SBA issued a technical update to SOP 50 10 8.1 on September 25, 2026. Although many revisions are administrative, several will affect how lenders process their loan files. What follows is not a comprehensive review of every change. Rather, it is an overview some of the more significant clarifications in Section A and Appendix 15, the ones most likely to show up in your next eligibility review or guaranty purchase package.

1. Three Section A items deserve your attention:

• Trust guaranties narrowed. One or more trusts must give unlimited full guaranties only when they own at least 20% of the applicant in the aggregate. All Trusts and Trustors must provide unlimited guarantees when the 20% aggregate threshold is met.
• “May” became “must.” When a business segment is acquired, if transcripts or financial statements do not identify the acquired division or segment, the lender must use alternative third-party verification, such as CPA-prepared or reviewed statements or sales tax records.
• EV Charging stations are ineligible as are businesses structured as “stand-alone” businesses operated on a passive basis.

2. Changes of Ownership

Allowing changes of ownership of $350,000 or less to be processed under more relaxed  Small 7(a) and SBA  Express procedures, allowing internal business valuations, and a relaxed standard for the “fully secured” determination.  However, all other provisions of Appendix 15, including DSC requirements remain unchanged, even for smaller deals that are processed under Small 7(a) or SBA Express.

Appendix 15 contains the update’s most significant substantive changes to Change of Ownership Requirements.

• Working capital “true-ups” are permitted.
• Purchases by individuals who have been employed by the business for less than 24 months are considered to be “Initial Acquisitions.” Owner Buyouts that are required to be processed as Initial Acquisitions and are required to meet the credit, equity injection, and quality of earnings requirements of an Initial Acquisition, may still allow the seller to remain on as an owner and employee of the business.
• For fully collateralized loans to finance special purpose owner occupied properties, lenders may use projections to satisfy debt service coverage even if historical DSC falls below the applicable ratio, provided the requirement is met within two years after funding. This creates flexibility for special-purpose property acquisitions that do not qualify on trailing results, but otherwise fully secure the loan.
• Quality of earnings reports must be independent and cannot be prepared by or for the seller. For PLP loans, the business valuation and any required QoE must also be formally engaged, with a vendor retained and engagement letter in place, when the SBA Loan Number is issued.  A QoE prepared for a Borrower may be reviewed by the Lender’s approved vendor to mitigate transaction costs; however, reliance on a QoE prepared for the Borrower without independent review by Lender’s vendor is not permitted.
• De minimis excess use of proceeds may once again be disbursed to the borrower as working capital, provided such amounts do not exceed the greater of $10,000 or 0.5% of the loan amount.
• Fees paid to an Agent by the Borrower are not eligible to qualify as Equity Injection.

3. A Final Word

Before October 1, 2026, lenders should update their affected workflows and checklists. Most of these revisions are technical, but several materially affect lender responsibility, documentation, and file processing. Careful implementation now will reduce avoidable eligibility issues and difficult questions during a guaranty purchase review.

For more information on SBA eligibility and compliance issues, contact Ethan at 267-470-1186 or esmith@starfieldsmith.com.