SBA Rule Changes That Hit Buyers
The Log
Takes effect October 1, 2026
SOP 50 10 8.1 rewrites how a change of ownership is financed
The next edition moves every change-of-ownership rule into a new appendix and sorts deals into four kinds. The 10% equity injection holds for all of them, but only a business expansion or a buyout between existing owners can have it reduced or eliminated by the lender, and never an outright purchase by a new owner. A buyout's injection is measured against the purchase price rather than total project cost. The existing-owner test that let a long-standing co-owner reach full financing (24 months active at the same or higher stake, with debt-to-worth no worse than 9 to 1) is gone. And a Quality of Earnings report stops being a good idea and becomes a requirement on any outright purchase or expansion priced at $3 million or more, measured before any equity, seller debt, or other financing. One change runs the buyer's way: the seller may be kept on as a consultant for up to 24 months in aggregate rather than 12, so a longer handover stops being something the loan program forbids.
Who it hits: Every first-time buyer, because the injection on an outright purchase can no longer be argued down; existing co-owners buying a partner out, who lose the test that reached full financing; anyone pricing a deal near $3 million, where a quality-of-earnings engagement becomes part of the file rather than an optional check; and anyone buying a business whose owner is the business, who gets twice as long to keep them.
Effective March 1, 2026
Ownership restricted to US citizens and nationals
100% of direct and indirect ownership must be held by US citizens or US nationals with a principal US residence. Lawful permanent residents, eligible owners for decades, became ineligible persons; any ineligible co-investor at any percentage fails the whole application.
Who it hits: Every 7(a) and 504 applicant, and any deal with a non-citizen investor anywhere in the cap table, including funds with foreign limited partners.
Effective October 1, 2025
FY2026 guaranty fee schedule
Upfront guaranty fees returned across the loan-size tiers after fee holidays in prior years: 2% of the guaranteed portion at $150,000 or less, 3% to $700,000, and 3.5% plus 3.75% above that, with manufacturers exempt up to a $950,000 loan for the fiscal year.
Who it hits: Every 7(a) borrower's cash to close; the sources-and-uses line most first-time buyers forget to model.
Effective June 1, 2025
SOP 50 10 8 rewrites the deal-structure rules
The lending SOP's current edition changed how acquisition deals are built. A seller note counts toward the required equity injection only on full standby for the life of the loan, and only up to half the injection. Collateral requirements tightened, and the partner-buyout injection waiver was restated: 24 months active at the same or higher stake, with debt-to-worth no worse than 9 to 1.
Who it hits: Anyone structuring a deal from a guide, template, or forum thread written before mid-2025; the older seller-note structures no longer count.
Method & Source
Every entry is verified against the controlling SBA document before it appears, and the tools that depend on these rules read from the same records: the Eligibility Pre-Check carries the ownership rule, and the Sources & Uses table computes the fee schedule live. A change reported by coverage but not yet locatable in an SBA document is not listed.