The passage of the CARES Act on March 27, 2020, introduced a host of new requirements and expectations for businesses benefiting from federal relief during one of the most disruptive economic periods in modern history. Among these was a stipulation that recipients of certain grants and loans report on supply chain disruptions—an element that, at first glance, may have seemed peripheral to firms focused on immediate liquidity challenges or workforce retention. Yet, as the dust began to settle, it became clear that supply chain transparency was to be a critical pillar of the Act’s implementation, not just an administrative afterthought. For small businesses, in particular, this represented both a challenge and, arguably, an opportunity.
One immediate task for small-business grant recipients was figuring out how to assess and communicate the health of their supply chains in a way that met the Treasury’s expectations without imposing unmanageable new burdens at a time when resources were already stretched thin. Here, the availability of open data from the Small Business Administration (SBA) provided a practical starting point. SBA’s databases, long used primarily for lender and program oversight, now offered a useful resource for firms seeking to benchmark the solvency of their critical suppliers. The logic was simple enough: by identifying suppliers with SBA loans or guarantees, and reviewing their reported status, a company could begin to form a view of where vulnerabilities might lie. But, as always, the simplicity of the concept masked the complexity of the execution.
Accessing and making sense of SBA open data was, for many, unfamiliar territory. Some firms found themselves surprised by the level of detail available—loan amounts, recipient locations, industry classifications. Others, frankly, found the data daunting in its raw form, requiring a degree of filtering and analysis that few small enterprises were set up to perform without external help. There was a certain irony in this: data designed for transparency risked becoming opaque through sheer volume and lack of clear guidance on use. This wasn’t to say firms weren’t trying. On the contrary, many showed remarkable creativity, partnering with consultants, trade associations, or even tech-savvy employees to build basic dashboards or tracking sheets that could turn raw SBA figures into actionable insights.
In parallel with these benchmarking efforts, companies had to consider how they would meet the reporting requirement itself. The Treasury, while not prescriptive in every detail, set out a clear expectation that recipients would provide timely, accurate information on supplier continuity. This led, in fairly short order, to the emergence of what some called “supplier-continuity affidavits”—monthly declarations that documented key supply chain risks and the steps being taken to mitigate them. The affidavits were, in most cases, straightforward in form: a statement of supplier status, identification of any known disruptions, and a summary of contingency plans. But behind these deceptively simple documents lay often frantic internal processes of information gathering, validation, and synthesis.
Designing a template for these affidavits was no small task. Firms had to strike a balance between thoroughness and usability. A document that was too sparse risked failing to satisfy oversight bodies; one that was too complex became unsustainable over time. The better examples tended to follow a loose but consistent structure. They would begin with a brief summary of supply chain status for the period—no major disruptions, minor delays, significant challenges, as the case may be. This would typically be followed by a table or narrative listing key suppliers, their operational status, and any relevant indicators of financial or logistical strain. Where possible, firms linked this to external data points, whether from SBA records, shipping data, or trade association reports.
Perhaps inevitably, the creation of these affidavits surfaced tensions within organizations. Operational teams, under pressure to keep production or service delivery going, sometimes viewed the reporting requirement as an unwelcome distraction. Legal and compliance teams, by contrast, saw it as a critical risk management tool, one that might protect the firm in the event of future scrutiny. Somewhere in between were the finance and procurement functions, often left to gather and consolidate the necessary information with limited time and resources. The dynamics varied from firm to firm, but the pattern was common enough to be remarked upon in industry forums and webinars.
What also became clear, as the months passed, was that the supplier-continuity affidavits served more than a compliance purpose. In many cases, they forced firms to look at their supply chains in new ways, to ask questions that had previously been background concerns at best. Which suppliers were truly critical? Where were the single points of failure? How resilient was the network not just to this crisis, but to future shocks? The answers were not always comforting, but they were undeniably valuable. And while the affidavits themselves may, in time, fade into administrative history, the habits of inquiry they encouraged were likely to leave a longer-lasting mark.