Before a lender spends a day on the credit side of a loan the Small Business Administration (SBA) guarantees, it has to prove the business may borrow under SBA's program at all. That means finding every person who owns the business, directly or through other companies. Each of them is checked against federal lists and the citizenship rule, every related company is added up to see whether the group is still small, and the business itself is tested against SBA's list of excluded types. The lender makes that call and signs it. SBA reads it later, often years later, when the loan has failed and the lender asks SBA to pay its promised share.
This guide is for anyone who screens, certifies, signs or pays for SBA eligibility work: SBA underwriters and credit analysts, loan processors, compliance officers, SBA lending managers, business development officers, and the people deciding whether to automate it. No background needed.
Imagine you are the senior SBA underwriter at a community bank in Columbus, Ohio, with authority to approve SBA loans yourself. It is October 12, 2026. Brassmoor Mechanical, a 64-person heating, air-conditioning and plumbing contractor, wants a $3,850,000 SBA 7(a) loan to buy the building it rents, add service vans and a plasma cutting table, and carry more working capital. The package came in complete on Thursday, October 8: 41 documents. Credit underwriting cannot start until you sign the eligibility determination.
The application lists three owners: Dana Whitfield 40%, a holding company called Ridgeway Trades Holdings 35%, and Tomas Valek 15%. That adds up to 90%. On page 4 of the operating agreement's second amendment, section 3.1, dated January 15, 2026, a fourth owner appears.
The application · owners
Dana Whitfield
40%
Ridgeway Trades Holdings
35%
Tomas Valek
15%
Total
90%
Amendment No. 2 · §3.1
Admitted
Keystone Field Partners, LLC
Share
10%
Its members
Three site supervisors
Total now
100%
3 owners on the form9 owners in the documentstwo companies and seven people.
The holding company's own 2025 partnership return, Schedule B, shows it also owns 70% of another plumbing business. That makes the other business an affiliate, and the two together take in $21.18 million a year on average, over SBA's $19.0 million size limit for their industry. A government debt database shows a federal housing claim against one of the holding company's two members, who owns 21% of Brassmoor through it and must guarantee the loan.
Careful screening finds the missing owner, the hidden affiliate and the federal claim before anyone underwrites the credit, while they can still be fixed.
What SBA eligibility screening checks, and why it now sits with the lender
The tests, the documents behind them, the rule changes of 2025 and 2026, the arithmetic of ownership and size, the federal lists, what goes wrong and the market, explained without selling anything. If you are new to SBA lending, start here.
01 · In plain words
SBA eligibility screening, from the first document to the signature
The U.S. Small Business Administration (SBA) does not lend money to most small businesses itself. It promises a bank, credit union or other approved lender that it will repay most of a loan if the borrower cannot. That promise is the guaranty, and on the agency's flagship 7(a) program it covers up to 75% of a loan over $150,000.1 In return, SBA sets rules about who may borrow, for what, and on what terms.
Most of those rules are about who the borrower is, before anyone looks at its finances. The business must be a for-profit company operating in the United States. It must be small, measured with every related company counted in. It must not be on SBA's list of excluded business types, such as lenders, landlords who only rent out space, and lobbying firms. Every person who owns any part of it, directly or through another company, must be a U.S. citizen or national whose home is in the United States. None of the owners or guarantors may owe the federal government money that is past due, have cost a federal program money on an earlier business loan, appear on a sanctions or exclusion list, or be in prison or under indictment.1
Checking all of that is eligibility screening. Since June 1, 2025 the lender makes the determination on almost every loan, documents it and signs it.2 Most of these loans are approved under delegated authority, meaning SBA trusts the lender to approve them without sending them in, and SBA issues the loan number without looking at the work. It reads the file when the borrower defaults and the lender asks SBA to buy the guaranteed part of the loan. If a rule was missed, SBA can refuse to pay, in part or in full.3,4
The hard part is that the application form answers only some of the questions. It asks who owns the business. It does not ask who owns the companies that own the business, what else those owners own, or whether a member admitted by an amendment last winter is on the list. The answers sit in operating agreements, amendments, partnership returns and personal financial statements, and someone has to read them.
Brassmoor's 41 documents, from package to SBA loan number
The business sends its packageBrassmoor sends 41 documents: the application, the operating agreement and two amendments, three years of returns and K-1s, personal financial statements, the holding company's papers.
A processor checks it is completeThe last document arrives on a Thursday. The processor logs the package and orders the federal database checks.
An underwriter screens eligibilityEvery owner traced to 100%, every person checked, every related business tested for size, every program rule tested. This is where the missing 10% owner and the affiliate are found, or missed.
Credit underwriting, approval and a loan numberCash flow, collateral and the credit memo. The lender certifies ownership in SBA's system and receives the loan number.
Closing, servicing, and perhaps a purchase reviewIf the loan defaults, SBA reads the eligibility file before it pays. A gap found then costs the guaranty.
Step 3 is the subject of this guide. The people, companies and figures in the example are fictional.
Four surprises in SBA ownership, size and federal debt checks
A 3% owner can make a $5 million loan ineligible
Since March 1, 2026 every direct and indirect owner must be a U.S. citizen or national living in the United States. No percentage is too small to count, and a green card holder may own none of the business.5
The form asks a narrower question than the rule
The application lists the applicant's owners. The size rule reaches into what those owners own, so the businesses that tip a company over its size standard are often in the owners' own tax returns.1
SBA's own screen never tested size
From August 2023 SBA ran eligibility through an automated framework. Its inspector general found it never checked size or for-profit status, and SBA agreed to flag all 73,302 loans it approved that way for review when a guaranty is claimed.6
Nine notices changed the rulebook in ten months
SOP 50 10 8.1, in force since October 1, 2026, folds in nine policy and procedural notices that took effect between September 2025 and July 2026, among them the two behind the March 2026 citizenship rule.7
Indirect owner, affiliate, CAIVRS and ineligible person
Indirect owner
A person who owns part of the business through another company. 60% of a company that owns 35% is 21%.
Affiliate
A business whose size is added to the applicant's because of who owns it. Its receipts and its SBA loans count.
CAIVRS
The federal database, run by HUD, of people and businesses with past-due federal debts or federal loan losses. Searched by tax ID.
Ineligible person
SBA's list of people and entities who may own no part of a borrower: green card holders, visa holders, anyone living abroad, foreign companies and others.
The SBA eligibility checklist: eleven questions an applicant must clear, and the document that answers each
In shortSBA's standard operating procedure lists six core requirements for the business and a series of checks on every owner, guarantor and related company, plus the loan's own limits. Most can be settled from documents the borrower already has; a few need a government database; three need someone's judgment. The determination must be documented "as early as practicable" and must stay true "throughout loan closing and disbursement".1
The SBA's rulebook for lenders is Standard Operating Procedure 50 10, now in version 8.1. Its first chapter opens: "Determination of Applicant eligibility is a required and critical step in the SBA loan process and should be completed and documented by the Lender as early as practicable."1 The chapter then works through the requirements one at a time. Grouped by what a lender has to do, they come to eleven questions.
#
Question
Rule
What usually answers it
1
Is it an operating business, organized for profit?
13 CFR 120.100(a)–(b)
Articles, bylaws or operating agreement, tax returns
2
Is it organized and operating in the United States?
120.100(c)
State filings, returns, addresses
3
Is it small, with every affiliate counted?
121.301; size table 121.201
The applicant's and affiliates' returns; owners' returns and agreements
4
Is it one of the excluded business types?
120.110
What it does and how it earns: returns, contracts, management agreements
5
Who owns it, to 100%, directly and indirectly?
SOP Ch. 1 Para. F
Operating agreement and every amendment, owners' own agreements, K-1s
6
Is every owner and required guarantor an eligible person?
SOP Ch. 1 Para. F; Appendix 3
The applicant's signed certification; ID; evidence for a U.S. national
7
Any prior federal loss or past-due federal debt?
120.110(q); SOP Para. E
CAIVRS by tax ID, and the borrower's own answers
8
Anyone excluded or sanctioned?
SOP Ch. 4 Para. B; Para. J
SAM.gov exclusions; OFAC lists
9
Anyone in prison, under indictment, on parole or probation?
120.110(n)
The borrower information form's questions, court records when answered "yes"
10
Is the credit unavailable elsewhere on reasonable terms?
120.101; SOP Para. H
The lender's own policy, owners' liquidity, the credit memo
11
Are the use of proceeds, occupancy and loan limits within the rules?
SOP Ch. 3; 120.151
Sources and uses, the property, existing SBA loans of the group
Our grouping of SOP 50 10 8.1, Section A, Chapters 1, 3, 4 and 5.1 Franchise brands add a twelfth check: a brand that meets the FTC's definition of a franchise "must be on the Directory in order to obtain SBA financing".1
Only the list checks come from a database; the ownership and size tests come from documents
Where the evidence for each test usually comes from
RarelyPartlyMainly
Application formEntity documentsTax returnsFederal databasesJudgmentOperating, for profit, U.S.PartlyMainlyPartlyRarelyRarelySmall with affiliatesRarelyPartlyMainlyRarelyPartlyExcluded business typePartlyPartlyPartlyRarelyMainlyOwnership to 100%PartlyMainlyPartlyRarelyRarelyCitizenship and residenceMainlyPartlyRarelyRarelyPartlyFederal loss or debtPartlyRarelyRarelyMainlyRarelyExclusions and sanctionsRarelyRarelyRarelyMainlyPartlyCredit elsewhereRarelyRarelyPartlyRarelyMainly
Our reading of the sources1,6 · Our reading of the SOP and of the inspector general's account of SBA's 2023–2025 screen, which ran database checks and left size and for-profit status untested.
Show the numbers
Application form
Entity documents
Tax returns
Federal databases
Judgment
Operating, for profit, U.S.
Partly
Mainly
Partly
Rarely
Rarely
Small with affiliates
Rarely
Partly
Mainly
Rarely
Partly
Excluded business type
Partly
Partly
Partly
Rarely
Mainly
Ownership to 100%
Partly
Mainly
Partly
Rarely
Rarely
Citizenship and residence
Mainly
Partly
Rarely
Rarely
Partly
Federal loss or debt
Partly
Rarely
Rarely
Mainly
Rarely
Exclusions and sanctions
Rarely
Rarely
Rarely
Mainly
Partly
Credit elsewhere
Rarely
Rarely
Partly
Rarely
Mainly
What "documented" means here
The word that matters in the SOP is documented. SBA's loan system receives the ownership list and the lender's certifications. The lender's own file has to hold the evidence behind each answer: the CAIVRS result, a screenshot or equivalent record of each SAM.gov search, the operating agreement pages, the affiliates' returns.1 SBA's credit elsewhere regulation shows the standard it applies to a lender's certifications: submitting an application "constitutes certification by the Lender" that it examined the availability of credit and "has substantiation in its file to support the certification".8
One determination, three moments. The applicant "must meet all core requirements at the time of application and throughout loan closing and disbursement".1 An owner admitted after screening, a debt that turns delinquent, or a sanctions listing before the first draw is still a problem for the lender, which is why careful desks re-run the list checks before closing.
03 · The rules and their dates
SBA's eligibility rules as of October 2026, and the six dates that moved them
Status as of October 2026
In shortEligibility went back to lenders on June 1, 2025. Between March 2025 and March 2026 the citizenship rule was rewritten four times, ending with U.S. citizens and nationals only. SOP 50 10 8.1 took effect on October 1, 2026 and tightened the guaranty rule for trusts. New industry size standards are proposed and open for comment until November 20, 2026, so the table in force still governs.
SBA rewrote who may own a borrower four times in a year, then folded it all into SOP 50 10 8.1
Mar 7, 2025Owners must be identified
Lenders enter at least 81% of beneficial owners and certify none is an ineligible person; green card holders still eligible.
Jun 1, 2025SOP 50 10 8
Lenders determine eligibility again; 100% of owners entered; citizens, nationals and green card holders.
Jan 1, 2026Up to 5% foreign-held
Notice 5000-872050 for approvals from January 1: a 5% exception; citizens of China and Hong Kong ineligible; entity owners organized in the U.S.
