EO14377: SBA Loan Rule & Local Permitting

This project examines the Small Business Administration’s interim final rule that allows disaster‑loan‑funded projects to proceed when certain state or local approval decisions are delayed. It explains how the rule can preempt state and local requirements and what that may mean for floodplain management, land use decisions, and local control over development and recovery. Following interest from the Executive Director of the Association of State Floodplain Managers (ASFPM) on the rule’s implications, this project provides written analysis and a one‑page overview that analyze SBA’s legal basis for preempting state and local law, describe how the rule operates in practice, and highlight key considerations for local governments and floodplain managers.

EO14377 Legal Analysis Memo   SBA Rule One-Pager

• People and Entities Involved Outside W&M:
  • Association of State Floodplain Managers
• People and Entities at W&M Involved:
  • Greg Fowler, VCRC Legal Fellow (Primary Author)
  • Thomas Ruppert, VCRC Director