Best Practices: Eligible Transaction Structures for Changes in Ownership
https://starfieldsmith.com/wp-content/uploads/2025/05/6b7d844c-a90e-4c3d-a2d6-2362e230e030.mp3 In recent weeks, my colleagues have been examining various components and modifications introduced by the newly enacted Standard Operating Procedure 50 10 8 (“SOP”). As we continue to further analyze the SOP, it is important to discuss the changes made to the rules concerning changes of ownership structures. This article aims to provide an ... Read More
Best Practices: What SBA Lenders Need to Know About the Return of the Credit Elsewhere Test in the SOP 50 10 8
https://starfieldsmith.com/wp-content/uploads/2025/05/3312a34f-39ab-4a81-b7aa-362a8086873b.mp3 Under the current SOP 50 10 7.1, lenders could essentially treat the Credit Elsewhere Test as a check-the-box exercise. That will no longer be the case starting June 1, 2025, when the SOP 50 10 8 becomes effective. The new SOP 50 10 8 reverts to prior practices of mandating a narrative within the ... Read More
Best Practices: Further Clarification on Citizenship Requirements for SBA Loans
https://starfieldsmith.com/wp-content/uploads/2025/05/7051d697-03c6-4fe9-b1e6-7d7362f383a4.mp3 In SOP 50 10 8, the SBA has updated its guidance on citizenship requirements for SBA loan eligibility, providing additional clarity for lenders navigating ownership and guarantor eligibility. These changes are critical for compliance, particularly when working with businesses that include non-citizen stakeholders. Six-Month Lookback for Ownership The SBA has clarified that an applicant ... Read More
Best Practices: A Review of Equity Injection Requirements Under SOP 50 10 8
https://starfieldsmith.com/wp-content/uploads/2025/05/d864319d-22e0-465b-af53-57600298c378.mp3 With the issuance of SOP 50 10 8, effective June 1, 2025, the SBA will be returning to well-established principles of equity injection. The SBA has eliminated the “do what you do” component to equity injection which was established in SOP 50 10 7.1. The Borrower once again will need to show that it ... Read More
Best Practices: Re-evaluating Policies and Procedures Regarding Site Visits
https://starfieldsmith.com/wp-content/uploads/2025/04/dddcd492-f03c-46f3-93c7-c0e6c61478d1.mp3 It is well established that the Small Business Administration (SBA) currently requires lenders to conduct a site visit when a loan is in default. However, lenders often have questions and obstacles related to how and when to obtain a site visit. Here, we will discuss best practices as well as options for lenders to ... Read More
Best Practices: SBA Issues SOP 50 10 8
https://starfieldsmith.com/wp-content/uploads/2025/04/4dea3489-0872-4318-9cfa-7aa38a5a64da.mp3 “Sooner or later, everything old is new again.” -Stephen King, The Colorado Kid On April 22, 2025, SBA issued Information Notice 5000-866746 announcing the issuance of the much-anticipated SOP 50 10 8. Per the Notice, this revised SOP which becomes effective on June 1, 2025 largely reinstates “requirements that were in place before ... Read More