Mar 1, 2026Citizens and nationals only
Green card holders may own no share; the applicant and the lender certify.
Mar 11, 202673,302 loans flagged
The inspector general's report on SBA's own screen; SBA agrees to review them at purchase.
Oct 1, 2026SOP 50 10 8.1
Nine notices folded in; trusts holding 20% together guarantee, and so do their trustors and donors.
Nov 20, 2026Size comments close
Proposed new size standards for 338 industries; not yet in force.
The core requirements; the lender determines and documents; 100% of direct and indirect owners entered in the SBA Loan System; lender certifies no owner or required guarantor is an ineligible person1
Effective October 1, 2026
Procedural Notice 5000-876626
Owners and SBA-required guarantors must be U.S. citizens or nationals with their principal residence in the U.S.; entity owners organized in the U.S.; six-month look-back5
Effective March 1, 2026; now in the SOP
13 CFR 121.301
Size for 7(a) and 504: the industry standard or the alternative standard, with affiliates; affiliation by ownership1
Current; control removed May 11, 2023
Alternative size standard
Tangible net worth up to $20 million and two-year average net income after tax up to $6.5 million14
Effective March 18, 2024
13 CFR 121.201
The size table; plumbing, heating and air-conditioning contractors $19.0 million in average annual receipts15,16
The excluded business types, from non-profits to speculative businesses17
Current
13 CFR 120.151
$3,750,000 cap on SBA's guaranty to a business and its affiliates; $5,000,000 per 7(a) loan18
Current
13 CFR 120.524
SBA is released from its guaranty if the lender "failed to comply materially with any Loan Program Requirement", and may recover "at any time"3
Current
Form 1919 revision
Adds each owner's date of birth, citizenship status and entity type19
Proposed February 23, 2026; until issued, lenders attach the certifications5,12
Which version governs a file
SBA's two notices on the new SOP describe the switch-over in different words. The August 14, 2026 notice says SOP 50 10 8.1 "will apply to all applications that are issued an SBA loan number on or after that date".7 The September 25 notice that issued the final technical updates says it applies "to all applications received by SBA on or after that date", and both say to keep using the earlier version for applications "submitted through September 30, 2026".12 Most files fall clearly on one side. For the few that straddle October 1, the safe practice is to write on the file which version was applied and why.
Old loans keep their old rules. When SBA reviews a defaulted loan for purchase, it "will apply the requirements of SOP 50 10 in effect when the Loan was approved".4 A 2024 loan with a green card holder among its owners was eligible then and is judged by the 2024 rule. A change of owner or guarantor on that loan today must meet today's rule, and such a loan may not be increased.20,1
The system's name changed too. SOP 50 10 8.1 calls the place where lenders enter ownership and certify "the SBA Loan System", and writes "E-Tran Servicing, or successor SBA Loan System" for changes after approval. The citizenship notices of early 2026, and many lenders' checklists and screens, still say E-Tran.1,5 Both names refer to the same certification.
04 · Ownership to 100%
How to trace indirect ownership: multiply through every company until each branch ends in a person
In shortThe lender must list 100% of the applicant's direct and indirect owners, people and companies. Indirect shares are multiplied through each layer and added across paths. The percentage each person ends up with decides which tests apply: any share means the citizenship test, 20% brings a personal guaranty and more searches, and more than 50% brings the widest affiliation test.
The SOP's instruction is short: "The SBA Lender must enter into the SBA Loan System 100% of the Applicant's direct and indirect owners, which includes entity and individual owners with direct or indirect ownership." Spouses' and minor children's shares "must be combined".1 It gives one example of the arithmetic: Jane Doe owns 15% of the applicant and 100% of a company that owns another 50%, so "SBA considers Jane Doe to own 65 percent of the Applicant".1
In practice the arithmetic is easy and the inputs are scattered. The applicant's operating agreement shows its direct members. Each amendment can add or remove one. Each member that is itself a company has its own agreement, which shows its members. The K-1s show who received a share of profit, which is a useful cross-check: a name on a K-1 that appears nowhere else is a question to ask.
The example, traced
Owner
On the application?
Path
Share of Brassmoor
Dana Whitfield
Yes
Direct
40.0%
Ridgeway Trades Holdings, LLC
Yes
Direct (a company)
35.0%
Marcus Ridgeway
No
60% of Holdings × 35%
21.0%
Elena Ridgeway
No
40% of Holdings × 35%
14.0%
Tomas Valek
Yes
Direct
15.0%
Keystone Field Partners, LLC
No
Direct, by Amendment No. 2, §3.1, January 15, 2026
10.0%
Luis Ardoya
No
40% of Keystone × 10%
4.0%
Priya Natesan
No
30% of Keystone × 10%
3.0%
Owen Becker
No
30% of Keystone × 10%
3.0%
Fictional example. The four direct owners add to 100%, and so do the seven people behind them: 40 + 21 + 14 + 15 + 4 + 3 + 3.
Only one of the people found in the documents crosses the 20% line that brings a personal guaranty
Brassmoor Mechanical, each person's direct and indirect share
Dana Whitfieldlisted · guarantor40%
Marcus Ridgewaythrough the holding company · guarantor21%
Tomas Valeklisted15%
Elena Ridgewaythrough the holding company14%
Luis Ardoyathrough Keystone4%
Priya Natesanthrough Keystone3%
Owen Beckerthrough Keystone3%
Fictional example from this guide · Every one of the seven, at any share, must pass the citizenship and residence test.
Show the numbers
Person
Share of the applicant
Dana Whitfield
40%
Marcus Ridgeway
21%
Tomas Valek
15%
Elena Ridgeway
14%
Luis Ardoya
4%
Priya Natesan
3%
Owen Becker
3%
What each ownership line brings with it
Share of the applicant
What applies
Rule
Any share, direct or indirect
Listed in the SBA Loan System; must be a U.S. citizen or national with a U.S. principal residence; entity owners organized in the U.S.; OFAC check of owners
Unlimited full guaranty, from a person or a company; personal financial statement within 90 days; SAM.gov search; credit-elsewhere liquidity test; same-subsector affiliation tests when no one owns a majority
Each trust guarantees; the trustor guarantees, whether the trust is revocable or not; "All donors to the trust will be deemed to have Trustor status for eligibility purposes"
SOP 50 10 8.1 Ch. 5, tightened October 1, 2026: SOP 50 10 8 counted each trust alone and asked the trustor of a revocable trust only12
More than 50%
Affiliation with the owner's other majority-owned businesses in the same 3-digit industry subsector
The SOP uses two slightly different lines: an Associate is an owner of "more than 20 percent", while guaranties and SAM.gov searches start at "20% or more".1 A 20.0% owner is a guarantor and is searched in SAM.gov.
Why the federal ownership registers do not help. A bank's customer due diligence rule identifies owners of 25% or more.21 FinCEN's August 14, 2026 rule "continues to exempt reporting companies from having to report the BOI of U.S. person beneficial owners", so there is no federal register of domestic owners to check against.22 SBA wants every owner, at any share. The applicant's own documents are the only complete source.
05 · Citizenship and residence
Who may own an SBA borrower since March 1, 2026, and what the six-month look-back reaches
In shortEvery direct and indirect owner and every SBA-required guarantor must be a U.S. citizen or U.S. national whose principal residence is in the United States or its territories. Green card holders, visa holders, anyone living abroad and companies organized abroad may own no share. An ineligible owner in the six months before the loan number makes the business ineligible, unless that person divests completely first.
The current text reads: "SBA financing is limited to business Applicants with 100% direct and/or indirect owners and SBA-required guarantors, all of whom must be U.S. Citizens or U.S. Nationals who have their Principal Residence in the United States, its territories, or possessions. All entity owners (whether direct or indirect) must be created, organized, or incorporated in the United States, its territories, or possessions."1 The lender certifies in SBA's system "that, to the best of their knowledge, no direct or indirect owner or SBA-required guarantor is an 'Ineligible Person'".1
About 4 in 100 of SBA's fiscal 2025 approvals went to businesses with a green card holder among the owners
4 in 100
of roughly 85,000 SBA approvals in fiscal 2025 (3,358 loans) had a lawful permanent resident among the owners. Each of those ownership structures would fail the rule in force since March 1, 2026.
of roughly 85,000 SBA approvals in fiscal 2025 (3,358 loans) had a lawful permanent resident among the owners. Each of those ownership structures would fail the rule in force since March 1, 2026.
4 of 100
The eight kinds of ineligible person
Status
Undocumented aliens in the U.S. illegally
People granted asylum, refugees, visa holders, non-immigrant aliens, DACA recipients
Anyone who is neither a U.S. citizen nor a U.S. national
Lawful permanent residents, permanent or conditional
Residence, origin and lists
Anyone, citizens included, whose principal residence is outside the U.S. and its territories
Companies created or organized outside the U.S.
Citizens of the People's Republic of China or Hong Kong
Anyone on an OFAC sanctions list
SOP 50 10 8.1, Appendix 3, as introduced by Procedural Notice 5000-876626.1,5 "Principal Residence is defined by IRS Publication 523."1
Four details that decide close cases
Situation
The rule
An ineligible owner left recently
"The Applicant business is ineligible if any direct or indirect owner of the business commencing 6 months prior to the date of issuance of the SBA loan number is an Ineligible Person, unless the Ineligible Person completely divests their ownership interest prior to the date of issuance of the SBA loan number."1
A guarantor who is not an owner
An SBA-required guarantor must meet the rule. A limited or supplemental guaranty that the lender wants for its own approval may come from an otherwise ineligible person, except someone in the U.S. illegally.1 SBA's answers to lenders' questions confirm it "does not restrict a Lender's ability to obtain additional supplemental guarantees".20
Businesses on the applicant's tax return
"All the businesses on the tax return are subject to these requirements." Affiliates that file their own returns are not.5
A U.S. national
People born in American Samoa and Swains Island. The lender must document "evidence of the person's status as a U.S. National (e.g., birth certificate or passport)" and enter the Social Security number.1
The applicant's supplement and the lender's ownership certification
The SOP asks for two certifications. The applicant signs a supplement to the application that "none of the direct and indirect owners of the Applicant … and all SBA-required guarantors … are Ineligible Persons", attached until SBA issues the revised Form 1919.5 The lender certifies in SBA's system to the best of its knowledge. A lender may also ask each owner to certify his or her own citizenship and residence as its own policy, beyond what SBA requires, which is sensible for owners nobody at the bank has met. Naturalized citizens need no further proof if the application shows them as citizens.1
Fair lending. SBA's programs are special purpose credit programs under the Equal Credit Opportunity Act, and Regulation B allows a creditor to "consider the applicant's immigration status or status as a permanent resident of the United States".1,24 What a lender may not do is guess. A name, an accent or a foreign mailing address is a reason to ask for the certification, never a finding.
06 · Affiliates and size
SBA affiliation and size: five ownership tests, two size standards, and a worked group
In shortSince May 2023, affiliation for SBA loans turns on ownership alone. A business is added to the applicant's size when one owns a majority of the other, or when a big owner also holds a majority of another business in the same 3-digit industry subsector. The group must then fit its industry's size standard or the alternative standard of $20 million net worth and $6.5 million average net income. The group's SBA loans count toward the program limits too.
The 2023 rule "removed the principle of control, both affirmative and negative control, as establishing affiliation between entities".1 What remains is five ownership tests, which the SOP sets out in order. A 3-digit subsector is the first three digits of the NAICS industry code: 238, specialty trade contractors, covers plumbers, electricians, roofers and excavators alike.1
Five ownership questions decide which businesses count toward the applicant's size
1Applicant owns more than 50% of another business?
Then that business is an affiliate.
Every applicant
2A business owns more than 50% of the applicant?
The owner is an affiliate, and so are its other majority-owned businesses in the same subsector.
Company owners
3A person owns more than 50% of the applicant?
That person's other majority-owned businesses in the same subsector are affiliates.
Majority owners
4No majority owner: is a 20%+ owner a business in the subsector?
