The SBA Feasibility Study Requirement That Does Not Exist (and the Ones That Do)

A primary-source reading of SOP 50 10 8: when a study is actually required, who may prepare one, what changed after June 1, 2025, and where guaranties get repaired.

By Michal Mohelsky, J.D., FMVA. MMCG Invest, LLC. Published August 14, 2026. Current as of August 14, 2026.

There is a sentence that borrowers, brokers, and more than a few lenders keep looking for in SOP 50 10 8, and it is not there. Nowhere in the SBA's lending manual will you find the words "the lender must obtain a feasibility study" attached to hotels, car washes, gas stations, startups, ground-up construction, or any other loan class. The entire codified basis for the study is one permissive clause in the regulations: SBA "may require professional appraisals of the applicant's and principals' assets, a survey, or a feasibility study" (1). May. Not must.

We prepare feasibility studies for a living, so it would be commercially convenient to tell you the opposite. A large share of what ranks for this query does exactly that, presenting the study as an SBA mandate for entire asset classes. It is not, and the overstatement matters, because the precise answer is worth real money on both sides of the closing table. The deals where studies are expected are the same deals where the SBA Office of Inspector General keeps finding "unsupported projected sales" in lender files and recommending that the agency recover the guaranty (2). Knowing where discretion ends and hard requirements begin is the difference between a file that survives a purchase review and a file that funds a recovery recommendation.

What follows is the reading we give lenders when they ask. It covers what the SOP actually says, the hard requirements that surround the discretionary study, the June 1, 2025 underwriting reset and the portfolio damage that caused it, the enforcement record on thin files, the USDA contrast, and what a study has to prove when no regulation tells you what it must contain. Every load-bearing claim is cited to a primary source, and the piece carries a currency stamp of August 14, 2026.

The rule as written

Start with the text, because everything else in this market is commentary. The feasibility study enters the SBA framework through 13 CFR 120.160, a short list of loan conditions, at subsection (b): SBA "may require professional appraisals of the applicant's and principals' assets, a survey, or a feasibility study" (1). The study sits in a list with surveys. That is the whole codified mandate.

The operating manual built on that regulation is SOP 50 10 8, effective June 1, 2025, which replaced SOP 50 10 7.1 of November 15, 2023 (3)(5). SBA announced the new edition on April 21, 2025 through Information Notice 5000-866746, then reissued it in a Technical Updates version on May 29, 2025 through Information Notice 5000-868665; the clean technical-updates text is the one lenders actually use (3)(4). The SOP is written as a principles-based document. It holds the lender or CDC responsible for prudent, well-supported underwriting, and where repayment rests on projections rather than operating history, it expects those projections to be supported. What it does not do is convert that expectation into a checklist.

Read closely, the SOP is silent on the feasibility study in three specific ways, and each silence gets papered over somewhere in the consultant marketing that dominates this query:

First, there is no mandate. No loan class, no asset type, no borrower profile categorically triggers a required feasibility study in the SOP text (3). Startups do not. Gas stations do not. Ground-up construction does not. The decision belongs to the lender, with 13 CFR 120.160(b) as the hook SBA can pull when it wants one.

Second, there is no preparer standard. The SOP names no credential, license, or qualification for whoever writes the study (3). Marketing that implies the SBA requires an MAI, a CPA, or any specific designation for feasibility work is not supported by the text.

Third, there is no content list. The SOP appends no template and itemizes no required sections for a feasibility study (3). The five-part content framework you will see attributed to the SBA all over the internet, economic, market, technical, financial, and management feasibility, is real, but it is USDA's codified standard at 7 CFR Part 5001, not SBA's (6). Attributing it to the SOP is the single most common factual error in this content category.

There is a fourth, quieter silence: the SOP states no independence standard for the feasibility preparer. That omission surprises people, because the SOP is famously strict about independence elsewhere. Which brings us to what the manual does require.

The hard requirements around the discretionary study

The absence of a feasibility mandate does not mean the SOP is relaxed about the deals that generate studies. The opposite is true. Around the discretionary study, SOP 50 10 8 builds a perimeter of hard rules, and that perimeter tightened considerably in June 2025.

