EDITORIAL · SBA 504

    The Feasibility Study Consultant's Role in SBA 504 Transactions

    Last updated: August 6, 2026

    FSC Consulting, Inc. is run by Sarrah Allen, MAI.

    An SBA 504 is three things a 7(a) is not: two lenders reading the same file for different reasons, a debenture fixed for up to twenty-five years, and money that arrives only after the building is finished rather than at closing. Each of those changes what the feasibility study has to prove. And a policy notice effective 4 July 2026 quietly fixed the programme's oldest structural problem.

    What makes this a different assignment

    Most feasibility work written for SBA borrowers is written for 7(a) and then reused on 504 files with the programme name changed. That produces a document that misses several things a Certified Development Company and a participating bank will look for.

    The 504 programme finances long-term fixed assets through a three-part structure. A third-party lender provides at least 50% of project cost in first-lien position. A CDC provides up to 40% through an SBA-guaranteed debenture sold to investors, secured in second position. The borrower contributes at least 10%.

    Whether the CDC can rely on a study addressed to the third-party lender, and how to add it as an intended user, is covered in Reliance, Certification and Liability: Who May Rely on a Feasibility Study.

    Five consequences follow.

    The borrower occupies the property but may not occupy all of it, which creates a second revenue stream that counts toward repayment.

    The debenture is fixed for its full term — but the bank's first mortgage frequently is not, which changes what the interest rate sensitivity should actually test.

    The programme cannot fund working capital, which creates a financing gap the study should identify.

    There is an economic development requirement, and the feasibility study is the natural place to substantiate it.

    And the debenture funds after project completion, which creates an interim financing exposure that has no equivalent in 7(a).

    The programme in 2026

    Volume recovered but remains rate-sensitive. Approvals by fiscal year:

    FY2021 — 9,676 loans, $8.2 billion

    FY2022 — 9,254 loans, $9.2 billion

    FY2023 — 5,924 loans, $6.4 billion

    FY2024 — 5,993 loans, $6.7 billion

    FY2025 — 6,762 loans, $7.8 billion

    The FY2022 to FY2023 collapse was 36% by loan count, and it tracked the rise in debenture rates. The FY2024 and FY2025 recovery tracked rate stabilisation — but FY2025 still sits 27% below the FY2022 peak.

    The average FY2025 debenture was $1,154,096. Because the debenture is typically 40% of the project, that implies an average total project size around $2.9 million, with special-purpose and construction deals skewing higher.

    Who uses it. Retail and service businesses are the largest borrower category at roughly a quarter to a third of approvals, followed by healthcare and medical practices, manufacturing, and hospitality at roughly 12% to 15%. California, Texas and Florida together account for approximately 30% of national volume.

    On lenders, TMC Financing announced its fifth consecutive year as the largest national 504 lender, having "approved 548 SBA 504 loans, totaling over $2.4 billion in total project financing" in FY2025. CDC Small Business Finance, now part of Momentus Capital, is another perennial top producer.

    One disruption worth noting for anyone modelling timing: the first quarter of FY2026 was affected by a 43-day government shutdown that suspended both 7(a) and 504 approvals.

    The capital stack, and what it does to the model

    The typical structure is 50 / 40 / 10 — bank, CDC debenture, borrower equity.

    Equity rises in identifiable circumstances, and the tiers matter more than the headline:

    Standard project: 10%

    Special-purpose property: 15%

    Startup or business operating under two years: 15%

    Both new business and special-purpose property: 20%

    Those are almost exactly the circumstances in which a third-party feasibility study is expected. A startup acquiring a special-purpose property faces the programme's highest equity requirement and its strongest study expectation simultaneously. A sponsor who discovers the equity tier late has usually also discovered the study requirement late.

    What counts as equity is broader than cash. The borrower's existing equity in land or a building already owned that becomes part of the project counts, valued by appraisal. Land already owned can substantially reduce or eliminate the cash down payment, and it is frequently overlooked at the point where a sponsor is deciding whether the deal is affordable.

    Debenture size is capped, not project size. The standard maximum is $5 million, rising to $5.5 million per project for small manufacturers under NAICS 31 to 33 and for eligible energy public policy projects. Small manufacturers may hold multiple 504 loans, one per distinct project. There is no cap on total project size, because the third-party first mortgage sits above the debenture.