Then the owner is an affiliate.
20%+ company owners
5No majority owner: does a 20%+ owner hold over 50% of a business in the subsector?
Then that business is an affiliate.
Every 20%+ owner
Our reading of the sources1 · Options, convertible securities and agreements to merge count as if exercised; an owner's ability to sell down does not avoid affiliation.
Show the numbers
Step
What happens
Who
Time
Applicant owns more than 50% of another business?
Then that business is an affiliate.
Every applicant
A business owns more than 50% of the applicant?
The owner is an affiliate, and so are its other majority-owned businesses in the same subsector.
Company owners
A person owns more than 50% of the applicant?
That person's other majority-owned businesses in the same subsector are affiliates.
Majority owners
No majority owner: is a 20%+ owner a business in the subsector?
Then the owner is an affiliate.
20%+ company owners
No majority owner: does a 20%+ owner hold over 50% of a business in the subsector?
Then that business is an affiliate.
Every 20%+ owner
The example's related businesses, tested
Business
Who holds it
Industry
Affiliate?
Tallbrook Plumbing & Drain, Inc.
Ridgeway Trades Holdings, 70% (a 35% owner of Brassmoor)
238220, subsector 238
Yes: no one owns a majority of Brassmoor, and a 20%+ owner holds over 50% of a business in subsector 238
Whitfield Excavating, LLC
Dana Whitfield, 30%
238910, subsector 238
No: same subsector, but 30% is no majority
Ridgeway Rentals, LLC
Ridgeway Trades Holdings, 100%
531120, subsector 531
No: majority-owned, but a different subsector
Fictional example. The affiliate appears nowhere on the application; it is on the holding company's 2025 Form 1065, Schedule B, question 3a, where a partnership lists each corporation in which it owns directly 20% or more, or directly or indirectly 50% or more, of the voting stock. Question 3b lists its interests in partnerships and trusts on the same terms.25
Sizing the group, two ways
Under the industry standard, the applicant alone must fit the standard for its own industry, and with its affiliates must fit the standard for its own primary industry or the group's, whichever is higher. Receipts come from federal tax returns.1 For SBA's business loan programs, an applicant in business at least three completed fiscal years may average its receipts over three years or five.26 Affiliates' average receipts are added.26
Under the alternative standard, the applicant with its affiliates must have tangible net worth of no more than $20 million and "average net income after Federal income taxes (excluding carry-over losses) for the 2 full fiscal years prior to application" of no more than $6.5 million.1,14 An applicant may qualify under either.1
Over the industry standard with its affiliate, Brassmoor is still small under the alternative standard
Brassmoor Mechanical and Tallbrook Plumbing & Drain together, against each limit
The limitThe group
Average annual receipts (industry standard)$19M$21.2M
Tangible net worth (alternative)$20M$6.7M
Average net income after tax (alternative)$6.5M$1.9M
Fictional example from this guide · Receipts: $11.42M for Brassmoor plus $9.76M for the affiliate, five-year averages from the returns. Limits: SBA's size table for NAICS 238220 and the alternative standard.
Show the numbers
The limit
The group
Average annual receipts (industry standard)
$19M
$21.2M
Tangible net worth (alternative)
$20M
$6.7M
Average net income after tax (alternative)
$6.5M
$1.9M
The group's SBA limits
Affiliation also matters when size does not. "If affiliation exists, SBA's loan maximums apply to the Applicant, including all affiliates, as if all were a single business."1 The limit that adds up the whole group is SBA's guaranty: the guaranty to "any one business and its affiliates must not exceed $3,750,000", counting existing 7(a) and 504 loans. Separately, any one standard 7(a) loan may be up to $5,000,000.1,18 Some lenders also test the group's gross SBA loans against $5,000,000 as a stricter check of their own. SBA's only limit across a group is the guaranty.
The affiliate's existing SBA loan brings the group to 85% of SBA's guaranty cap
Brassmoor's group: SBA's guaranty limit, and the bank's own gross-loan check
SBA's guaranty cap: about $3,202,500 of $3,750,000$2,887,500 new + about $315,000 existing85.4%
Bank's own check: gross SBA loans $4,270,000 of $5,000,000$3,850,000 new + $420,000 existing85.4%
Fictional example from this guide · Only the first line is an SBA limit (13 CFR 120.151). The second is a policy setting in the example bank's screens. The affiliate's guaranty share is assumed at 75%, SBA's maximum for loans over $150,000; use the actual figure from the loan's terms.
Show the numbers
Limit
Share of the limit used
SBA's guaranty cap: about $3,202,500 of $3,750,000
85.4%
Bank's own check: gross SBA loans $4,270,000 of $5,000,000
85.4%
Credible evidence. A lender approving under delegated authority "may accept as true the size information provided by an Applicant, unless credible evidence to the contrary is apparent".1 A partnership return in the package that lists a 70% subsidiary in the applicant's own subsector is that evidence. Before denying eligibility on size, the applicant or the SBA official with final authority may ask SBA's Government Contracting Area Director for a formal size determination.1
07 · CAIVRS, SAM.gov and OFAC
CAIVRS, SAM.gov and OFAC checks for an SBA loan: who goes through each, and what clears a hit
In shortCAIVRS answers two tests, prior federal loss and past-due federal debt, searched by tax ID. SAM.gov answers whether anyone is debarred or excluded from federal business, searched by name or entity ID. OFAC's lists answer whether anyone is sanctioned. Each check covers a different set of people, every result belongs in the file, and a hit clears only with a document from the agency or a recorded reason why the match is false.
Check
What it answers
Who must be covered
What the file keeps
CAIVRS (HUD)
Prior loss to the government; past-due federal debt
The applicant, any guarantor, and every Associate: officers, directors, owners of more than 20%, key employees1
"SBA Lenders must retain documentation of the CAIVRS check in the loan file"1
SAM.gov exclusions (GSA)
Suspended, debarred or otherwise excluded
The applicant; 20% owners; officers, directors and managing members; key employees; a living trustor; 20% entity owners; both companies in a property-holding structure1
Evidence of each search, "for example, a screen shot of the search results"1
OFAC lists (Treasury)
Sanctioned people and entities
"The applicant business and owners … at the time of application"1
The search and, for a potential match, the reasons it was or was not a true match27
Each federal check covers a different set of people, so one list of owners feeds three searches
Who each check must cover under SOP 50 10 8.1
Not requiredRequired
CAIVRSSAM.govOFACThe applicant businessRequiredRequiredRequiredOwner of 20% or moreRequiredRequiredRequiredOwner under 20%Not requiredNot requiredRequiredOfficer or directorRequiredRequiredNot requiredKey employeeRequiredRequiredNot requiredRequired guarantorRequiredNot requiredNot requiredCompany owning 20% or moreRequiredRequiredRequired
Our reading of the sources1 · Our reading of Chapter 1 (CAIVRS through the Associate definition, OFAC for 'owners') and Chapter 4 (SAM.gov). Many lenders run OFAC on officers and guarantors as well under their own sanctions program.
Show the numbers
CAIVRS
SAM.gov
OFAC
The applicant business
Required
Required
Required
Owner of 20% or more
Required
Required
Required
Owner under 20%
Not required
Not required
Required
Officer or director
Required
Required
Not required
Key employee
Required
Required
Not required
Required guarantor
Required
Not required
Not required
Company owning 20% or more
Required
Required
Required
Prior loss or past-due debt: two different tests in one database
A prior loss is a default on "a Federal loan or federally assisted financing" that cost the government money, by the applicant or by "any other business owned, operated, or controlled by the Applicant or an Associate". The SOP defines that kind of financing as "any loan that is made for business purposes" by a federal agency, directly or through a guaranty.1 A loss that has been "fully satisfied" can be processed, with the file showing how.1 Under a policy update effective June 1, 2026, when the loss was on an SBA 7(a) or 504 loan, an owner who held under 20% of the failed business, did not guarantee its loan and had no control over it can be considered for a waiver, which SBA decides case by case.7,1
Delinquent federal debt is any non-tax debt to the federal government owed by the applicant or "any guarantor (except a Supplemental Guarantor)" and unpaid 90 days after its due date.1 In the example, CAIVRS shows a federal housing claim on an FHA home loan against Marcus Ridgeway, the 21% owner who must guarantee. The prior-loss test covers business financing, so a claim on a home loan falls outside it. It counts instead as a possible past-due federal debt of a required guarantor, which makes the application ineligible until HUD confirms the debt is resolved and the file shows it.
A "no" that conflicts with a record. Marcus Ridgeway's borrower information form answered "No" to the federal debt question. A hit in CAIVRS that contradicts an owner's own answer is two items to clear: the debt, and a corrected form. CAIVRS searches by Social Security number or EIN, so a hit there belongs to the person; a name hit in SAM.gov or OFAC may not. OFAC's own guidance: "Many potential matches identified through screening are false positives."27
HUD runs CAIVRS as "a shared, inter-agency database" so that participating agencies and their lenders can check that applicants "are not presently delinquent on another Federal obligation".28 SBA points lenders to its web portal, which accepts several tax IDs at once.1 GSA publishes a SAM.gov exclusions interface that returns public exclusion records in a machine-readable form.29
08 · Business type and credit elsewhere
SBA ineligible businesses, use of proceeds and credit elsewhere: the program tests that need a reader
In shortSBA excludes some kinds of business outright and others above a revenue threshold. Many of the calls are visible in the documents; a few, such as whether a management agreement makes the business passive, need someone to read the contract. Credit elsewhere is the lender's own judgment and must be explained in the credit memo with specific reasons.
The excluded types are listed in 13 CFR 120.110, from (a) non-profit businesses to (s) speculative businesses.17 The SOP explains each and sets thresholds for several: a loan packager earning more than a third of its revenue from packaging SBA loans, a business earning more than a third of its gross revenue from legal gambling, a pawn shop earning most of its revenue from interest, a hotel earning half its revenue or less from guests staying 30 days or less.1,17 Two recur in practice:
Passive businesses
Landlords that do not occupy what they finance are excluded, apart from an eligible property-holding company that leases to the operating company. A management agreement that gives a third party "sole discretion over the business operations" also makes the applicant passive; the applicant needs "meaningful oversight": the budget, large spending, the bank accounts and the employees.1
Character
Ineligible if an Associate "is currently incarcerated, serving a sentence of imprisonment imposed upon adjudication of guilty, or is under indictment for a felony or any crime involving or relating to financial misconduct or a false statement". Parole or probation can be eligible, with a plan for the business if it depends on that person.1
SBA's own 2023–2025 screen checked five of the 19 ineligible business types it was meant to cover
ScreenedLeft to the lender's file
Ineligible business types (inspector general's count)5 types14 types
Source6 · Screened: marijuana businesses, loan packagers, businesses with associates with a criminal history, prior loss to the government, certain investment-company-financed businesses.
Show the numbers
Screened
Left to the lender's file
Ineligible business types (inspector general's count)
5 types
14 types
Credit elsewhere, use of proceeds and occupancy
The lender "must certify and indicate that the Applicant does not have the ability to obtain some or all of the requested loan funds on reasonable terms" elsewhere, including from itself. The credit memo must weigh the liquidity of every 20% owner and give "the specific reasons why the Applicant does not meet conventional loan policy requirements". A credit-score policy alone is never enough, and neither is a better rating under the Community Reinvestment Act.1 The rule has a long record of findings: in fiscal 2016, "Over 40 percent (17 of 40) of the on-site lender reviews" found lenders out of compliance with it.30
When the loan buys or improves real estate, the business must occupy at least 51% of an existing building or 60% of a new one.1 In the example the bank finances a building Brassmoor will occupy entirely.
09 · What goes wrong
Where SBA eligibility files fail: affiliates without returns, percentages without agreements
In shortThe inspector general's 2026 report is the clearest record. When SBA cleared its own eligibility warnings, 38% of the clearances it sampled had no supporting documents, and almost nine in ten of those were affiliation warnings. The missing items were ordinary documents: the agreement that proves a percentage, the returns behind a size figure, the contract showing an affiliate was sold.