Special-purpose property. The SOP defines it as "a limited market property with a unique physical design, special construction materials, or a layout that restricts its utility to the specific use for which it was built," and gives a non-exhaustive example list: hotels and motels, car washes, gas stations with or without convenience stores, bowling alleys, golf courses, funeral homes with crematoriums, cold storage facilities where more than half the square footage is refrigerated, nursing homes and assisted living, marinas, theaters, and service centers with pits and in-ground lifts (3). If you sell or lend on single-use real estate, you are on this list or adjacent to it.

The going-concern appraisal. Here the SOP is exacting in exactly the way it declines to be for feasibility studies. For special-purpose property, the lender must obtain an independent appraisal from a Certified General Real Property Appraiser, and per the SOP's own words the appraiser "must have completed no less than four going concern appraisals of equivalent special use property as the property being appraised, within the last 36 months" (3). The appraisal must allocate separate values to land, building, equipment, and intangible assets, and it must be a full USPAP-compliant Appraisal Report; the SOP states flatly that SBA has not accepted and will not accept Restricted Appraisal Reports (3). The lender orders it. An appraisal or valuation prepared for the borrower or the seller cannot be used (3).

Construction. For new construction or substantial renovation, the appraisal must estimate market value at completion, and after completion the lender must obtain a statement from the appraiser, the general contractor, the project architect, or a construction management firm confirming the building was built with only minor deviations from the plans relied upon (3). Substantial renovation means rehabilitation expenses exceeding one-third of the purchase price or fair market value at application (3). The automatic-waiver threshold for performance bonds and related construction protections dropped from $500,000 to $350,000 with the new edition (3).

Coverage floors. SOP 50 10 8 restored prescriptive debt service coverage. Standard 7(a) loans above $350,000 must demonstrate coverage of 1.15 to 1 or greater on a historical or projected basis, with operating cash flow defined as EBITDA and debt service defined as required principal and interest on all business debt, the new SBA loan included (3). For 7(a) Small Loans of $350,000 or less, a codified floor arrived on March 1, 2026: the applicant's coverage "must be equal to or greater than 1.10:1 on either a historical or projected basis," and a loan that cannot clear it must be processed as a Standard 7(a) loan or as SBA Express (7)(8). In 504 practice, global coverage is conventionally demonstrated at 1.00 to 1 alongside project-level coverage.

Equity injection. The new edition imposes a minimum injection of 10% of total project costs for startups, defined as businesses generating revenue for one year or less, and for complete changes of ownership, with total project costs meaning all costs required to become operational (3). A seller note counts toward the injection only if it sits on full standby, no principal and no interest, for the entire term of the SBA loan, and it can satisfy no more than half of the requirement, which means at least five points of real, unborrowed cash in every startup and full acquisition (3). Verification tightened with it: copies of checks or wire transfers, at least thirty days of account statements, and settlement statements. A promissory note or a gift letter alone no longer gets it done (3).

Collateral. The collateral threshold fell from $500,000 to $50,000, a tenfold reduction (3). Lenders must lien all available business assets, reach personal real estate of twenty-percent-plus owners where the loan is under-secured, and carry hazard insurance on collateral above $50,000 (3).

Step back and the architecture becomes visible. The mandatory appraisal answers the value question. The mandatory floors answer the coverage question, arithmetically. The mandatory injection answers the skin-in-the-game question. What remains is the only question a projection-based deal actually turns on: whether this operator, at this site, at this scale and capital structure, will produce the cash flow the projections assume. On a deal with years of tax returns, the file can answer that from history. On a startup, a ground-up build, or a single-use asset changing hands, it cannot. That is the space the feasibility study occupies, and it is why the study remains, in any practical sense, non-optional on those deals even though no sentence in the SOP says so.

June 1, 2025: the reset that never touched the feasibility text

To understand why demand for feasibility studies rose after June 2025 even though the feasibility language did not change, you have to understand what the new SOP was built to end.