    One item to verify per deal: the $16.5 million aggregate cap on energy public policy projects was removed in 2024, and some CDC summaries describe the June 2025 SOP as restoring it at $5.5 million per project. Confirm against the current SOP for any specific energy deal.

    The first mortgage is not fixed, and the sensitivity analysis has to reflect that

    This is the most common analytical error in 504 feasibility work.

    The CDC debenture is fixed for its full term — 10, 20 or 25 years. That is the programme's headline advantage and it is genuine.

    But the bank's first mortgage is commonly written on a ten-year term against a twenty or twenty-five year amortisation, producing a balloon while the debenture continues at its fixed rate to maturity.

    So "504 is fully fixed" is only true of the CDC leg. The bank leg carries refinance and rate risk, and the study should test:

    Rate movement on the bank portion only, not across the whole stack

    Coverage at the bank's refinancing point, where its term is shorter than the debenture's — a first mortgage maturing in year ten against a debenture running to year twenty-five is a real event that has to be survivable

    Blended debt service across both instruments, which is the number that actually determines coverage

    Applying a uniform rate shock across the entire capital stack overstates the borrower's exposure and, in doing so, understates the programme's principal advantage.

    Owner-occupancy creates two revenue streams

    This is the feature most commonly under-analysed and a genuine opportunity to add value.

    Existing building: the operating business must occupy at least 51%, and may lease up to 49% long-term.

    New construction: at least 60% immediately, with up to 20% leased long-term, a plan to occupy some of the remaining space within three years, and 80% total occupancy within ten years.

    Occupancy is measured per parcel, and in an EPC/OC structure the EPC leases 100% to the operating company, which must meet the occupancy test.

    Leasehold income from the permitted leased portion counts toward repayment ability.

    Which means a study modelling only the operating business has analysed part of the credit. Where a meaningful share is leased, treat it as what it is — a small commercial property attached to an operating business:

    Market rent for the leasable space, evidenced against comparable local leases

    Realistic vacancy and lease-up assumptions rather than full occupancy from day one

    Tenant credit and lease terms where tenants are identified

    Re-letting risk over the loan term, which on a twenty-five year debenture is not remote

    Operating expense allocation between owner-occupied and leased portions

    Two analyses, one document. Blending them into a single revenue line obscures both.

    One compliance trap worth naming. Occupancy must be met within one year of debenture funding, and selling the business and leasing the whole building to a tenant breaches it. That scenario should be identified where a sponsor's exit plan implies it.

    The working capital gap — and the July 2026 fix

    504 finances fixed assets. It cannot fund working capital, inventory or goodwill.

    For a stabilised business buying its own premises this is unremarkable. For a startup or an expansion it has always been a structural problem — and one no individual party in the transaction is responsible for spotting.

    That changed on 4 July 2026.

    SBA Policy Notice 5000-879058 decoupled the two programmes. Outstanding 7(a) balances no longer reduce a borrower's maximum 504 debenture. 504 balances still count against 7(a) capacity, so a combined structure must have the 7(a) approved first.

    Maximum combined SBA financing is now $10 million — $5 million per programme.

    The clean structure is a 7(a) for the operating company and working capital alongside a 504 for the real estate, closing together, with the 7(a) approved first.

    For manufacturers there is now a second route. MARC — Manufacturer's Access to Revolving Credit — launched 1 October 2025, offering revolving lines and term loans up to $5 million.

    And one indirect path exists inside 504 itself. The refinance-with-cash-out option, within an 85% loan-to-value ceiling, can fund eligible business operating expenses. It is not a general working capital line, but it is the only route to operating cash inside the 504 framework.

    The study should still quantify the gap explicitly — what the business needs to fund operations from opening to positive cash flow, month by month, and where that money is coming from. The gap is now solvable. It is not automatically solved.

    The base rate behind the concern: per a LendingTree analysis of Bureau of Labor Statistics Business Employment Dynamics data, "22.1% of new private-sector businesses in the U.S. fail within their first year. After five years, nearly half (48.6%) close." A borrower who buys real estate with 10% down and preserves no operating cash is exposed to exactly that.

    Job creation, now $95,000

    The standard was reset upward effective 1 October 2025 under 90 FR 47117, published 30 September 2025.

    One Job Opportunity per $95,000 of SBA debenture, up from $90,000 set on 11 May 2023 at 88 FR 30379.

    For small manufacturers and energy public policy projects: $150,000, up from $140,000.