73,302
7(a) loans, about $32 billion, approved through SBA's own eligibility screen from August 1, 2023 to December 31, 2024, now flagged for review when a guaranty is claimed.6
SBA OIG Report 26-07, March 11, 2026
38%
of 188 sampled loans with a cleared eligibility warning had no documents to support the clearance: 71 loans, about $60.7 million.6
SBA OIG Report 26-07
62 of 71
of those loans carried warning 803, "Additional Business Affiliation", the commonest code in the period.6
SBA OIG Report 26-07
Of 188 sampled clearances, 71 lacked support, and 62 of those were about affiliates
SBA's review of its own eligibility warnings, loans approved August 2023 to December 2024
Sold or inactive affiliate without the sale contract
13 files
Other matters, such as industry and business name
11 files
The report's diagnosis applies to any lender's file. SBA's instructions let the lender clear an affiliation warning with "a copy of their credit memorandum or other documentation". The inspector general's office (OIG) commented: "Although the credit memorandum is listed as acceptable support, on its own it is not sufficient to validate an applicant's information because it does not include underlying source documentation."6
The pattern goes back years
In 2019, OIG reviewed eight early-defaulted loans SBA had already paid on and found material deficiencies justifying denial in five, about $8.7 million. The lenders had not documented "eligibility, repayment ability, size standards, franchise agreements" and more.31
In 2024, OIG found 5,044 7(a) loans, $4.5 billion, approved between October 2019 and May 2023 for borrowers whose pandemic loans carried an unresolved eligibility or potential fraud issue. Delegated lenders approved 92% of all 7(a) loans in that period.32
In September 2026, OIG's review of two small business lending companies counted 20 eligibility deficiencies across 18 SBA reviews and one examination, alongside repeated errors on the borrower information form.33
Why owners and affiliates go missing
Where it hides
The document that finds it
A member admitted by amendment
Every amendment to the operating agreement, in date order
The people behind a company owner
That company's own agreement or schedule of members
A spouse's or minor child's share
The operating agreement and the K-1s; shares are combined1
An affiliate behind a holding company
The holding company's return: Form 1065 Schedule B, Form 1120-S or 1120 Schedule
A trust's people
The trust agreement and the gift history; donors count as trustors since October 1, 202612
An owner who left last spring
Transfer documents dated within the six-month look-back1
10 · The guaranty at risk
What a missed owner or affiliate costs when SBA is asked to pay the guaranty
In shortSBA can refuse to pay all or part of a guaranty when the lender did not follow the rules, and can claw back what it has paid. An ineligible loan made under delegated authority is SBA's first example of a full denial. The loss lands years after the screening, on a loan that has already defaulted.
The regulation is broad: SBA "is released from liability on a loan guarantee (in whole or in part, within SBA's exclusive discretion)" if the lender "failed to comply materially with any Loan Program Requirement", failed to act prudently, or placed SBA at risk. If SBA finds one of those "at any time", it "is entitled to recover any moneys paid on the guarantee plus interest from the Lender".3 SBA's servicing SOP gives the eligibility case first: "A full Denial of Liability is justified if a delegated Lender made an ineligible 7(a) Loan in accordance with the Loan Program Requirements in effect when the Loan was approved."4
Eligibility came fourth among the deficiencies SBA's reviewers found at two small business lending companies
Deficiencies counted across 18 SBA reviews and one examination, October 2021 to March 2025 (selected categories)
Other core requirements (tax transcripts, insurance)31
Loan closing and disbursement26
Technical exceptions (incomplete forms, Form 1919 among them)21
Other core requirements (tax transcripts, insurance)
31
Loan closing and disbursement
26
Technical exceptions (incomplete forms, Form 1919 among them)
21
Eligibility (eligible passive businesses)
20
Use of proceeds
15
Secondary market sale
14
Prohibited fees
10
The purchase review is also where SBA's own decisions are tested. Between October 1, 2021 and March 31, 2025, SBA's quality control team made final decisions on 545 loans that its staff had recommended for repair or denial. OIG examined 32 that were overturned in the lender's favor and found 16, about $11.5 million, without enough evidence for the decision; four of the twelve "other eligibility" cases were among them.34
Half of the overturned purchase decisions the inspector general examined lacked the evidence to support them
32 of the 545 quality control decisions made October 2021 to March 2025, each overturned in the lender's favor
Without enough evidence (about $11.5 million)Supported
Overturned decisions OIG examined16 loans16 loans
Source34 · Four of the twelve 'other eligibility' cases were among the 16.
Show the numbers
Without enough evidence (about $11.5 million)
Supported
Overturned decisions OIG examined
16 loans
16 loans
For the 73,302 loans SBA screened itself, a lender's exposure is narrower. Under the SOP in force then, SBA could not deny or repair a purchase over an eligibility call it had made itself. It agreed to flag the loans for review at purchase and to seek recovery "where appropriate and legally justified", and its officials told OIG they would seek remedy on defaulted loans found ineligible where the lender knew of the ineligibility.6
Exposure by the numbers a lender controls
SBA's guaranty on fiscal 2026 7(a) loans averaged about $425,000 per loan, by our count of SBA's public loan data.35 Of the loans approved in fiscal 2022, 4.1% had been charged off by September 30, 2026.35 Those are the loans whose files SBA reads. A lender can estimate its own exposure as the number of defaulting SBA loans a year, times the share whose eligibility file would not survive a careful reading, times the guaranty at stake. The second figure is the one nobody publishes, and a small sample of re-screened files is the cheapest way to estimate it.
Fair lending and the eligibility file. Eligibility decisions are credit decisions under the Equal Credit Opportunity Act. SBA's citizenship rule is a program requirement a lender may apply, since Regulation B allows creditors to consider immigration status and SBA's programs are special purpose credit programs.24,1 The risk sits in uneven practice: asking some owners for proof and letting others pass.
The 2026 CFPB changes. A CFPB rule effective July 21, 2026 states that ECOA does not authorize disparate-impact liability and amends the special purpose credit program provisions; the ban on disparate treatment is unchanged, and a lawsuit challenging the rule is pending. The CFPB's rewritten small business data rule takes effect for collection on January 1, 2028.36
11 · The market
SBA 7(a) lending in numbers: fewer loans in fiscal 2026, almost all approved by lenders themselves
In shortSBA approved 56,130 7(a) loans for $32.4 billion in fiscal 2026, down by more than a quarter in number from fiscal 2025, SBA's biggest year by dollars. Nineteen in twenty were approved under a lender's own delegated authority, so the lender's eligibility file is the only screening most loans get. More than half of the 1,202 lenders made five loans or fewer, so many lenders apply a rulebook that changes often only a few times a year.
7(a) approvals fell by more than a quarter in fiscal 2026, from the busiest year since 2020
SBA 7(a) loans approved, by federal fiscal year
42,298FY2020
51,856FY2021
47,678FY2022
57,362FY2023
70,242FY2024
78,078FY2025
56,130FY2026
Source35,37 · Our count of SBA's public 7(a) loan data as of September 30, 2026, approvals later canceled included. SBA's FY2025 release gave 77,600 loans; the later data includes revisions. FY2026 dollars: $32.4 billion.
Show the numbers
Period
Value
FY2020
42,298
FY2021
51,856
FY2022
47,678
FY2023
57,362
FY2024
70,242
FY2025
78,078
FY2026
56,130
Fiscal 2025 was SBA's biggest year by dollars: 84,400 7(a) and 504 loans for $44.8 billion, "the most capital ever delivered to small businesses" in SBA's words.38 Fiscal 2026 ended with 56,130 7(a) loans for $32.4 billion, with "double-digit percentage declines for both metrics", in American Banker's words. The paper tied the fall in part to the stricter underwriting rules of 2025 and noted that they may not be the only reason.37
Lenders' own delegated approvals made up 95% of fiscal 2026 7(a) loans
7(a) loans approved in FY2026, by processing method
56,130loans
Preferred Lenders Program34,191
SBA Express19,226
Sent to SBA for a decision2,100
Other programs613
Source35 · Our count of SBA's public loan data. Under the Preferred Lenders Program and SBA Express the lender decides eligibility; SBA decides only on applications sent to it.
Show the numbers
Part
Value
Preferred Lenders Program
34,191
SBA Express
19,226
Sent to SBA for a decision
2,100
Other programs
613
More than half of SBA's 1,202 lenders made five 7(a) loans or fewer in fiscal 2026
Lenders by the number of 7(a) loans they approved in FY2026
1 loan265 lenders
2 to 5 loans383 lenders
6 to 20 loans284 lenders
21 to 99 loans198 lenders
100 or more loans72 lenders
Source35 · Our count by lender name, 1,202 lenders in all. The top ten lenders made 46% of the loans; the top hundred, 80%.
Show the numbers
Loans made
Lenders
1 loan
265 lenders
2 to 5 loans
383 lenders
6 to 20 loans
284 lenders
21 to 99 loans
198 lenders
100 or more loans
72 lenders
The shape matters for eligibility work. A lender making a hundred SBA loans a year can keep a specialist who reads every notice the week it appears. The 648 lenders that made five or fewer in fiscal 2026 use the rules a few times a year, under a rulebook that took in nine notices between September 2025 and July 2026.35,7 Specialty trade contractors, the subsector of the example, received 5,160 of the fiscal 2026 loans, about 9%.35
No public source measures the time or cost of an eligibility review, the share of applications with an owner left off, or how often eligibility decides a purchase denial across the portfolio. Part C shows how to measure your own.
12 · Software and AI
What software can settle in an eligibility file, and what stays with the person who signs
In shortSoftware can read the agreements, multiply the percentages, add the receipts, run the list searches on every name and write each finding with its page. It cannot be the one who certifies, clears a hit, judges character or explains why credit is unavailable elsewhere. SBA's own screen shows the risk of software that reads only databases: it skipped the tests whose data sat in documents.
SBA's 2023–2025 framework used "technology for real time validation of applicant data".6 It drew on federal and commercial databases and the business's credit, and it left size, for-profit status and most business types untested, because the data those tests need sits in agreements and tax returns.6 Any tool for this work should be judged by which of the eleven questions it produces evidence for.
The tests that take the most reading need the least judgment, which is where software helps first
Eligibility tests by reading effort and by how much they rest on a person's judgment
What SR 26-2 means for ownership arithmetic and size rules
Text
What it says
What it means for eligibility tools
OCC Bulletin 2026-13, Federal Reserve SR 26-2, FDIC FIL-15-2026, April 17, 2026
One joint issuance that replaces SR 11-7 and OCC Bulletin 2011-12. A model "excludes simple arithmetic calculations … as well as deterministic rule-based processes". Generative AI is outside the guidance's scope, and the bank's own risk management "should guide the determination of appropriate governance and controls"39,40,41
Ownership arithmetic and the size rules are rules, outside the model definition. Generative AI that reads documents falls under the bank's own governance; a non-generative AI model stays within the guidance
Third-party guidance, June 9, 2023
Sound risk management for every stage of a third-party relationship. In force; the agencies proposed a shorter replacement on September 15, 2026, with comments due November 16, 202642
The lender stays responsible for the determination, whoever reads the documents
13 CFR 120.101
Submission is certification with "substantiation in its file"1
Every finding must point to its page
Colorado SB26-189, signed May 14, 2026
Duties for automated decisions in "financial or lending services", most from January 1, 202743
Aimed at consumers; whether it reaches a business loan with personal guarantors is a question for counsel
SBA OIG 26-15, September 2026
OMB presumes that AI affecting a person's request for a federal loan is high impact, as SBA's inspector general reports44
Binds SBA alone; for lenders it sets a sensible bar: test before relying
CAIVRS searches, name matches and documents never sent
CAIVRS is a web portal for lenders; the SOP gives no machine interface, so the search itself stays a supervised step under the lender's own access.1
A name match in SAM.gov or OFAC needs a person to compare dates of birth, addresses and identifiers.27
Software sees only the documents it is given. An owner whose agreement was never sent stays invisible until someone asks for it, which is why the 100% check matters: a total under 100% means a document is missing.