The 2023 editions, SOP 50 10 7 in August and 7.1 in November, ran on a philosophy the industry came to call "do what you do": underwrite SBA loans the way you underwrite your conventional book, with wide latitude on equity sourcing, scoring-driven small loans up to $500,000, and no universal injection minimum (5). SOP 50 10 8 reversed that posture deliberately. It replaced latitude with SBA-prescribed minimums that lenders may exceed but may never relax (3)(4).

The cause was not ideological. It was arithmetic. SBA's own March 27, 2025 announcement said the quiet part plainly: fee waivers worth $460 million, "along with a dramatic reduction in underwriting standards, ultimately drove the SBA's core 7(a) lending program into negative cash flow for the first time in thirteen years" (10). The FY2024 numbers behind that sentence are stark. The program's cash flow went negative by roughly $397 million. Default rates reached about 3.7%, the highest since 2012. SBA purchased $1.6 billion in defaulted guarantees during FY2024 alone, up from $1.1 billion the prior year and $733 million in FY2022 (11).

The market's response to the tightening was a whipsaw worth remembering when you read volume statistics. Borrowers and lenders rushed to close ahead of June 1, and FY2025 finished as a record: 78,078 loans for $37.3 billion, up from 70,242 loans and $31.1 billion in FY2024 (11). Then the pipeline thinned. Through the first nine months of FY2026, approvals ran roughly a third lower by count and a fifth lower by dollars according to industry trackers, figures we treat as estimates rather than audited data (13). A 43-day federal shutdown that froze E-Tran made it worse; SBA estimated the stoppage blocked $5.3 billion in financing to some 10,000 small businesses (11).

Against that backdrop, the June 2025 changes read as a single coordinated move. The 7(a) Small Loan ceiling dropped from $500,000 to $350,000, pushing every loan between those numbers into full Standard 7(a) underwriting (4). The SBSS score minimum rose from 155 to 165, and then the score was retired entirely: effective March 1, 2026, SBA discontinued mandatory SBSS use for small loans and replaced it with commercial credit analysis plus the 1.10 coverage floor (7)(8). The credit-elsewhere test returned as a written, documented determination with a personal-resources component. The Franchise Directory, eliminated in 2023, came back for loans approved on or after June 1, 2025 (4). Ownership eligibility went through three phases in under a year, landing on March 1, 2026 at the strictest standard in program history: 100% of direct and indirect owners must be U.S. citizens or U.S. nationals with their principal residence in the United States, with lawful permanent residents no longer eligible to hold any interest (12). A September 30, 2025 procedural notice refined the collateral and lien rules, raised the 504 construction contingency from 10% to 15% of construction costs, and removed the "same geographic area" criterion from the business-expansion test (9).

Here is the finding that matters for this article, and it is a negative one: not a single post-June-2025 notice amended the feasibility, appraisal, or special-purpose-property provisions (3)(7)(8)(9)(12). The feasibility text is exactly where the base SOP left it. What changed is the burden of proof around it. When coverage floors are prescriptive, when injections are mandatory and verified, and when the small-loan scoring shortcut no longer exists, a projection-based file has to demonstrate its cash flow rather than assert it. The SOP did not add a feasibility mandate in June 2025. It added the conditions under which a lender cannot responsibly defend a projection-based credit without independent support. Demand for studies rose the way demand for umbrellas rises when the forecast changes. Nobody ordered it.

Where guaranties get repaired

Everything above is origination. The reason it matters is what happens two or three years later, when a loan defaults early and the file gets read by someone whose job is to decide whether SBA should pay.

The legal machinery is short and unsentimental. Under 13 CFR 120.524(a), SBA is released from liability on its guarantee, "in whole or in part, within SBA's exclusive discretion," if the lender "has failed to comply materially with any Loan Program Requirement," and purchase of the guaranty does not waive SBA's right to recover afterward (14). The machinery runs through the SOP 50 57 series; the servicing and liquidation edition in force is SOP 50 57 4, effective November 1, 2025 (15). A repair is a partial haircut tied to the quantifiable harm a lender's lapse caused. A denial is the whole guaranty. Chapter 25 of the servicing SOP lists the classic justifications, and early default caused by lender failure to properly make or close the loan sits near the top (15).

