong start moves everything.
Strong answer · warning sign
A written list with the section and the starting event for each.
"All FSA deadlines."
A2

Where does the due date come from: the payment history, or a field someone typed?

Why it mattersA partial payment or a reversal changes the default date.
Strong answer · warning sign
The transaction history, re-read nightly.
A delinquency code from the core.
A3

How do you handle Preferred Lender agreements and loans in bankruptcy or mediation?

Why it mattersPLP dates follow the lender's agreement; bankruptcy and state mediation stop or change the clock.
Strong answer · warning sign
Settings per lender status and per loan event, shown on the clock.
One schedule for every loan.
A4

When FSA changes a rule, as on October 1, 2026, who updates the dates and how do we see it?

Why it mattersThe annual analysis threshold moved from $100,000 to $500,000 overnight.
Strong answer · warning sign
A dated change with the Federal Register citation, applied to every loan, versioned.
"We update it in the next release."
B

Drafted FSA-2248s, decision cash flows and restructurings

B1

Show us a drafted FSA-2248: where does each line come from?

Why it mattersItem 15 is a statement to a federal agency about a borrower.
Strong answer · warning sign
Each line links to a note, the meeting or the payment history.
A summary with no source.
B2

How do you build the cash flow for a decision, and from which statements?

Why it mattersThe restructuring must rest on a feasible plan and three years of history.21
Strong answer · warning sign
Each line with its document; your coverage policy applied; both options shown.
A recommendation with no numbers.
B3

What do you draft for a Certified Lender's restructuring, as opposed to a Standard Eligible Lender's?

Why it mattersOne sends a certification and narrative; the other asks for approval first.21
Strong answer · warning sign
Different packages by lender status, with the 762.145 checklist.
One request letter for all.
B4

Can your drafts be wrong, and how would we know?

Why it mattersA tool that cannot say how often it errs has not measured it.
Strong answer · warning sign
A measured field accuracy on your sample, and every value traceable.
"It doesn't make mistakes."
C

Checks before a loss claim goes to signature

C1

What do you check before an estimated or final loss claim goes to signature?

Why it mattersMissing collateral, unpaid-for interest and unauthorized advances are where claims get cut.5
Strong answer · warning sign
Appraisal coverage against every lien, the 210-day limit, advance authorizations, attachments.
"We fill in the form."
C2

How do you treat protective advances on an estimated claim?

Why it mattersFSA pays them with the final claim; its form says to leave them off the estimate except as the handbook allows.13
Strong answer · warning sign
Held for the final claim, with the authorization and receipts kept ready.
Added to the estimate by default.
C3

Can you produce the final claim's loan ledger and accountings from our core?

Why it mattersFSA requires them with every final claim.5
Strong answer · warning sign
Generated from the transaction history, reconciled to the claim.
"You attach them."
C4

Do you track the three years of collection reports after a final loss payment?

Why it mattersThe duty outlives the loan.6
Strong answer · warning sign
A clock per unsatisfied account until the third report.
The loan closes when FSA pays.
D

A named signature on everything sent to FSA

D1

Can anything go to FSA without a named person's signature?

Why it mattersThe lender answers for every filing, whoever drafted it.
Strong answer · warning sign
No; signatures with their meaning, and a second approval for decisions and claims.
"Auto-submit is optional."
D2

What does the audit trail record, and can FSA or our examiners read it?

Why it mattersThe file is your defense when a claim is questioned.
Strong answer · warning sign
Every date change, draft, source and signature, exportable by loan.
Logs only the vendor can read.
D3

How do you fit our model risk and third-party reviews?

Why it mattersSR 26-2, OCC Bulletin 2026-13 and FIL-15-2026 set expectations for quantitative models and leave generative and agentic AI to the bank's own governance, so ask which parts are which.33,34,35
Strong answer · warning sign
Documentation of what each component does, how it was tested, and its limits.
"It's not a model."
D4

Who keeps our data, where, and can we take it with us?

Why it mattersBorrower financials and federal filings are sensitive and long-lived.
Strong answer · warning sign
Your tenancy, your retention rules, a full export.
Unclear answers on location or export.
20 · How to start

Piloting on 40 to 80 of your FSA loans through one 60-day default cycle, and the six things to measure

In shortStart with a baseline and a sample: 40 to 80 of your guaranteed loans, including every loan in default and one recent liquidation. Load their documents and payment history, run the clocks and drafts beside your current process through one status report date and at least one 60-day default cycle, and score what each finds. Decide on three numbers: dates and claim gaps found that your process missed, false alarms, and hours.