13 · How teams do it today
Who screens an SBA application today: five roles, six hand-offs, and the hours spent finding owners
In shortFour or five people touch eligibility: the business development officer who gathers the package, the processor who orders checks and certifies in SBA's system, the underwriter who reads and decides, a compliance officer who reviews cleared hits, and the SBA lending manager who owns the rules. Most of the time goes to finding owners and affiliates in documents, and to waiting for the borrower to send what is missing.
Who screens SBA eligibility: officer, processor, underwriter, compliance
BD
Business development officer
Brings the deal, collects the package and goes back to the borrower for anything missing. Cares about asking the borrower once, with a precise list.
LP
SBA loan processor
Logs the package, orders the CAIVRS and other searches, enters ownership and certifies in the SBA Loan System. Cares about certifying only what the file proves.
UW
SBA underwriter or credit analyst
Reads the documents, traces owners, tests size and the program rules, decides and signs eligibility, then writes the credit memo. Cares about spending the day on judgment instead of on finding owners.
CO
Compliance officer
Takes a second look at any cleared CAIVRS, OFAC, SAM.gov or character issue, where the lender separates the role. Cares about the agency's own document being in the file.
LM
SBA lending manager
Owns the checklist, the delegated authority, SBA's review findings and purchase outcomes. Usually the buyer. Cares about a file that survives a purchase review years later.
A typical eligibility screen passes through four hands before the loan number
1Package complete
41 documents logged; searches ordered.
ProcessorThursday
2Owners traced
Agreements, amendments and the owners' own papers read; percentages multiplied.
UnderwriterDay 1
3People and lists
CAIVRS, SAM.gov, OFAC and the character questions for each person.
Processor and underwriterDay 1–2
4Affiliates and size
Owners' other businesses found and tested; receipts added; alternative standard if needed.
UnderwriterDay 2–3
5Items to clear
One request to the borrower; documents back; tests re-run.
Business development officerDay 3–5
6Sign and certify
Determination signed; second look on cleared hits; ownership certified.
Underwriter, compliance, processorDay 5
Fictional example from this guide · The fictional example's steps, by hand; timings are illustrative.
Show the numbers
Step
What happens
Who
Time
Package complete
41 documents logged; searches ordered.
Processor
Thursday
Owners traced
Agreements, amendments and the owners' own papers read; percentages multiplied.
Underwriter
Day 1
People and lists
CAIVRS, SAM.gov, OFAC and the character questions for each person.
Processor and underwriter
Day 1–2
Affiliates and size
Owners' other businesses found and tested; receipts added; alternative standard if needed.
Underwriter
Day 2–3
Items to clear
One request to the borrower; documents back; tests re-run.
Business development officer
Day 3–5
Sign and certify
Determination signed; second look on cleared hits; ownership certified.
Underwriter, compliance, processor
Day 5
Finding owners and affiliates takes more than half the hand-built screen
Hours of work on one application with a holding-company owner, by step
Finding every ownerAffiliates and sizeCertifications and formsCAIVRS, OFAC, SAM.govChecklist, request, signature
By hand (estimate)8 h8 h4 h4 h6 h
Illustrative · replace with your own numbers · An estimate for one file: 30 working hours, about four days; no published study measures it. Time five of your own files by step.
Show the numbers
Finding every owner
Affiliates and size
Certifications and forms
CAIVRS, OFAC, SAM.gov
Checklist, request, signature
By hand (estimate)
8 h
8 h
4 h
4 h
6 h
Underwriter, processing desk, service provider or software
1 · In house
The underwriter screens
Eligibility is the first part of the credit analysis, done by the person who will sign it.
Strength
Judgment stays close to the credit
Strain
Underwriter hours go to document tracing
2 · Desk
A processing desk assembles
Processors gather the evidence and fill a checklist; the underwriter reviews and signs.
Strength
Cheaper per file
Watch for
A signature on a summary nobody tested against the documents
3 · Outside
A lender service provider
Common at lenders making few SBA loans. The provider and its staff are searched in SAM.gov before their first day.1
Strength
Expertise on demand
Watch for
The lender "bears full responsibility for all aspects of its 7(a) loan operation"1
4 · Software
Questionnaires or document reading
Questionnaire tools ask the borrower the eligibility questions. Document-reading tools trace owners and affiliates from the package.
Strength
Every file gets every test
Watch for
Which tests it produces evidence for, and who signs
Part B · See it working
Botminds SBA Eligibility Screening, one application from 90% declared to 100% signed
Part A described the work without naming a product. This part shows how Botminds does it, at a fictional community bank in Columbus, Ohio that approves SBA loans under its own authority. Every company, person, number and document in the screens is sample data.
14 · One application, start to finish
Brassmoor Mechanical: three owners declared, nine found, an affiliate on a 1065
In shortThis is the example from the top of the page, inside the product. Six agents read the 41 documents and grow the applicant's ownership tree from them: a missing 10% owner, the people behind the holding company, an affiliate found in a partnership return, a federal housing claim on a guarantor. Alicia Moreno, the senior SBA underwriter, sends one request to the borrower, the agents re-test what comes back, and three people sign.
1
What the application says: three owners and 90%
Alicia opens the next file on its ownership tree, set to "As filed". Brassmoor Mechanical sits at the top, with Dana Whitfield at 40%, Ridgeway Trades Holdings at 35% and Tomas Valek at 15% below it, and a dashed box for the rest: "10% not accounted for · The application adds to 90%".
Each box carries five small dots, one per test: size, citizenship and residence, CAIVRS, criminal history, federal debt. Gray means not yet run.
As filed. The three owners on the application, and the 10% nobody listed.
2
Traced from the documents: nine owners, 100%
She clicks "Trace from the documents" and the tree grows, each step logged on the right with the agent, the time and the source page. Amendment No. 2, section 3.1, admits Keystone Field Partners with 10%, marked "not on the application". The holding company's schedule adds Marcus Ridgeway at 21.0% and Elena Ridgeway at 14.0%. Keystone's agreement adds its three members at 4%, 3% and 3%. The strip under the tree reads "7 people add to 100.0%".
Then a new box appears under the holding company: Tallbrook Plumbing & Drain, Inc., with the callout "Affiliate found in Ridgeway Holdings’ 2025 partnership return" and the line "Combined receipts $21.18M — over the $19.0M size standard for NAICS 238220".
Traced from the documents. Every owner, direct and indirect, the related businesses below them, and each finding in the rail with its page.
3
The return, opened at the line that made the affiliate
Alicia clicks the callout. The holding company's 2025 Form 1065, Schedule B opens at the question where a partnership lists the corporations it owns: "Tallbrook Plumbing & Drain, Inc. · US · 70%". Below it, the partnership interests list Ridgeway Rentals at 100% and Brassmoor at 35%. The sample return on screen labels the corporations 3b. On the IRS form, corporations are question 3a and partnerships 3b.25
The page is document 19 of 41 in the package. The application form never asks what the owners own; the holding company's own tax filing answers that.
The partnership return. Schedule B, the corporations it owns, with the 70% holding highlighted and the rule it triggers.
4
Over the industry standard, small under the alternative
The size page sets out each related business and why it is or is not an affiliate: Tallbrook Plumbing & Drain counted; Ridgeway Rentals in a different subsector; Whitfield Excavating held at 30%; Keystone with no other holdings. Five years of receipts for Brassmoor and the affiliate average $21.18 million against the $19.0 million standard.
So the alternative standard runs: tangible net worth $6.65 million against $20 million, two-year average net income $1.89 million against $6.5 million. Small. The affiliate's $420,000 SBA loan brings SBA's guaranty across the group to about $3.2 million of the $3.75 million cap. The screen also tests the group's gross SBA loans, $4,270,000, against $5,000,000, a limit this bank sets for itself. SBA's limit across a group is the $3,750,000 guaranty.18
Size and affiliation. Each related business tested, five years of receipts, the alternative standard and the group's SBA loans.
5
Three items cleared, three signatures
The checklist found three items to clear: a corrected ownership schedule with Keystone and certifications from it and its members; HUD's clearance and a corrected borrower information form for Marcus Ridgeway; Elena Ridgeway's certification. Alicia sends one request to Dana Whitfield, with the business development officer copied. The screen asks every owner to certify, as this bank's settings require. SBA requires two certifications: the applicant's and the lender's.5
On Wednesday, October 14, Dana uploads the documents, including HUD's letter of October 13. The agents re-read them and re-test: 22 of 22. Alicia signs the eligibility determination, Margaret Ellery takes the second look on the cleared CAIVRS hit, and Dennis Chae certifies 100% of ownership in SBA's system. The file goes to credit underwriting.
Cleared and signed. Each item with the document that cleared it, the re-test, and the three sign-offs in order.
The solution's design target is a signed eligibility checklist within one business day of a complete package. It is a target, to be measured on your own applications. On the sample file, the agents' first run took 71 seconds.
15 · Every screen
The ownership tree through each test, the 22-line checklist, the queue and the settings
In shortOne application is the story. These screens show the rest: the tree seen through one test at a time, one owner's tests and documents, the 22-line checklist, the agents' run and the findings, the request to the borrower, every application in screening, the signature, and the settings where your department's choices live.
One test across the tree. The CAIVRS lens fades everyone it does not cover and shows the HUD claim on the node it belongs to.
Citizenship and residence. Who has certified and where they live; the five without a certification in amber.
One owner's tests. Holdings, share, role, residence, and each test with its source, including the "No" on the federal debt question.
What the signature means. The determination states its evidence and its meaning before the underwriter signs.
The eligibility checklist. Twenty-two tests in five groups, each with its result, the rule and the source; three marked to clear.
The run and the findings. What each agent read and found, and four findings with the pages behind them.
Items to clear and the request. Who supplies each item and why; the request is drafted and goes only when the underwriter sends it.
Every application in screening. Owners listed against owners found, size, records and items to clear, for eleven files and $22.45 million requested.
All clear. After the re-test every owner is green, and the rail records the request, the upload and the signatures.
Your department's settings. Who certifies, who is screened, the size test order and the sign-offs, each versioned on the audit trail.
Select any screen to open it larger. The bank, applicants, people and figures are fictional. The screens call SBA's loan system E-Tran, its older name, and cite SOP 50 10 8; the rules they apply here carry over unchanged into SOP 50 10 8.1. Two checks are the example bank's own settings. The screens ask every owner for a citizenship certification; SBA requires the applicant's and the lender's.5 They test the group's gross SBA loans against $5,000,000; SBA's limit across a group is the $3,750,000 guaranty.18
16 · Agents, and who signs
Agents trace owners and test size; the underwriter signs and the processor certifies to SBA
In shortEach agent has one job and limits it does not cross. None of them signs a determination, certifies in SBA's system, clears a hit or waives a rule. The SBA underwriter decides and signs; the compliance officer takes a second look at any cleared government-record hit; the processor certifies ownership only after both.
Six agents, from entity document reader to eligibility memo writer
Entity document reader
Reads articles, operating agreements and every amendment, the owner companies' own agreements and the K-1s, and traces ownership to 100%, direct and indirect, until every branch ends in a person. Reports each owner the application leaves out, with the document and page.
Never adds an owner without a document, and never assumes a percentage.
Ownership and citizenship verifier
Checks every person's citizenship and residence certification, ID, principal residence and the answers on the borrower forms, and reports anyone without a certification or with an answer that conflicts with another document.
Never decides citizenship from a name or an address; it asks.
Government records checker
Runs CAIVRS for the business, guarantors and associates, OFAC and SAM.gov exclusions for the people each one covers, and looks for prior SBA losses in the group; re-screens before closing.
Never clears a hit without the agency's own document.
Affiliation and size tester
Finds every business an owner holds in the owners' own filings, applies the ownership tests of 13 CFR 121.301 to each, runs the industry and alternative size standards and adds up the group's SBA loans.
Never changes the NAICS code on the application without flagging it, and always says why a business is or is not an affiliate.
Program rules checker
Tests the excluded business types, use of proceeds, owner occupancy, credit elsewhere, franchise listing and loan limits.
