SBA Rule Changes That Hit Buyers
Why It Matters
Guides written before a rule change keep circulating after it, confidently wrong, and the rules that moved lately are the ones a deal is built on: who may own the company, what a seller note counts for, and what the guaranty fee adds to cash at close. This log records each change the day it is verified against the SBA's own document.
The Log
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). Mid-2025 SBA rule changes are reported to require seller notes counting toward the equity injection to sit on full standby for the life of the loan, alongside tighter collateral requirements; guides written before mid-2025 can mislead on structure.
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 & Sources
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.