    A Job Opportunity is a full-time or full-time-equivalent permanent job created within two years of 504 funding, or retained because of the loan. 75% of jobs must be in the community where the project is located, though the jobs need not sit at the project site.

    The arithmetic is worth doing early. A $2 million debenture at $95,000 per job implies roughly 21 jobs created or retained. If the business plan does not produce that many, the project must qualify on a public policy or community development goal instead — and knowing which basis applies changes what the study must demonstrate.

    The full list, which most summaries get wrong

    13 CFR 120.862 contains thirteen qualifying goals, not ten. Many secondary summaries still track the older SOP 50 10 5 structure and omit the energy goals. The consolidated CFR list is authoritative.

    Community Development goals, under subsection (a):

    Improving, diversifying or stabilising the economy of the locality

    Stimulating other business development

    Bringing new income into the community

    Assisting manufacturing firms, NAICS Sectors 31 to 33

    Assisting businesses in Labor Surplus Areas

    Public Policy goals, under subsection (b):

    Revitalising a business district with a written revitalisation or redevelopment plan

    Expansion of exports

    Expansion of small businesses owned and controlled by women

    Expansion of small businesses owned and controlled by veterans, especially service-disabled veterans

    Expansion of minority enterprise development

    Aiding rural development

    Increasing productivity and competitiveness — retooling, robotics, modernisation, competing with imports

    Modernising or upgrading facilities to meet health, safety and environmental requirements

    Assisting businesses in or moving to areas affected by federal budget reductions or base closings

    Reducing unemployment in labor surplus areas

    Reducing energy consumption by at least 10 percent

    Increased use of sustainable or low-impact design

    Plant, equipment and process upgrades of renewable energy sources — micropower, biodiesel, ethanol

    Goals 11 through 13 are the ones most often missed, and for a project involving an energy-efficient building or a renewable installation they can be the cleanest qualifying route available.

    On enforcement. If a project misses its job number it does not automatically default. The shortfall is absorbed at the CDC portfolio level, and for projects in Alaska, Hawaii, enterprise and empowerment zones, labor surplus areas and Opportunity Zones the portfolio average may be relaxed further.

    Which is why the job test is, candidly, loosely enforced at the individual borrower level — a gap between the programme's stated economic development purpose and its practical operation. The feasibility study is still the natural place to substantiate it, because a study that builds a defensible staffing schedule by function, phased over the ramp, produces the job numbers as a by-product of proper analysis. A study that asserts a headcount produces a number the CDC cannot rely on.

    Pricing, fees, and the manufacturer waiver

    Current debenture pricing. The August 2026 debenture priced on 6 August 2026:

    25-year: 5.14% — Treasury 4.64%, spread plus 0.50%, pool of 423 loans totalling $499.2 million

    20-year: 5.08% — spread plus 0.44%

    10-year: 4.69%, priced July 2026

    For historical context, the 25-year peaked at 5.71% in November 2023 and bottomed at 1.75% in November 2021.

    Effective all-in rates, including servicing fees, ran approximately 6.17% on the 25-year, 6.20% on the 20-year and 5.87% to 6.19% on the 10-year in July 2026.

    Manufacturer rates in FY2026 run roughly 20 to 25 basis points below standard, because their annual service fee is waived.

    How pricing works. The debenture is priced monthly, on the first Thursday of the first full week, with 20- and 25-year debentures offered every month and 10-year every other month. Funding follows the week after pricing.

    Fees

    Per 13 CFR 120.971 and the FY2026 notices:

    CDC processing fee: up to 1.5% of net debenture proceeds

    SBA upfront guaranty fee, FY2026: 0.50% — up from 0% in FY2025, for all 504 loans other than Debt Refinance Without Expansion, per SBA Information Notice 5000-871532, effective 1 October 2025 to 30 September 2026

    SBA annual service fee, FY2026: 0.209% of outstanding balance for standard loans, down from 0.331%; 0.2115% for Debt Refinance Without Expansion

    Central Servicing Agent fee: approximately 0.10% annually

    CDC servicing fee: minimum 0.625% annually

    Third-party lender participation fee: one-time 0.5% of the first mortgage

    All-in fee load runs roughly 2.5% to 3.5% of project cost, comparable to or slightly cheaper than an equivalent 7(a) for real estate. Most fees are financed into the debenture.