The Office of Inspector General has been documenting what "failure to properly make the loan" looks like for more than a decade, through its High Risk 7(a) Loan Review Program, running since FY2014, and a string of improper-payment audits before that. The findings are strikingly stable. In FY2019 alone, OIG's review of eight early-defaulted loans "identified material lender origination and closing deficiencies that justified denial of the guaranty for five loans in the amount of approximately $8.7 million" (2). The recurring repayment-ability deficiencies are itemized in the same consolidated results: "unverified seller's financial statements, all liabilities not considered, impact of affiliates not considered, unsupported projected sales; and inadequate business valuation" (2). An earlier review in the same cycle found lenders "did not provide adequate documentation to substantiate reasonable assurance that the borrowers met requirements for eligibility, repayment ability, and equity injection" (16). The program's cumulative arithmetic through 2017: twenty loans reviewed with purchase amounts of $17.7 million, recoveries recommended on seven totaling roughly $6 million, plus one outright denial of $917,107 (17). The Recovery Act audits that preceded the program found the same fact patterns and priced them at $4.6 million and $3.1 million in improper payments (18).

Read that deficiency list again and notice which phrase does the work on projection-based deals: unsupported projected sales. That is the audit name for a missing feasibility analysis. When repayment rests on projections and the file contains nothing independent behind them, the reviewer does not need to argue about underwriting philosophy. The deficiency language writes itself.

Two structural findings sharpen the point. First, OIG has repeatedly shown that SBA's own purchase reviews under-catch these problems. For FY2015, SBA reported improper payments of 0.9% of guaranty purchases; OIG statistically estimated 3.61%, roughly four times higher, with improper payments in 11 of 32 purchases reviewed (19). A lender should not take comfort from a clean purchase; the look-back can come later. Second, the loans originated during the loose window are now expressly flagged. OIG's FY2026 management-challenges report states that the 2023 changes "dramatically reduced underwriting standards," that the changes "increased potential risk," and that although most were reversed in 2025, "the loans made during that time remain susceptible to increased risk and financial loss" (20). A companion audit of SBA's screening framework found the agency could not support its own clearance decisions on 71 of 188 loans reviewed, about $60.7 million (21).

The metric that ties it together is early default. OIG treats defaults within roughly 18 to 36 months of origination as a signal of origination quality rather than economic misfortune, and the cohort data explain why the scrutiny is rising. Third-party analyses of SBA data show recent vintages deteriorating about twice as fast as older ones at the same loan age: the FY2016 cohort sat near 3.0% two years out, while the FY2024 cohort sits near 7.2% (13). The same analyses show default risk concentrating exactly where projections replace history: complete changes of ownership run near 0.71%, against roughly 1.99% for new businesses (13). These are estimates built on SBA data rather than audited SBA publications, and we present them as such, but the direction is consistent with everything in the primary record.

Construction deserves its own sentence, because it produces its own failure mode. SBA cites failure to ensure borrower use of proceeds as required by the loan authorization among the most common deficiencies in delegated-lender audits and purchase reviews, and the servicing SOP lists it explicitly as a repair-or-denial example (15). The controls reviewers expect are unglamorous: lien waivers before each draw, interim inspections before each advance, written change-order approval, and a borrower acknowledgment that the lender is not obligated to fund overruns. A feasibility study cannot administer a draw schedule, but a cost build-up reconciled to the budget the lender will control against is where that discipline starts.

One last piece of law, for the lenders who believe a funded guaranty is a settled guaranty. In Frillz, Inc. v. Lader, the First Circuit confirmed that determining the soundness of a loan guaranty is SBA's call and cannot be delegated away (22). The regulation says exclusive discretion and means it. The lender's real protection has never been the purchase; it is the file. On a projection-based deal, the study is the spine of that file.

USDA prescribes; SBA delegates

The cleanest way to see what SBA left out is to look next door. USDA Rural Development's OneRD framework, codified at 7 CFR Part 5001 in July 2020, writes down everything the SOP declines to (6).