Never waives a rule.
Eligibility memo writer
Writes the checklist one line per test with its result, rule and document, the items that would clear each failed test, and the request to the borrower in plain words.
Never signs, never certifies, and never sends a request without the underwriter.
The underwriter signs eligibility; compliance reviews every cleared hit
Decides and signsSBA underwriterReviews the tree and the checklist, decides the items that need judgment, sends the request, and signs: "I have reviewed the documents and find the applicant eligible under SOP 50 10 8 and Procedural Notice 5000-876626."
Second lookSBA compliance officerReviews every cleared CAIVRS, OFAC, SAM.gov or borrower-form issue with the agency's document attached, before the file moves on.
Certifies to SBASBA loan processorCertifies 100% of direct and indirect ownership in SBA's loan system only after both signatures.
Every agent step, request, upload, re-test and signature is on the file's activity with who and when. Settings changes are versioned. The rule library carries each rule with its effective date, so a file is tested against the rules in force on its date; a proposed rule is watched and never applied.
Alicia Moreno's six to eight applications a week and her SBA team
Fictional, from the sample data
AM
Alicia Moreno · senior SBA underwriter
Screens six to eight new 7(a) and 504 applications a week before credit work starts.
"I spend a day finding the owners and ten minutes deciding whether they're eligible."
RK
Rob Kessler · SBA lending manager
Owns the bank's delegated authority, purchase outcomes and SBA's review findings.
"If SBA finds an owner we missed at purchase, the guaranty is gone."
DC
Dennis Chae · SBA loan processor
Enters ownership and certifies it to SBA.
"I can only certify what someone has proven to me."
ME
Margaret Ellery · SBA compliance officer
Takes the second look on every cleared government-record issue.
"A cleared hit needs the agency's letter in the file."
CH
Chris Halloran · business development officer
Brought in the Brassmoor deal and speaks to the borrower.
"Tell me exactly what to ask Dana for, once."
17 · What goes in and out
Application packages in, a traced ownership tree and a cited, signed checklist out
In shortThe solution reads the documents applicants already send, applies the department's own settings on top of SBA's rules, and leaves behind an ownership tree traced to 100%, every related business tested, a 22-line checklist with a rule and page on each line, a request to the borrower, and three sign-offs. Your loan origination system and SBA's loan system stay where they are.
From the applicant
The application, borrower information forms and the citizenship certification
Articles, operating agreements and every amendment
Owner companies' agreements and schedules; trust documents
Business returns and K-1s, the affiliates' returns
Personal financial statements (Form 413)
From the bank and the government
Your checklist choices and sign-off rules
CAIVRS, SAM.gov exclusions and OFAC results
SBA's size table and the SOP in force
Existing SBA loans of the group
Agents trace, search and testEvery owner, every related business, every rule, under your department's settings
The underwriter signs
Every finding cites its page
Outputs
The ownership tree, direct and indirect, traced to 100%
Each related business with its affiliation verdict and reason
The size test, both standards, and the group's SBA limits
The eligibility checklist, a rule and page on every line
Items to clear and the request to the borrower
The signed determination, second look and certification record
What changes for the desk
Underwriters start from a traced tree
One request to the borrower, complete
A file a purchase reviewer can follow years later
Origination, CAIVRS, SAM.gov, OFAC and the SBA loan system
Loan origination systemThe application, the credit memo, the decision
Borrower portal or secure uploadPackages in, requests out, documents back
SBA's loan systemOwnership and certifications, entered by your processor
Core bankingExisting loans and relationships
Identity and accessWho signs, who takes the second look
Email or ticketingRequests and notices
For each, check whether it has an interface, a file feed, or only screens, and who owns it.
Your SBA checklist, processors and compliance review, as settings
Your checklist
Becomes settings: who certifies, who completes the borrower form, who CAIVRS screens, the size test order, the second look. Versioned, with every change on the audit trail.
Your origination system
Stays the system of record. The signed determination and the checklist go into the file through your normal process.
Your processors
Keep certifying to SBA, from a checklist where each owner is traced to a page.
Your compliance team
Sees every cleared hit with the agency's document before the file moves on.
Your older loans
Can be re-screened against the rules in force when each was approved, starting with the 2023–2024 loans SBA has flagged.
Your borrowers
Get one request listing exactly what is missing and why, with the forms attached.
Every owner from a document, every hit cleared, people sign
1
Every owner from a document
No owner added, and no percentage assumed, without the page that shows it.
2
Every hit cleared by the agency
A CAIVRS, OFAC or SAM.gov hit stands until the agency's document is in the file and a second person has looked.
3
Agents test; people sign
The underwriter decides and signs, the compliance officer reviews, the processor certifies.
Part C · Are you ready to automate?
Automating SBA eligibility screening: what it costs you today, what it could return, and how to test it
You screen SBA applications, or run the department that does, or answer for the guaranties when loans go bad. This part is written for you: what missed owners and slow screens cost, what automating the reading could return, whether your desk is ready, and what to ask any vendor, including us.
18 · What a missed test costs
What an eligibility gap costs you: underwriter days now, a denied guaranty later
In shortTwo costs, years apart. The first is time: underwriter and processor days spent finding owners and affiliates before any credit work starts. The second is the guaranty: on a defaulted loan, a gap in the eligibility file can cost all of SBA's share. Nobody publishes how often that happens, so the numbers that decide your case are your own.
$425K
was SBA's average guaranteed amount on a fiscal 2026 7(a) loan: the money at stake on a typical file if a purchase review finds the loan ineligible.35
SBA 7(a) loan data, FY2026 · our count
4.1%
of the 7(a) loans approved in fiscal 2022 had been charged off by September 30, 2026. These are the files SBA reads before it pays.35
SBA 7(a) loan data · our count
5 of 8
early-defaulted loans the inspector general reviewed in 2019, after SBA had paid on them, had material deficiencies that warranted full recovery from the lenders, about $8.7 million, size standards among them.31
SBA OIG Report 19-22, 2019
Most of a hand-built screen is reading, which is the part software can take
Working hours on one application with a holding-company owner
By hand (estimate)With automation (estimate)
Finding every owner8 hours0.8 hours
Affiliates and size8 hours1.6 hours
Certifications and forms4 hours0.8 hours
CAIVRS, OFAC, SAM.gov4 hours0.8 hours
Checklist and borrower request4 hours1.6 hours
Decision and signature2 hours2 hours
Illustrative · replace with your own numbers · Neither column is a measurement; both are estimates. The solution's design target is a signed checklist within one business day of a complete package. Time five of your own files by step and measure the rest in a pilot. The decision itself does not get shorter.
Show the numbers
By hand (estimate)
With automation (estimate)
Finding every owner
8 hours
0.8 hours
Affiliates and size
8 hours
1.6 hours
Certifications and forms
4 hours
0.8 hours
CAIVRS, OFAC, SAM.gov
4 hours
0.8 hours
Checklist and borrower request
4 hours
1.6 hours
Decision and signature
2 hours
2 hours
What nobody publishes. There is no public figure for hours per eligibility review, the share of applications with an owner left off the form, the share of files whose affiliation analysis lacks the returns, or how often eligibility alone decides a purchase denial across all lenders. Vendor figures come without a dataset. Measure your own.
Timing five SBA files and re-tracing ownership on twenty
Time five files by step, with a stopwatch; pick ones with a company owner
Waiting days
Complete packages not yet screened; second and third requests to the borrower
Median days from complete package to signed determination, from your pipeline
Owners and affiliates missed
Files that look complete and are not
Re-trace ownership on 20 recent files from the documents; count owners found against owners listed
Guaranties at risk
Defaulted loans, and 2023–2024 loans SBA has flagged for review at purchase
List your loans in the flagged period and your purchase requests of the last three years; note any repair or denial and its reason
Review findings
SBA lender review comments on eligibility and Form 1919
Your last two SBA review reports
Rule upkeep
Rewriting the checklist after each notice
Hours spent updating procedures since June 2025, and who did it
Delegated authority at risk and checklists built on an old SOP
Delegated authoritySBA may suspend or revoke a lender's delegated authority as an enforcement action for breaking program rules, which would slow every future SBA loan.45
The borrower who waitedA week of screening before credit work starts is a week for another lender to answer.
The second requestAsking the borrower three times for papers you could have listed once costs goodwill.
Rule changes nobody caughtA checklist built on an earlier SOP passes files the current rule would fail.
Your best underwriter's weekSpent multiplying percentages instead of reading cash flow.
19 · Your return
Underwriter hours and guaranty dollars: what automated eligibility screening could return
In shortPut in your own numbers. The calculator counts two things: underwriter time released on every application, and guaranty money protected on the few loans that default. Only the average guaranty comes from published data; every input marked illustrative is an assumption to replace.
Underwriter hours, guaranties kept at purchase, credit work sooner
Underwriter time
Start from a traced tree
Owners, affiliates and searches arrive done, each with its page; the underwriter works the items that need judgment.
applications × hours saved × loaded hourly cost
Guaranty
Fewer files that fail at purchase
Every owner traced and every affiliate's return in the file before the loan number.
purchase requests × share with a gap × average guaranty × share caught
Speed
Credit work starts sooner
One complete request to the borrower instead of three.
days from complete package to signed determination, before and after
Rules
The current rule, every time
Each file tested against the version in force on its date, with the change recorded.
hours of checklist upkeep a year × hourly cost
Reviews
Evidence ready for SBA
Each finding with its rule and page for lender reviews and purchase packages.
hours assembling support for reviews and purchases
Old files
Re-screen the flagged years
The same tests run on 2023–2024 loans, against the rules in force when each was approved.
flagged loans re-screened × hours saved per file
Your underwriter hours and guaranty dollars from traced eligibility
The average guaranty is SBA's fiscal 2026 figure from its public loan data, about $425,000.35 Every input marked illustrative is an assumption; replace it with yours.
Your volume and timeYour guaranty exposureYour cost
Illustrative yearly value
Screening time today, valued$0
Staff time released, valued$0
Guaranty protected, expected$0
After your yearly cost$0
Staff hours released a year0
Applications a year to cover your cost on time alone0
Formulas, per year: Screening time today = applications × hours today × hourly cost Time released = applications × (hours today − hours with automation) × hourly cost Guaranty protected = purchase requests × share with a gap × average guaranty × share caught After your cost = time released + guaranty protected − yearly cost Break-even applications = yearly cost ÷ (hours saved × hourly cost)
The 30-hour default is the estimate charted above for an application with a company owner. The 8-hour default is illustrative: one working day, the length of the solution's design target for a signed checklist. Use fewer hours for a business with one owner. Not counted: faster answers to borrowers, rule upkeep, review findings and delegated authority. Released hours become value once you decide what they are for.
The hours saved per application decide how many files cover the cost
Applications a year to cover $60,000 of yearly cost at $75 an hour, on time savings alone
Saves 22 hours an application36 applications
Saves 8 hours an application100 applications
Saves 4 hours an application200 applications
Illustrative · replace with your own numbers
Show the numbers
Hours saved
Applications a year
Saves 22 hours an application
36 applications
Saves 8 hours an application
100 applications
Saves 4 hours an application
200 applications
A lender screening 120 applications a year clears the first two lines. One making five SBA loans a year does not clear any of them on time alone, and should weigh the guaranty and rule-upkeep levers, or a lender service provider, before buying software.
Start here20 · Readiness check
How ready your desk is to hand ownership tracing and list checks to software: a nine-question score
In shortPick the answer closest to your desk 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
Volume
How many SBA 7(a) and 504 applications does your desk screen a year?
Why it mattersVolume turns hours per file into staff capacity. More than half of SBA's 7(a) lenders made five loans or fewer in fiscal 2026.35
A strong answer"About 150, a third of them with a company owner."
2
Shape of your applicants
How often do your applicants have company owners, layered ownership or owners with other businesses?
Why it mattersLayers are where owners and affiliates go missing and where the reading time goes. A desk of sole proprietors gains less.
A strong answer"Often: holding companies, family trusts, partners who own other shops."