    The manufacturer waiver, which is unusually generous

    For all 504 loans to manufacturers under NAICS 31 to 33 — including Debt Refinance both with and without Expansion — both the upfront guaranty fee and the annual service fee are waived entirely in FY2026 under the Made in America initiative.

    This is the first time SBA has extended full 504 fee waivers to manufacturers, and it runs to 30 September 2026. For a manufacturing project, the timing question is worth raising explicitly.

    The timeline problem nobody warns about

    This is the structural feature of 504 that has no 7(a) equivalent, and it catches sponsors.

    The debenture funds only after project completion — roughly 30 to 60 days after closing on an acquisition, and after certificate of occupancy on a construction deal.

    Which means someone has to advance the CDC's 40% at closing. That is the interim or bridge lender, usually the same bank holding the 50% first mortgage. Under 13 CFR 120.890 the borrower or an associate may not provide it.

    SBA Form 2288, the Interim Lender Certification, must be executed not more than 60 days before debenture funding.

    For construction deals the bridge is carried through build-out to certificate of occupancy, lengthening the exposure considerably. CDC materials cite an interest-only interim rate around 7%.

    Three practical consequences for the study and the deal team:

    Interim interest is a real cost and belongs in the project budget rather than appearing as a surprise.

    Misalignment with the monthly debenture calendar extends the wait, so closing should be sequenced against the pricing date.

    And construction cost overruns have nowhere to go. The debenture funds a fixed amount at completion. Overruns must be covered by the borrower or the interim and first mortgage lender — which makes a realistic construction budget with genuine contingency a credit item rather than a formality.

    What SOP 50 10 8 changed for 504

    Effective 1 June 2025, issued 22 April 2025 via Information Notice 5000-866746 and superseded on 29 May 2025 by the Technical Updates version.

    Notably, NADCO's summary observed that Section C — the 504-specific section — had no updates beyond the cross-cutting changes. The substantive shifts fell in Section A, which applies to 504, and Section B, which is 7(a). The 504-relevant changes:

    Ownership and citizenship. Only US firms are eligible, and all direct and indirect owners must be US citizens or, initially, permanent residents with a US primary residence. Subsequent notices 5000-872050 and 5000-876626 tightened this further: as of 1 March 2026, 100% of owners must be US citizens or US nationals, and lawful permanent residents no longer qualify.

    The Franchise Directory was reinstated for loans approved on or after 1 June 2025.

    Environmental. Reports must be dated within one year of loan number issuance. CDCs retain compliance documentation for uncontaminated properties rather than submitting it. NAICS matches to Appendix 6 sensitive industries — and 457 gas stations under Appendix 7 — trigger Phase I environmental site assessments. Procedural Notice 5000-866054, effective 20 March 2025, placed environmental compliance responsibility on CDCs.

    Appraisals. USPAP-compliant Appraisal Reports — not Restricted Appraisal Reports — are required above $250,000. Special-purpose appraisals require an appraiser experienced in that specific property type, and SOP 50 10 8 codified a floor of four going-concern appraisals in 36 months for special-use appraisers.

    And the 95% rule matters. If the appraisal comes in below 95% of estimated value, the loan must be reduced, additional collateral or equity added, or SBA approval requested. This is among the most common late-stage deal-killers.

    Change of ownership. 504 finances only the real estate and fixed-asset portion — it cannot fund goodwill or the intangible portion of an acquisition. Business acquisitions therefore typically run on 7(a), frequently paired with a 504 for the property. Procedural Notice 5000-872764, effective 30 September 2025, amended both programmes further; a business expansion with identical ownership and co-borrowers requires no equity injection.

    When a feasibility study is required

    SOP 50 10 8 does not publish a rigid "always required" rule for 504. The requirement is risk-based, resting on the CDC's and lender's duty to support repayment where history cannot.

    In practice a study is required or strongly indicated for:

    Startups and businesses operating under two years

    Complete changes of ownership

    Ground-up construction or major expansion

    Special-purpose or limited-purpose property — hotels, car washes, gas stations, cold storage, bowling alleys, amusement parks, cemeteries, dormitories, farms, funeral homes and similar, on the list SOP 50 10 8 reinstated largely unchanged from SOP 50 10 5(I)

    And there is a practical enforcement mechanism. SBA quality control reviewers can and do return files missing an independent feasibility study on special-purpose property deals. CDCs and banks therefore treat the study as a de facto condition for these categories even where the SOP language is discretionary.