  1. Write the baseline: five years of claims and FSA's reasons for any cut, the dates you met late on the last ten defaults, and the hours on one defaulted file.
  2. Choose the sample: 40 to 80 loans across loan officers and loan types, every loan in default, a sold loan, and a recently liquidated one to rebuild the claim.
  3. Load your rules: lender status, lead times, coverage policy, terms and approvers.
  4. Run in parallel: the clocks and drafts beside your process; your people still file.
  5. Decide with three numbers: what it found that you missed, false alarms per 100 dates, and hours per loan.
A twelve-week pilot ends with a decision on three numbers
Your teamVendor
Baseline: claims, late dates, hours
Choose the sample; gather documents
Load lender status, lead times, policies
First read: dates and drafts for the sample
Parallel run through a 60-day default cycle
Rebuild one liquidated claim and compare
Score finds, false alarms and hours
Decide
Week 04812

Illustrative · replace with your own numbers

Show the numbers
ActivityFromTo
Baseline: claims, late dates, hours02
Choose the sample; gather documents13
Load lender status, lead times, policies24
First read: dates and drafts for the sample35
Parallel run through a 60-day default cycle510
Rebuild one liquidated claim and compare69
Score finds, false alarms and hours911
Decide1112

Where to start inside the work

Default reports pay back first; decisions and claim checks cost the most when they go wrong
Cost if it goes wrong on a loan that fails →
Check closely by hand
Automate first
Leave for later
Automate the drafting
Default reportsDecisionsClaim checksStatus reportsAnnual analysesAdvances
How often the task comes up →

Illustrative · replace with your own numbers

Show the numbers
ItemHow often the task comes up (0–1)Cost if it goes wrong on a loan that fails (0–1)
Default reports0.740.63
Decisions0.440.76
Claim checks0.130.66
Status reports0.840.10
Annual analyses0.600.21
Advances0.150.12

The positions are our judgment from 7 CFR 762.149's grounds for reducing claims and FSA's counts of each filing. Advances means protective advance approvals; claim checks means checking a plan and claim before signing. Place your own using your claim history.5,8

Dates found, draft accuracy and claim gaps to record

MeasureHowWhy
Dates found that you missed or met lateDates the tool raised that your calendar lacked or had wrong, checked by the coordinatorThe protection case rests on it
False alarmsDates raised that were not real, per 100 datesA tool that flags everything finds everything
Draft accuracy200 drafted values checked against their documentsNone wrong in 200 bounds the error rate near 1.5%
Claim gaps on the rebuilt claimWhat the check found against what FSA actually cutThe clearest test of claim value
HoursTimesheets on reports, decisions and claims, before and duringThe cost case
Days earlyDays between filing and due date, before and duringMargin is what protects the guarantee
Twelve questions for your first working session, in four groups

Bring the coordinator, ag loan officers, special assets, loan operations, credit administration, vendor management and IT into one room.

A

Lines, large term loans, sold loans and defaults

A1

How many loans are lines of credit, term loans above $500,000 in aggregate, sold to holders, or in default?

Why it mattersEach group carries different duties after October 1, 2026.
Strong answer · warning sign
Counts from the core by group.
Nobody knows the sold share.
A2

Which loans are serviced under a Preferred Lender agreement, and what does it change?

Why it mattersPLP dates and approvals follow the agreement.
Strong answer · warning sign
The agreement's servicing terms listed.
"Same as everyone."
A3

Which states are your borrowers in, and which have mandatory farm mediation?

Why it mattersMediation can add weeks before a liquidation can start.24
Strong answer · warning sign
A state list with each program's rules.
Found out at foreclosure.
B

Servicing notes, the FSA loan ledger and indexed liens

B1

Where do servicing notes live, and are meeting notes written on the day?

Why it mattersThe default report's comments come from them.
Strong answer · warning sign
In the loan system, dated, by loan.
In officers' email.
B2

Can the core produce the loan ledger FSA asks for, with every transaction and the interest calculations?

Why it mattersFSA requires it with claims.5,13
Strong answer · warning sign
A standard report.
Rebuilt by hand each time.
B3

Are appraisals and lien filings indexed to the collateral they cover?

Why it mattersThe Kessler gap was a lien no appraisal covered.
Strong answer · warning sign
A collateral list per loan with its lien and value.
"It's in the file somewhere."
C

Who signs FSA filings and approves claims today

C1

Who signs filings to FSA today, and who approves decisions and claims?