Start with the definitions. A feasibility study under Part 5001 is "a report including an opinion or finding conducted by an independent qualified consultant(s)," and a qualified consultant is "an independent third-party person possessing the knowledge, expertise, and experience to perform the specific task required" (6). Then the trigger, and it is a bright line, not a judgment call: for Business & Industry guaranteed loans greater than $1,000,000 to a new business, "a feasibility study prepared by an independent qualified feaisbility consultant acceptable to the Agency is required," and "the scope of the feasibility study will be determined by the Agency" (6). The content is fixed too. Five components, economic, market, technical, financial, and management feasibility, enumerated across 37 factors in Appendix A to Subpart D: five economic, six market, nine technical, twelve financial, five management (6). The National Office reviews the study against that factor list, and a study silent on a required factor renders the application incomplete and sends it back (6). USDA amended Part 5001 in late 2024 and left the feasibility thresholds and the Appendix A factors untouched, which tells you how settled the standard is (23).

Set the two frameworks side by side and the asymmetry is structural, not cosmetic. USDA names the preparer, requires Agency acceptance of that preparer, fixes the contents, and grades the study against a codified checklist. SBA names nobody, fixes nothing, and grades the study twice, informally: once through the credit committee at origination, and once, if the loan defaults early, through the guaranty reviewer with 13 CFR 120.524 open on the desk (1)(14). Two programs, two completely different instruments that happen to share a name.

The practical consequence runs against intuition. A USDA study is the easier assignment in one narrow sense: the checklist tells you when you are done. An SBA study has to satisfy a lender in the absence of a checklist, which means the preparer, not the regulation, has to know what a credit committee and a purchase reviewer will each demand of a projection three years apart. The absence of a prescribed standard is precisely why preparer quality matters more on the SBA side, not less.

Building a study to a standard the SOP refuses to write

So the SOP will not tell you what an SBA feasibility study must contain. The audience will. A study on a projection-based deal has to survive two readers: the credit committee that approves the loan, and the purchase reviewer who may re-read the file after an early default with the OIG deficiency list in mind. We build to that standard, and it resolves into seven disciplines.

Architecture first. We build SBA studies on the same five-component architecture USDA codified, economic, market, technical, financial, and management feasibility, not because the SOP requires it but because it is the most complete answer to the question the file must survive, and because no reviewer has ever faulted a study for addressing management capacity or technical execution (6). Label it what it is: best practice aligned to the federal standard that exists, not an SBA mandate.

Coverage demonstrated at the floors, not asserted near them. The financial component must show debt service coverage at or above the applicable floor, 1.15 for Standard 7(a), 1.10 for Small Loans numbered on or after March 1, 2026, with operating cash flow built as EBITDA the way the SOP defines it, under a base case and at least one stressed case (3)(8). A projection that clears the floor only in the base case is not a conclusion; it is a warning with good manners.

Assumptions sourced, one by one. Every revenue and cost assumption ties to a named dataset, a comparable, or a contract, and any projection that departs from historical performance says why, in writing. This is the direct antidote to "unsupported projected sales," and it is the discipline USDA writes into its rule for projections that deviate from history (2)(6).

Independence, properly understood. The preparer must have no stake in whether the loan funds. The borrower typically orders and pays for the study in SBA practice, and payment alone does not impair independence; contingent compensation or a preparer related to the transaction does. Say so in the study, in a signed statement, so the reviewer does not have to wonder.

Reconciliation to the appraisal. On special-purpose deals the study and the going-concern appraisal will sit in the same file, and their numbers must be able to look at each other. Cash flows consistent with the appraisal's component allocation to land, building, equipment, and intangibles; discrepancies explained rather than ignored (3).

Construction discipline. For ground-up and substantial-renovation deals, the cost build-up reconciles to the budget the lender will administer draws against, including the 15% contingency on 504 construction, and states the completion-value logic the appraisal will confirm (3)(9).

Gating conditions, flagged. Feasibility cannot cure ineligibility. Since March 1, 2026, any ownership interest held by someone other than a U.S. citizen or national with a U.S. principal residence fails the eligibility test outright, lawful permanent residents included, so a study that ignores the borrower's ownership structure can bless a project the program cannot fund (12). We flag ownership, franchise-directory status, and size-standard exposure as gating conditions up front.