    What the study must contain for the credit memorandum

    The study should anticipate what the credit memo has to say: how market demand was measured, why the capture rate holds, what coverage survives stress, and which conditions stand between commitment and closing.

    Coverage at the programme minimums — 1.15x operating debt service coverage and 1.00x global — with the revenue ramp behind it and an explicit downside case.

    A study written to that logic gives the underwriter language the memo can adopt, and creates a documented rationale predating any later guarantee review.

    How the study and the appraisal divide the work

    They are complements, not substitutes.

    The appraisal establishes value. The feasibility study demonstrates market depth and re-use risk directly — which matters most on special-purpose collateral, precisely because that collateral has few alternative uses and the study cannot lean on the appraisal to establish that a successor operator exists.

    For a special-purpose going-concern appraisal, the appraiser must meet the experience floor, and the value must support the loan against the 95% test.

    Where 504 transactions fail or get declined

    Common decline reasons:

    Ineligible use — working capital or goodwill

    Failure to meet owner-occupancy

    Ineligible ownership, now that 100% US citizen or national status is required

    Passive or investment real estate

    Weak or unsupported repayment projections

    Appraisal below 95% of estimated value without cure

    Environmental contamination

    Franchise not listed in the Directory

    Common underwriting and feasibility errors:

    Aggressive revenue ramps and capture rate assumptions. Expense ratios that sit below what comparable operators achieve. Ignoring a competitor's announced project in the same trade area. And coverage ratios built on numbers nobody believes.

    On that last point, a principle worth stating plainly: a defensible 1.30x built on realistic inputs beats a 1.40x built on optimism. The higher ratio invites the scrutiny that finds the assumptions.

    On losses. The dominant reason 504 loses less than 7(a) is the real estate collateral and the equity floor. Where 504 losses do occur, they cluster in special-purpose properties whose collateral cannot be repurposed, and in businesses that failed during ramp — which is precisely the argument for independent feasibility work on exactly those deals.

    Two things worth knowing that run against the conventional view

    504 is frequently cheaper than 7(a) once fees are counted, not just on headline rate. A fixed debenture in the low 5% range plus a 2.5% to 3.5% all-in fee load frequently beats a variable 7(a) — priced at Prime plus 2.75% to 4.75%, which at a 6.75% prime rate caps around 9.75% to 13.25% — for real estate, particularly above $1 million where the fee structure favours 504. The "two loans, more paperwork" objection masks a lower lifetime cost.

    And 504 defaults materially less than 7(a). Net charge-off rates in normal conditions have averaged roughly 0.8% to 1.5% for 504 against roughly 2% to 4% for 7(a), with recovery rates on defaulted loans of 50% to 70% against 30% to 50%. These figures derive from analyses citing SBA Office of Inspector General reporting rather than a single current published table, and the precise current-vintage figure should be confirmed against the latest OIG report before being relied upon.

    The reason is structural rather than incidental. A 504 loan is anchored to real estate that retains value and can be recovered, carries a hard equity floor, and tends to finance more established operators.

    One more, on equity. The 10% requirement is genuinely lower than conventional, not cosmetically so — conventional commercial real estate typically requires 25% to 35% down. And because land already owned counts toward the injection, the effective cash requirement can be lower still.

    What each reader wants

    The third-party lender holds a first mortgage at 50% loan-to-cost in first position. Their exposure is well collateralised and their focus is conventional commercial credit: repayment capacity, collateral value, guarantor strength, and the realism of the projections. They are frequently the party with the deepest sector knowledge.

    The CDC packages the SBA portion, takes second position, and must satisfy programme requirements as well as credit standards — eligibility, occupancy compliance, the economic development test, and SBA's documentation requirements, with a file that survives quality control review.

    The borrower should want to know whether the working capital gap has been identified and funded, because that is the failure mode the programme structure creates and the July 2026 decoupling now makes solvable.

    A study written for only one of the three leaves the others doing work it should have done.

    Frequently asked questions

    How much equity does an SBA 504 loan require? 10% for a standard project, 15% for special-purpose property, 15% for a business operating under two years, and 20% where both apply. Equity in land or a building already owned that becomes part of the project counts toward the injection, valued by appraisal, which can substantially reduce the cash required.