Why it mattersThese become the signing roles.
Strong answer · warning sign
Named roles with a backup for each.
Whoever is in.
C2

When does a defaulted loan move from the loan officer to special assets?

Why it mattersHand-offs are where dates slip.
Strong answer · warning sign
A written trigger and date.
"When it gets bad."
C3

Who talks to the FSA county office, and how?

Why it mattersOne channel keeps filings and answers together.
Strong answer · warning sign
The coordinator, with a shared log.
Several people, several inboxes.
D

The twelve-week result that expands the pilot

D1

What result in twelve weeks would make you expand to the whole book?

Why it mattersAgreeing the bar first keeps the pilot honest.
Strong answer · warning sign
Three numbers with thresholds.
"We'll know it when we see it."
D2

What would make you stop?

Why it mattersA pilot needs a failure condition too.
Strong answer · warning sign
A false alarm rate or an accuracy floor.
None.
D3

Who approves going live: credit, compliance, model risk, IT?

Why it mattersEach needs evidence from the pilot.
Strong answer · warning sign
A list, with what each needs to see.
Discovered after the pilot.
21 · FAQ

Answers on FSA default status reports, the 90-day decision, protective advances and loss claims

In shortThe questions lenders and their teams ask most about servicing FSA guaranteed farm loans, each answered on its own.

What are the FSA guaranteed loan servicing requirements?

Under 7 CFR 762.140 to 762.149 a lender services the whole loan prudently, protects the collateral and reports to FSA. It files status reports as of March 31 and September 30, analyzes borrowers each year where the rule requires it, and asks FSA before certain releases, subordinations and transfers. When a borrower defaults it meets the borrower, files a default status report every 60 days, decides within 90 days of default, and if it liquidates files a plan and an estimated loss claim within 150 days of the due date.3,6,4,5

When is an FSA guaranteed loan in default?

A borrower is in default when 30 days past due on a payment or in violation of the loan documents. Standard Eligible and Certified Lenders then meet the borrower within 15 days of default, 45 days after the due date for a missed payment, and report on FSA's default status form. Preferred Lenders follow their lender's agreement.4

What is the FSA-2248 and how often is it filed?

FSA-2248 is the Guaranteed Farm Loan Default Status Report. It is filed after the meeting with a borrower whose loan is 30 days past due, then every 60 days until the default is cured by restructuring or liquidation. It reports the delinquency date, unpaid principal, accrued interest, the amount past due, a status code, interest assistance and comments on the action taken.6,10

What is the FSA guaranteed loan status report?

The status report, form FSA-2241, updates each guaranteed loan's balance and status in FSA's records. Every lender files it as of March 31 and September 30 each year; FSA usually sends it with most items already filled from the last report. FSA estimated about 20 minutes a loan.6,23,8

How long does a lender have to decide to restructure or liquidate?

Ninety days from default, which is 120 days from the missed payment, unless the lender documents circumstances that justify an extension by FSA. If neither the lender nor the borrower wants to consider servicing options, that should be documented and liquidation can begin.4

When is the FSA liquidation plan and estimated loss claim due?

Within 150 days after the payment due date. The plan includes balance sheets, a collection method, an independent appraisal of all collateral with its net recovery value, a time estimate, liquidation costs and protective advances. The estimated loss claim is due by the same date unless the account is already fully liquidated, in which case a final claim is filed. FSA has 20 calendar days to approve the plan or ask for changes.5

Does FSA pay interest on a defaulted guaranteed loan?

Yes, up to a point. FSA pays its share of interest until it pays the estimated loss claim, but never beyond 210 days from the payment due date, apart from narrow bankruptcy and redemption exceptions. It does not pay default interest, late charges or servicing fees, and it can refuse interest that accrued while the lender took no action.5

What is a protective advance and when does it need FSA approval?

A protective advance is money a lender spends to protect or preserve the collateral, such as unpaid real estate taxes. It may be made only in or near liquidation, and a Certified Lender needs FSA's prior written authorization for any above $5,000, a Standard Eligible Lender above $3,000. FSA pays its share when the final loss claim is approved; legal fees are not protective advances.5

What is the difference between an estimated and a final loss claim?

The estimated claim, due by day 150, pays FSA's guaranteed share of the outstanding debt less the net recovery value of the remaining security and any unaccounted-for security. The final claim follows the sale of the collateral and settles the account with accountings and a loan ledger; FSA decides it within 40 days. If the final loss is less than the estimate, the lender repays the difference with interest.5,13

How can FSA reduce a guaranteed loan loss claim?