A study built this way does one more thing that no checklist captures: it states conditions. "Feasible if" is an analytical conclusion. "Feasible" without conditions is advocacy, and reviewers can smell the difference. If your file rests on projections, the study is where those projections either earn their place in the credit memorandum or fail in private, before a purchase reviewer makes the point for you at a price.

Current as of August 14, 2026

Currency is part of the claim this article makes, so here is the version status, stated exactly. The controlling origination document is SOP 50 10 8, effective June 1, 2025. There is no SOP 50 10 8.1 and no SOP 50 10 9 as of today; amendments arrive as procedural, policy, and information notices layered on the base text, and a lender must read the base SOP together with that layer (3)(7)(8)(9)(12). For the subject of this article the layer is quiet: none of the post-June-2025 notices touched the feasibility, appraisal, or special-purpose provisions. The two amendments a projection-based file must absorb are the 1.10 coverage floor for Small Loans and the ownership-eligibility rule, both effective March 1, 2026 (8)(12).

Two open items are worth watching. The Monetary-Based Size Standards proposal, published August 22, 2025 with comments closed October 21, 2025, would raise receipts- and asset-based size thresholds for 263 industries and remains pending; a final rule would widen the eligible-applicant pool in affected sectors (24). And effective July 4, 2026, borrowers may combine 7(a) and 504 exposure up to a $10 million cumulative limit, double the prior cap, which enlarges exactly the class of large, projection-dependent projects this article is about (25). We refresh this currency check quarterly.

Questions lenders actually ask

Does the SBA require a feasibility study for every loan? No. No SBA authority mandates a feasibility study for any loan class. The codified basis is permissive: SBA "may require" one under 13 CFR 120.160(b), and SOP 50 10 8 leaves the decision to lender judgment (1)(3).

When does an SBA loan require a feasibility study in practice? When repayment rests on projections rather than history. Lenders most consistently order studies for startups, ground-up construction, special-purpose property, and complete changes of ownership, because those files cannot demonstrate the SOP's coverage floors from tax returns alone and because the enforcement record punishes unsupported projections (2)(3).

Who can write an SBA feasibility study? The SOP names no credential. The working standard is an independent third party with no financial stake in the outcome and documented experience in the asset class. By contrast, USDA codifies its preparer standard, and the SOP's own prescriptive credentials attach to appraisers and business valuators, not feasibility preparers (3)(6).

What coverage does an SBA feasibility study need to demonstrate? At or above the program floors: 1.15 to 1 for Standard 7(a) loans, with operating cash flow defined as EBITDA, and 1.10 to 1 for 7(a) Small Loans numbered on or after March 1, 2026. A strong study demonstrates the floor in a base case and holds it under stress (3)(8).

Is a feasibility study the same as an appraisal? No, and the two are not substitutes. The appraisal answers the value question and, for special-purpose property, must come from a Certified General appraiser with four equivalent going-concern assignments in the last 36 months. The study answers the cash-flow question the appraisal cannot. Projection-based special-purpose deals typically need both (3).

What is a special-purpose property under the SBA? A limited-market property whose design, materials, or layout restricts it to the use it was built for. The SOP's example list runs from hotels, car washes, and gas stations to bowling alleys, golf courses, cold storage, assisted living, marinas, and funeral homes with crematoriums (3).

Did SOP 50 10 8 change feasibility study requirements? The feasibility text itself, no. The environment around it, substantially: prescriptive coverage floors, a mandatory 10% equity injection on startups and full changes of ownership, a $50,000 collateral threshold, and a tightened going-concern appraisal regime, all of which raise what a projection-based file must prove (3)(7)(8).

What does an SBA feasibility study cost, and how long does it take? Published fees across the providers ranking for this query run from about $4,900 at the entry level to $25,000 and more for complex assets, with turnaround typically quoted at nine to sixteen business days; scope, asset class, and lender requirements drive the spread (26).