3
Your baseline
Do you know your hours per file, your days from complete package to signed determination, and how many owners your files miss?
Why it mattersNo public benchmark exists for any of them, so your own baseline is the only way to show an improvement.
A strong answer"About two days a file, four days elapsed, and two missed owners in last year's review sample."
4
Your checklist
Is your eligibility checklist rebuilt on SOP 50 10 8.1, with the March 2026 citizenship rule and the trust guaranty rule?
Why it mattersSoftware should apply your rules; a checklist built on an earlier SOP has to be settled first.1
A strong answer"Updated in October, owned by the SBA manager, with each rule's effective date."
5
Findings and exposure
Have SBA reviews or purchase decisions raised eligibility or Form 1919 issues, or do you hold loans in the flagged 2023–2024 period?
Why it mattersFindings and flagged loans bring deadlines and budget.6,33
A strong answer"Two review comments on affiliation and 140 loans in the flagged period."
6
Files and systems
Do application packages arrive electronically, in one place that software can reach?
Why it mattersScanned email attachments work but take longer to set up than a portal or document system with an interface.
A strong answer"Through our portal into the document system, with an interface the origination system uses."
7
Owner and budget
Is there a named owner of SBA eligibility with a budget to change how it is done?
Why it mattersEligibility crosses business development, processing, underwriting, compliance and IT. Without one owner it stalls.
A strong answer"Our SBA lending manager sponsors it, and the budget for a second processor can move."
8
Governance
Do you have a way to approve AI in credit work: vendor due diligence, a view on the April 2026 model risk guidance, named signers and an audit trail?
Why it mattersThe 2026 model guidance leaves generative AI to your own framework, and you remain responsible for vendors' work.40,42
A strong answer"Vendor management has a path for AI tools, and every determination needs a named signer and a second look on cleared hits."
9
Vision · for reflection
If SBA asked tomorrow for the eligibility file on a loan you approved in 2024, what would it take to show every owner, every affiliate test and every search result, each with its document?
Why it mattersYour answer lists the gaps. Each gap is a candidate job for software: tracing, searching, sizing or writing up.
A strong answerA short, specific list, for example: "the holding companies' agreements, the affiliates' returns, and the SAM.gov screenshots for officers."
Explore, re-screen 20 to 30 decided files, or screen every application
0–6
Explore
Measure first: time five files, re-trace ownership on twenty, and rebuild the checklist on SOP 50 10 8.1 with dates. Name an owner. Then start narrow, for example with ownership tracing on applications that have a company owner.
7–11
Ready to pilot
Re-screen 20 to 30 closed files your underwriters already decided, then run new applications in parallel for a few weeks. Compare owners found, affiliates found, findings that differ and staff minutes, and keep your people signing every determination.
12–16
Ready to implement
Plan the whole SBA desk: your checklist and thresholds as settings, sign-off and second-look rules, links to the portal, the document system and SBA's loan system, a re-screen of flagged loans, and the evidence a reviewer will ask for.
21 · Questions for any vendor
Questions for SBA eligibility screening software vendors: owners, affiliates, list hits and evidence
In shortAsk every vendor the same questions, us included. The answers show whether the tool reads documents or only asks the borrower, how it finds owners and affiliates, what evidence you keep, whose rules apply, and how you would test it on your own files.
Ask
A good answer
A warning sign
Ownership
How does it find owners the application leaves out?
Reads the operating agreement, every amendment and each company owner's own agreement, and shows the page
"The borrower lists the owners"
Does it multiply indirect shares and combine spouses and minor children?
Yes, with the arithmetic shown for each person
Indirect owners entered by hand
What does it do when the shares do not add to 100%?
Stops and names the missing documents
Lets the file continue
Affiliates and size
How does it find businesses the owners hold?
From the owners' own returns and agreements, each tested under the five ownership rules
A yes/no question to the borrower
Does it run both size standards and the group's SBA limits?
Industry and alternative standards, three- or five-year receipts, SBA's $3.75M guaranty limit across the group and the $5M loan maximum
The applicant's receipts alone
Does it say why a related business is not an affiliate?
The share, the subsector and the rule, per business
Only the affiliates are shown
People and lists
Which people does it run through CAIVRS, SAM.gov and OFAC?
The SOP's list for each check, built from the traced owners, officers and guarantors
Only the names on the application
How does it handle a hit?
Flags it, compares it with the owner's own answers, and waits for the agency's document and a second look
Clears name matches automatically
How does it decide citizenship and residence?
From certifications and documents only; asks when unsure
Infers from names or addresses
Rules
Which SOP version does it apply to a file, and how does it record that?
The version in force on the file's date, written on the file; rule changes dated and versioned
"Always the latest"
Who updates the rules when SBA issues a notice, and how fast?
A named owner, a stated turnaround, and your sign-off before a change applies
Silent updates
Can we set our own policy choices, such as who certifies and who takes a second look?
As settings, versioned, on the audit trail
A configuration project for each change
Evidence and sign-off
Does every line of the checklist carry its rule and its page?
Rule citation and document page, one click away, kept with the file
A pass/fail list
Who signs the determination and who certifies in SBA's system?
Your underwriter signs; your processor certifies after the signatures
The tool "approves" eligibility
What is kept for a purchase review years later?
The traced tree, every search result with its date, every request and every signature
A PDF summary only
Your data and proof
Which AI models do you use, where do they run, and does our data train them?
Named models, a region you choose, no training on your data, in writing
"Proprietary AI", no detail
Can we test it on our own closed files before we sign?
Yes, including files with owners and affiliates your team already found
Demo files only
What will you report from the test?
Owners and affiliates found against your team's, every difference with its cause, staff minutes
One accuracy percentage
We found no published independent test of any SBA eligibility tool, as of October 2026. A re-screen of your own closed files is the fairest comparison, and it measures your current process too.
22 · How to start
A ten-week eligibility pilot: re-trace 25 decided files, then screen new applications side by side
In shortSettle the rules, re-screen closed files your team already decided, run new applications in parallel, then decide on three numbers. None of these steps commits you to a vendor, and your underwriters sign every determination throughout.
Time five files by step, three with a company owner. That is your baseline.
Rebuild the checklist on SOP 50 10 8.1 and write down your own choices: who certifies, who takes a second look, which receipts average you use.
Pick 25 closed files your team decided, including some with holding companies, trusts or partners who own other businesses.
Run new applications in parallel for four weeks, comparing test by test.
Decide on three numbers: owners and affiliates found against your team's, differences explained, staff minutes per file.
A ten-week pilot ends with a decision on three numbers
Your teamVendor
Time five files; pull review findings
Rebuild the checklist on SOP 50 10 8.1
Load your rules and settings
Re-screen 25 closed files
Compare with your team's decisions
Parallel run on new applications
Score and decide
Week 0246810
Illustrative · replace with your own numbers
Show the numbers
Activity
From
To
Time five files; pull review findings
0
2
Rebuild the checklist on SOP 50 10 8.1
0
2
Load your rules and settings
1
3
Re-screen 25 closed files
2
4
Compare with your team's decisions
3
5
Parallel run on new applications
5
9
Score and decide
9
10
Owners found, affiliates found and differences explained
Measure
How
Why
Owners found
People and companies found ÷ those your team found, per file, and any extra ones with their page
The 100% rule is the foundation of every other test
Affiliates found
Related businesses found and tested, with the reason for each verdict
Affiliation was the commonest unsupported warning in SBA's own screen6
Differences explained
Every test where tool and team disagree, with a written cause
An unexplained difference is a risk either way
False alarms
Items raised that your team rightly cleared, in minutes spent
A tool that flags everything wastes the time it saves
Staff minutes and days
Stopwatch per file; days from complete package to signature
The cost case rests on them
The full working-session questions: 18 questions in six groups
Bring business development, processing, underwriting, compliance, the SBA lending manager and IT into one room. Each question says why it matters and what a strong answer and a warning sign look like.
A
SBA applications by program, ownership shape and 2023–2024 vintage
A1
How many applications do we screen a year, by program and by ownership shape?
Why it mattersLayered ownership is where the hours are.
Strong answer · warning sign
Counts by shape.
One number, nobody sure of the mix.
A2
How many of our loans fall in the flagged 2023–2024 period?
Why it mattersSBA will flag them for review at purchase and seek recovery where it finds the lender knew of an ineligibility.6
Strong answer · warning sign
A list, with balances.
"SBA screened those."
A3
Who signs, who takes a second look, and who certifies?
Why it mattersSign-offs become settings.
Strong answer · warning sign
Written roles.
"Whoever is in."
B
Your checklist's SOP version, citizenship certifications and receipts average
B1
When did we last rebuild our checklist, and on which SOP?
Why it mattersNine notices took effect between September 2025 and July 2026.7
Strong answer · warning sign
October 2026, on 8.1.
Before March 2026.
B2
Do we ask every owner to certify citizenship, or rely on the applicant's certification?
Why it mattersThe SOP asks the applicant; many lenders ask more.5
Strong answer · warning sign
A written choice.
It varies by underwriter.
B3
Which receipts average do we use, and do we test both?
Why it mattersBusiness loan applicants may choose three or five years.26
Strong answer · warning sign
Both tested, the choice recorded.
"Five years, always."
C
SBA review findings, re-traced files and eligibility repairs
C1
What did SBA's last reviews say about our eligibility files and Form 1919?
Why it mattersFindings show where the process breaks.
Strong answer · warning sign
A list by type.
Nobody tracks them.
C2
Re-trace ownership on five recent files: does anything change?
Why it mattersThe cheapest way to size the problem.
Strong answer · warning sign
Done, differences explained.
"Our files are fine."
C3
Have we had a repair or denial on eligibility grounds?
Why it mattersIt prices the guaranty lever.
Strong answer · warning sign
Known, with reasons.
Unknown.
D
Affiliates' returns at intake and where list results live
D1
Do we ask for company owners' agreements and affiliates' returns at intake?
Why it mattersA tool can only read what arrives.
Strong answer · warning sign
On the intake list.
Only when someone thinks of it.
D2
Where do CAIVRS, SAM.gov and OFAC results live today?
"All of it": then start with tracing and searches.
23 · Frequently asked questions
Green card holders, affiliates, CAIVRS hits and Form 1919: SBA eligibility answers
In shortThe questions SBA lenders and borrowers search for most, each answered on its own.
What is SBA eligibility screening?
SBA eligibility screening is the lender's check, before credit underwriting, that an applicant for an SBA 7(a) or 504 loan meets SBA's program rules. It covers the business (for-profit, in the U.S., small with its affiliates, an eligible type), every direct and indirect owner (citizenship, residence, federal debts and losses, exclusions, sanctions, criminal matters) and the loan (use of proceeds, credit elsewhere, limits). The lender documents each test and signs the determination.
Who determines SBA loan eligibility in 2026?
The lender does, on every loan approved under its own delegated authority. SOP 50 10 8 returned the determination to lenders on June 1, 2025, after SBA had run it itself from August 2023, and SOP 50 10 8.1 keeps that rule from October 1, 2026. SBA decides eligibility only on applications sent to it for a decision: about 2,100 of fiscal 2026's 56,130 7(a) loans were standard loans SBA processed itself.
What are the SBA 7(a) eligibility requirements?
The business must be an operating, for-profit business located in the U.S., small under its industry size standard or the alternative standard with all affiliates counted, and not one of the excluded types in 13 CFR 120.110. All direct and indirect owners and required guarantors must be U.S. citizens or nationals living in the U.S., with no prior federal loss, past-due federal debt, exclusion or sanction. The lender must also show credit is unavailable elsewhere on reasonable terms and that the use of proceeds and loan size are within the rules.
Can a green card holder own part of a business that gets an SBA loan?
No, for any 7(a) or 504 loan approved since March 1, 2026 (for a loan a lender approves itself, the date the SBA loan number is issued). SBA's rule requires 100% of direct and indirect owners to be U.S. citizens or U.S. nationals with their principal residence in the U.S., and lists lawful permanent residents as ineligible persons at any percentage. A green card holder may still give a limited or supplemental guaranty that the lender asks for, and loans approved earlier keep the rules in force when they were approved.