FSA reduces a final claim by the loss it calculates the lender's negligent servicing caused: collateral not secured after default, interest during inaction or excessive delay, unauthorized releases of proceeds, ownership not verified, collateral not inspected. Deficiencies that did not materially add to the loss do not reduce it. From October 1, 2026, payments on unguaranteed loans that missed 762.146 are also deducted.5,7

What changed in FSA guaranteed servicing on October 1, 2026?

A final rule published September 4, 2026 raised the annual analysis threshold for non-PLP lenders' term loans from $100,000 to $500,000, limited the analyses sent to FSA to lines of credit and defaulted loans, ended FSA's prior approval for most additional unguaranteed loans in favor of file documentation, allowed electronic servicing submissions and raised the real estate evaluation limit to $500,000.7

Does releasing FSA guaranteed loan collateral need FSA's consent?

Not when the item is sold for market value with the proceeds applied to the loan, traded for a like item taken as security, or worthless. A release for no consideration or for improvements needs FSA's written approval; one for nothing passes only if the loan stays at or under 75% of the remaining security's appraised value.19

22 · One-page summary

The FSA servicing calendar from day 30 to day 210, with 14 terms, on one page

Print this page

In shortThe whole guide on one screen: the dates, the rules as of October 2026, the readiness bands and the terms.

The duties and dates
  1. Status reports (FSA-2241) on every loan as of March 31 and September 30.
  2. Annual analysis: term loans above $500,000 in aggregate, all lines of credit, all defaults (non-PLP, from October 1, 2026).
  3. Ask FSA in writing before a release for nothing, a subordination of basic security, a transfer or a release of liability.
  4. Default at day 30; meet the borrower and file FSA-2248 by day 45; file it again every 60 days.
  5. Decide to restructure or liquidate within 90 days of default.
  6. Liquidation plan and estimated loss claim (FSA-2254) by day 150; no FSA interest after day 210.
  7. Protective advances over $5,000 (CLP) or $3,000 (SEL) need FSA's prior written approval; paid with the final claim.
  8. Final claim with accountings and loan ledger; FSA decides within 40 days; collection reports for 3 years.

Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.

As of October 2026: 7 CFR 762 as amended by 91 FR 56741, effective October 1, 2026 · interest assistance last funded in fiscal 2011 · farm bill pending · model risk guidance SR 26-2 / OCC 2026-13 / FIL-15-2026.

14 terms
FSA
The USDA's Farm Service Agency, which guarantees commercial lenders' farm loans.
Loan note guarantee
FSA's guarantee document for a loan, backed by the full faith and credit of the United States.
SEL · CLP · PLP
Standard Eligible, Certified and Preferred Lenders, with growing authority.
FSA-2241
The guaranteed farm loan status report, as of March 31 and September 30.
FSA-2248
The default status report, after the meeting and every 60 days.
FSA-2254
The guaranteed loan report of loss, for estimated and final claims.
Default
30 days past due on a payment, or a violation of the loan documents.
Feasible plan
A cash flow budget showing enough cash coming in to pay all the cash going out.
Net recovery value
Market value of the security less the costs of acquiring, holding and selling it.
Protective advance
Money spent to protect or preserve the collateral.
Estimated loss claim
FSA's early payment of its share of the expected loss, by day 150.
Negligent servicing
Failing to act, or to act on time, as a reasonable lender would.
Holder
An investor who bought the guaranteed portion of a loan.
Loss rate
Net loss claims paid on loans made in the past 7 years over the amount of those loans.
23 · Sources

Sources

Accessed October 2026. Regulatory status statements are as of October 2026.