Request a Feasibility Study https://calendar.app.google/EJzWEz3GCqLY2jU86

Michal Mohelsky, J.D. | Principal | mmcginvest.com 

Contact: michal@mmcginvest.com

Phone: (628) 225-1125

Disclaimer: This report is provided for informational purposes only and does not constitute investment, legal, or tax advice. Data presented herein is derived from proprietary MMCG databases and third-party sources believed to be reliable; however, MMCG Invest makes no representation as to the accuracy or completeness of such information. Figures from third-party industry databases have been independently verified and, where appropriate, adjusted to reflect MMCG's proprietary analytical methodology. Statutory and regulatory references are provided for context and must be verified with counsel before reliance. Past performance is not indicative of future results.

Sources

(1) 13 CFR 120.160(b), Loan conditions (eCFR, current through August 2026). (2) SBA Office of Inspector General, Report 19-22, Consolidated Results of the OIG High Risk 7(a) Loan Review Program, September 26, 2019. (3) U.S. Small Business Administration, SOP 50 10 8, Lender and Development Company Loan Programs, effective June 1, 2025 (Technical Updates version issued via Information Notice 5000-868665, May 29, 2025). (4) SBA Information Notice 5000-866746, Issuance of SOP 50 10 8, April 21, 2025. (5) U.S. Small Business Administration, SOP 50 10 7.1, effective November 15, 2023. (6) 7 CFR Part 5001 (OneRD Guarantee Loan Initiative), 85 FR 42494, July 14, 2020, including 5001.3, 5001.306(a)(3)(i), and Appendix A to Subpart D. (7) SBA Procedural Notice 5000-875701, Sunset of SBSS Score for 7(a) Small Loans, published January 16, 2026, effective March 1, 2026. (8) SBA Procedural Notice 5000-876777, Sunset of SBSS Score, Supplemental Guidance, February 20, 2026, effective March 1, 2026. (9) SBA Procedural Notice 5000-872764, Revisions to SOP 50 10 8, 504 and 7(a) Loan Program Updates, effective September 30, 2025. (10) SBA News Release 25-41, March 27, 2025. (11) SBA 7(a) program data: FY2024 Annual 7(a) Risk Analysis Report; SBA FY2025 year-end lending data and FYE25 Activity Report; SBA News Release 26-06, November 13, 2025. (12) SBA Policy Notice 5000-876441 (February 2, 2026) and SBA Procedural Notice 5000-876626 (February 11, 2026), both effective March 1, 2026, rescinding Procedural Notice 5000-872050. (13) Third-party analyses of SBA loan-level data: Lumos cohort analysis; GoSBA loan-purpose analysis; Coleman Report and NAGGL volume trackers. Presented as estimates. (14) 13 CFR 120.524, When is SBA released from liability on its guarantee. (15) U.S. Small Business Administration, SOP 50 57 4, 7(a) Loan Servicing and Liquidation, effective November 1, 2025 (Information Notice 5000-872353); SOP 50 57 3, Chapter 25. (16) SBA Office of Inspector General, Report 19-16, High Risk 7(a) Loan Review Program, FY2019. (17) SBA Office of Inspector General, Report 17-18, OIG High Risk 7(a) Loan Review Program. (18) SBA Office of Inspector General, Reports 13-16R (June 14, 2013) and 14-09 (January 29, 2014), improper payments on 7(a) Recovery Act loans. (19) SBA Office of Inspector General, Report 18-07, Accuracy of the FY2015 7(a) Loan Guaranty Purchase Improper Payment Rate. (20) SBA Office of Inspector General, Report 26-01, Top Management and Performance Challenges Facing the SBA in Fiscal Year 2026, December 18, 2025. (21) SBA Office of Inspector General, Report 26-07, SBA's Screening of 7(a) Loan Applications Under its Risk Mitigation Framework. (22) Frillz, Inc. v. Lader, 104 F.3d 515 (1st Cir. 1997). (23) 89 FR 79720 and 89 FR 79721, amendments to 7 CFR Part 5001, effective November 29, 2024. (24) Small Business Size Standards: Monetary-Based Industry Size Standards, 90 FR 41168, proposed August 22, 2025; comment period closed October 21, 2025. (25) SBA Policy Notice 5000-879058, Coordination of 7(a) and 504 for Maximum Loan Limits, May 18, 2026, effective July 4, 2026. (26) Provider-published fee and turnaround disclosures for SBA feasibility studies, surveyed August 2026.