What is the SBA six-month look-back rule?
An applicant is ineligible if any direct or indirect owner during the six months before the SBA loan number is issued was an ineligible person, unless that person completely divested before the loan number. A separate six-month look-back keeps a guaranty requirement on anyone who held 20% or more six months before the application and then reduced the share, unless they divested completely and cut all ties with the business.
How does SBA affiliation work for 7(a) loans?
Since May 11, 2023, affiliation for SBA loans is based on ownership only. Businesses are affiliated when one owns more than 50% of the other, when a majority owner of the applicant also owns more than 50% of another business in the same 3-digit NAICS subsector, or, when nobody owns a majority, when a 20% owner is a business in that subsector or owns more than 50% of a business in it. Affiliates' receipts, net worth and SBA loans are added to the applicant's.
What is the SBA alternative size standard?
An applicant that is too big under its industry size standard can still qualify if, with its affiliates, its tangible net worth is no more than $20 million and its average net income after federal income taxes, excluding carry-over losses, for the two full fiscal years before the application is no more than $6.5 million. These limits took effect March 18, 2024 and apply to 7(a) and 504 loans.
Do affiliates' SBA loans count toward the loan limit?
Yes. SBA's loan maximums apply to the applicant and all its affiliates as if they were one business. The limit that adds up the group is SBA's guaranty: it may not exceed $3,750,000 for a business and its affiliates, counting existing 7(a) and 504 loans. Any one standard 7(a) loan may be up to $5,000,000.
What is CAIVRS and who must be checked for an SBA loan?
CAIVRS is the Credit Alert Verification Reporting System, a shared federal database run by HUD of people and businesses with past-due federal debt or federal loan losses. SBA lenders must search it, by Social Security number or EIN, for the applicant, every guarantor and every Associate, which includes officers, directors, owners of more than 20% and key employees, and keep the result in the loan file.
Who must be searched in SAM.gov for an SBA loan?
The applicant business, owners of 20% or more, officers, directors and managing members, key employees, a living trustor when a trust owns the business, any company owning 20% or more, and both companies in a property-holding structure. The lender keeps evidence of each search, such as a screenshot, and also searches its own SBA staff, loan agents and service providers once before they start work.
What changed in SOP 50 10 8.1?
SOP 50 10 8.1 took effect October 1, 2026. It folds in nine policy and procedural notices that took effect between September 2025 and July 2026, including the March 2026 citizenship rule and a June 2026 waiver of the prior-loss rule for small non-controlling owners. Its technical update tightened the trust rule: trusts are counted together toward 20%, the trustor guarantees whether the trust is revocable or not, and donors to the trust count as trustors for eligibility.
What happens if SBA finds a loan was ineligible at guaranty purchase?
SBA can deny its guaranty in full or in part, and can recover money it already paid, if the lender failed to comply materially with a program requirement. SBA's servicing rules give a delegated lender making an ineligible loan as the first example of a full denial. The loan is judged against the SOP in force when it was approved.
Do all owners have to be listed in E-Tran?
Yes. The lender must enter 100% of the applicant's direct and indirect owners, people and companies, in SBA's loan system, which SOP 50 10 8.1 now calls the SBA Loan System. The listed percentages must add to 100%, spouses' and minor children's shares are combined, and the lender certifies that none of the owners or required guarantors is an ineligible person.
Who has to guarantee an SBA loan?
Every individual and every company that owns 20% or more of the applicant, directly or indirectly, must give an unlimited full guaranty. Spouses who each own less than 20% must guarantee when spouses and minor children together own 20% or more. A trust owning 20% or more guarantees too, and since October 1, 2026 trusts are counted together, their trustors guarantee whatever the trust type, and donors count as trustors. The lender may require others as well.
Can software determine SBA eligibility?
Software can read the agreements and returns, trace owners to 100%, find affiliates, add up receipts, run the list searches and write each finding with its rule and page. The determination stays with the lender's named signer, as do clearing a database hit, judging criminal history and explaining why credit is unavailable elsewhere. SBA's own automated screen of 2023–2025 left size and for-profit status untested because the data sat in documents.
24 · One-page summary
SBA eligibility on one page: owners to 100%, affiliates sized, lists cleared, signed
Print this page
In shortThe whole guide on one screen: the method, the rules as of October 2026, the readiness bands and the terms.
The method
Trace ownership to 100% from the agreements and every amendment; multiply indirect shares; combine spouses and minor children.
Certify every person: citizenship, principal residence, the applicant's certification; ask, never infer.
Search CAIVRS, SAM.gov and OFAC on the right people for each; clear hits only with the agency's document.
Find every business the owners hold; apply the five ownership tests; size the group both ways; check SBA's $3.75M guaranty limit across the group and the $5M loan maximum.
Test business type, use of proceeds, occupancy and credit elsewhere; read management agreements.
Write each finding with its rule and page; request missing items once; sign; second look; certify.
Readiness: score 0–2 on eight questions: 0–6 explore · 7–11 pilot · 12–16 implement.
As of October 2026: SOP 50 10 8.1 in force from October 1, 2026 · citizens and nationals only since March 1, 2026 · alternative size standard $20M / $6.5M since March 18, 2024 · new size standards proposed, comments to November 20, 2026 · 73,302 loans flagged for review at purchase · OCC Bulletin 2026-13, SR 26-2 and FDIC FIL-15-2026 replaced SR 11-7 on April 17, 2026.
14 terms
7(a)
SBA's main guaranteed loan program, up to $5 million a loan.
Delegated authority
A lender's power to approve SBA loans itself (PLP, SBA Express).
PLP
Preferred Lenders Program; 61% of fiscal 2026 7(a) loans.
SOP 50 10 8.1
SBA's rulebook for 7(a) and 504 lenders, since October 1, 2026.
Indirect owner
Owns part of the applicant through another company; shares multiply.
Affiliate
A business whose size and SBA loans are added to the applicant's.
NAICS subsector
The first three digits of an industry code; 238 is specialty trade contractors.
Alternative size standard
Net worth to $20M and average net income to $6.5M, with affiliates.
Ineligible person
May own no share: green card and visa holders, anyone living abroad, foreign companies, others.
Associate
Officer, director, owner of more than 20%, key employee.
CAIVRS
HUD's database of past-due federal debt and federal loan losses.
SAM.gov exclusions
GSA's list of people and firms barred from federal business.
Form 1919
SBA's borrower information form; a revision with citizenship fields is pending.
Denial of liability
SBA refusing to pay all or part of its guaranty.
25 · Sources
Sources
Accessed October 2026. Regulatory status statements are as of October 2026.
SBA, SOP 50 10 8.1, Lender and Development Company Loan Programs, with Technical Policy Updates, published September 25, 2026, effective October 1, 2026. legacy.sba.gov
SBA, Information Notice 5000-866746, Issuance of SOP 50 10 8, effective April 21, 2025 (SOP 50 10 8 effective June 1, 2025). legacy.sba.gov
13 CFR 120.524, when SBA is released from liability on its guarantee (Legal Information Institute text). law.cornell.edu
SBA, SOP 50 57 4, 7(a) Loan Servicing and Liquidation, effective November 1, 2025. legacy.sba.gov
SBA, Procedural Notice 5000-876626, Revised Applicant Ownership Citizenship and Residency Requirements for 7(a) and 504 Loans, published February 11, 2026, effective March 1, 2026. legacy.sba.gov
SBA OIG, Report 26-07, SBA's Screening of 7(a) Loan Applications Under its Risk Mitigation Framework, March 11, 2026. oversight.gov
SBA, Information Notice 5000-880695, Issuance of SOP 50 10 8.1, published August 14, 2026. legacy.sba.gov
13 CFR 120.101, Credit not available elsewhere, Code of Federal Regulations, revised as of January 1, 2026 (GovInfo). govinfo.gov
SBA, Policy Notice 5000-865754, Policy updates to comply with Executive Order 14159 regarding citizenship requirements for obtaining 7(a) and 504 loans, effective March 7, 2025. legacy.sba.gov
SBA, Procedural Notice 5000-872050, Update to SOP 50 10 8 – Citizenship and Residency Requirements, effective December 19, 2025, for applications approved from January 1, 2026 (rescinded March 1, 2026). legacy.sba.gov
SBA, Policy Notice 5000-876441, Update to SOP 50 10 8 – Citizenship and Residency Requirements and Rescission of Procedural Notice 5000-872050, published February 2, 2026, effective March 1, 2026. legacy.sba.gov
SBA, Information Notice 5000-882227, Issuance of Technical Updates to SOP 50 10 8.1, published September 25, 2026. legacy.sba.gov
SBA, Small Business Size Standards (proposed), 91 FR 53741, August 20, 2026; comment period extended to November 20, 2026, 91 FR 60524. federalregister.gov
SBA, Adjustment of Alternative Size Standard for 7(a) and CDC/504 for Inflation, 89 FR 11703, February 15, 2024, effective March 18, 2024. federalregister.gov
13 CFR 121.201, What size standards has SBA identified by NAICS codes?, Code of Federal Regulations, revised as of January 1, 2026 (GovInfo). govinfo.gov
SBA, Table of Small Business Size Standards, effective March 17, 2023. sba.gov
13 CFR 120.110, What businesses are ineligible for SBA business loans? (Legal Information Institute text). law.cornell.edu
13 CFR 120.151, statutory limit for total loans to a borrower (Legal Information Institute text). law.cornell.edu
SBA, Data Collection Available for Public Comments (Form 1919), 91 FR 8567, February 23, 2026. federalregister.gov
SBA, Information Notice 5000-877673, Guidance for Frequently Asked Questions Related to Recent SBA Procedural Notices, published March 31, 2026. legacy.sba.gov
31 CFR 1010.230, Beneficial ownership requirements for legal entity customers, Code of Federal Regulations, revised as of July 1, 2025 (GovInfo). govinfo.gov
FinCEN, Beneficial Ownership Information Reporting Requirement Revision, 91 FR 52508, August 14, 2026. federalregister.gov
SBA, 7(a) and 504 FOIA loan data, FY2020–present, as of September 30, 2026. data.sba.gov
CFPB, Small Business Lending Under the Equal Credit Opportunity Act (Regulation B), 91 FR 23530, May 1, 2026; Equal Credit Opportunity Act (Regulation B), 91 FR 21620, April 22, 2026. federalregister.gov
J. Reosti, "SBA starts new fiscal year with even tighter credit box", American Banker, October 9, 2026. americanbanker.com
SBA, News Release 25-83, September 30, 2025. legacy.sba.gov
OCC Bulletin 2026-13, Model Risk Management: Revised Guidance, April 17, 2026. occ.gov
Federal Reserve, SR 26-2, Revised Guidance on Model Risk Management, April 17, 2026, and attachment. federalreserve.gov
FDIC, FIL-15-2026, Agencies Revise Interagency Model Risk Management Guidance, April 17, 2026. fdic.gov
Interagency Guidance on Third-Party Relationships: Risk Management, 88 FR 37920, June 9, 2023; proposed replacement, Proposed Third-Party Risk Management Guidance, 91 FR 58536, September 15, 2026, comments due November 16, 2026. federalregister.govfederalregister.gov (2026 proposal)
Colorado General Assembly, SB26-189, Automated Decision-Making Technology, signed May 14, 2026. leg.colorado.gov
SBA OIG, Management Advisory Report 26-15, SBA's Progress on Implementing Federal Artificial Intelligence Requirements, September 24, 2026. oversight.gov
13 CFR 120.1500, Types of formal enforcement actions—SBA Lenders, Code of Federal Regulations, revised as of January 1, 2026 (GovInfo). govinfo.gov
Next step
See it on your own SBA applications.
Explore the solution, or bring a sample of your own application packages, including some your team has already decided, and we will trace them with you, every owner and every finding linked to its page.
We use essential cookies to make this site work, and cookieless, anonymised analytics to understand how it's used. "Accept all" also turns on Google Analytics, which sets cookies. Privacy policy