  1. F. Parum, American Farm Bureau Federation, "Financing the Farm: A Look at USDA Farm Loan Programs", Market Intel, September 9, 2026. fb.org
  2. 7 CFR 762.103, Full faith and credit, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  3. 7 CFR 762.140, General servicing responsibilities, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  4. 7 CFR 762.143, Servicing distressed accounts, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  5. 7 CFR 762.149, Liquidation, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  6. 7 CFR 762.141, Reporting requirements, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  7. Farm Service Agency, "Driving Efficiency in Farm Loan Delivery", final rule, 91 FR 56741, September 4, 2026, effective October 1, 2026. federalregister.gov
  8. Farm Service Agency, Supporting Statement for OMB control number 0560-0155, Guaranteed Farm Loan Programs, 2023 (ICR 202302-0560-003). reginfo.gov
  9. Budget of the U.S. Government, Appendix, Department of Agriculture, Agricultural Credit Insurance Fund Program Account: Fiscal Year 2013 (guaranteed subsidized farm operating loan level, 2011 actual, $63 million; the 2013 Budget "does not provide funding for guaranteed subsidized farm operating loans") and Fiscal Year 2014 (no subsidized level, 2012 actual). govinfo.gov (FY2013) · govinfo.gov (FY2014)
  10. USDA eForms, "Instructions for FSA-2248, Guaranteed Farm Loan Default Status Report". forms.sc.egov.usda.gov
  11. 7 CFR 762.106, Preferred and certified lender programs, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  12. 7 CFR 761.2, Abbreviations and definitions, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  13. USDA eForms, "Instructions for FSA-2254, Guaranteed Loan Report of Loss". forms.sc.egov.usda.gov
  14. Farm Service Agency, "Notice of Eligibility Criteria for Certified and Preferred Lenders", 64 FR 7404, February 12, 1999. govinfo.gov
  15. Farm Service Agency, "Revised Loan Volume Requirements for the Preferred Lender Program and the Certified Lender Program", 89 FR 13682, February 23, 2024. federalregister.gov
  16. Farm Service Agency, "Enhancing Program Access and Delivery for Farm Loans", final rule, 89 FR 65020, August 8, 2024, effective September 25, 2024. federalregister.gov
  17. Farm Service Agency, "Information Collection Requests; Guaranteed Farm Loan Program", notice, 91 FR 22788, April 28, 2026. federalregister.gov
  18. Cowboy State Daily, "Farm Bill Clears Senate Ag Committee, But Wyoming Leaders See Major Hurdles Ahead", September 16, 2026. cowboystatedaily.com
  19. 7 CFR 762.142, Servicing related to collateral, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  20. 7 CFR 762.144, Repurchase of guaranteed portion from a secondary market holder, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  21. 7 CFR 762.145, Restructuring guaranteed loans, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  22. 7 CFR 762.146, Other servicing procedures, Code of Federal Regulations, 2026 edition (January 1, 2026). govinfo.gov
  23. USDA eForms, "Instructions for FSA-2241, Guaranteed Farm Loan Status Report". forms.sc.egov.usda.gov
  24. Iowa Code 2026, chapter 654A, "Farm Mediation — Farmer-Creditor Disputes". legis.iowa.gov
  25. Farm Service Agency, "Information Collection Request; Certified Mediation Program", notice, 91 FR 40513, July 2, 2026. federalregister.gov
  26. Office of Information and Regulatory Affairs, ICR 202507-0560-004, Guaranteed Farm Loan Programs, concluded July 28, 2025 (form list and burden). reginfo.gov
  27. E. Kepner and D. Oppedahl, Federal Reserve Bank of Chicago, AgLetter No. 2013, "Second Quarter Midwest Farmland Values Unchanged", August 2026. chicagofed.org
  28. FDIC, Quarterly Banking Profile, Second Quarter 2026, Table V-A, Loan Performance. fdic.gov
  29. USDA Economic Research Service, "Highlights from the Farm Income Forecast", September 3, 2026. ers.usda.gov
  30. Federal Reserve Bank of Kansas City, Ag Credit Survey, "Steady Tightening of Agricultural Credit Conditions Persists", August 14, 2026. kansascityfed.org
  31. Federal Reserve Bank of Kansas City, Ag Finance Update, "Farm Loan Growth Remains Strong as Lending Shifts at Some Large Banks", July 1, 2026. kansascityfed.org
  32. S. Atkinson (USDA) and R. Loy (University of Arkansas), "Which FSA Farm Loan Borrowers Filed Bankruptcy between 2015-2025?", farmdoc daily (16):147, August 17, 2026. farmdocdaily.illinois.edu
  33. Federal Reserve, SR 26-2, "Revised Guidance on Model Risk Management", April 17, 2026. federalreserve.gov
  34. OCC Bulletin 2026-13, "Model Risk Management: Revised Guidance", April 17, 2026. occ.gov
  35. FDIC FIL-15-2026, April 17, 2026. fdic.gov
Next step

See it on your own guaranteed loans.

Explore the solution, or bring a sample of your own FSA guaranteed loan files, defaulted ones included, and we will put every date on a clock with you, each filing drafted from your documents.

botminds.ai The complete guide to FSA guaranteed loan servicing · October 2026. Lindmark Valley Bank, Brandt Ridge Farms, Pettibone Orchards, Kessler Dairy, every person and every figure in the example and the screens are fictional. Regulatory status is as of October 2026; check the sources, and FSA Handbook 2-FLP, before relying on it.