    Can an SBA 504 loan fund working capital? No. 504 finances fixed assets — real estate, construction and renovation, long-life equipment — plus associated soft costs and qualified debt refinance. Working capital, inventory and goodwill are not eligible. The refinance-with-cash-out option can fund eligible business operating expenses within an 85% loan-to-value ceiling, which is the only indirect route.

    Can a borrower have a 7(a) and a 504 at the same time? Yes, and it became considerably easier on 4 July 2026. SBA Policy Notice 5000-879058 decoupled the programmes so that outstanding 7(a) balances no longer reduce 504 debenture capacity, raising maximum combined SBA financing to $10 million. Because 504 balances still count against 7(a) capacity, the 7(a) must be approved first.

    What is the SBA 504 job creation requirement? One job created or retained per $95,000 of SBA debenture, effective 1 October 2025 under 90 FR 47117, up from $90,000. For small manufacturers and energy public policy projects the figure is $150,000. A $2 million debenture therefore implies roughly 21 jobs.

    What if a project cannot meet the job creation requirement? It can qualify instead on any of the thirteen community development or public policy goals in 13 CFR 120.862 — which include rural development, exports, women-owned and veteran-owned business expansion, and three energy goals that many summaries omit: reducing energy consumption by at least 10%, sustainable or low-impact design, and renewable energy upgrades. Shortfalls are also absorbed at the CDC portfolio level.

    How much owner-occupancy does 504 require? At least 51% of an existing building, with up to 49% leasable long-term. For new construction, at least 60% immediately, up to 20% leased long-term, some of the remainder occupied within three years and 80% within ten. Occupancy must be met within one year of debenture funding.

    Does rental income from the leased portion count? Yes. Leasehold income from the permitted leased space counts toward repayment ability, which means a 504 study on a partly leased building is analysing two things — an operating business and a small commercial property — and should model them separately.

    What is the current SBA 504 debenture rate? The August 2026 debenture priced on 6 August 2026 at 5.14% for the 25-year and 5.08% for the 20-year; the July 2026 10-year priced at 4.69%. Effective all-in rates including servicing fees ran approximately 6.17% to 6.20%. The 25-year peaked at 5.71% in November 2023.

    Is the whole 504 structure fixed rate? Only the CDC debenture. The bank's first mortgage is commonly written on a ten-year term against a twenty or twenty-five year amortisation, producing a balloon while the debenture continues to maturity. A sensitivity analysis should test rate movement on the bank portion and coverage at its refinancing point, not apply a uniform shock across the whole stack.

    Why does the 504 debenture fund after closing rather than at closing? Because debentures are pooled and sold to investors monthly, funding roughly 30 to 60 days after closing and after certificate of occupancy on construction deals. An interim or bridge lender — usually the bank holding the first mortgage, and never the borrower or an associate under 13 CFR 120.890 — advances the CDC portion at closing and is taken out when the debenture funds.

    Are there fee waivers currently available? Yes, and they are substantial for one group. For all 504 loans to manufacturers under NAICS 31 to 33, including Debt Refinance both with and without expansion, both the upfront guaranty fee and the annual service fee are waived entirely in FY2026 — the first time SBA has extended full 504 fee waivers to manufacturers. The FY2026 fee year runs to 30 September 2026.

    When does an SBA 504 transaction need a feasibility study? The requirement is risk-based rather than a bright-line rule, but a study is required or strongly indicated for startups and businesses under two years, complete changes of ownership, ground-up construction or major expansion, and special-purpose property. SBA quality control reviewers return files missing an independent study on special-purpose deals, so CDCs treat it as a de facto condition.

    Does 504 default less than 7(a)? Yes, and materially. Net charge-off rates in normal conditions have averaged roughly 0.8% to 1.5% for 504 against roughly 2% to 4% for 7(a), with better recovery on defaults. The reason is structural: the loan is anchored to recoverable real estate, carries a hard equity floor, and tends to finance more established operators.

    Sources

    SBA Standard Operating Procedure 50 10 8, effective 1 June 2025, issued via Information Notice 5000-866746 and superseded 29 May 2025 by the Technical Updates version.

    SBA Policy Notice 5000-879058, effective 4 July 2026, decoupling 7(a) and 504 maximum loan amounts.

    SBA Procedural Notices 5000-866054, 5000-872050, 5000-872764 and 5000-876626.

    SBA Information Notice 5000-871532, FY2026 fee schedule.

    Federal Register, 90 FR 47117, published 30 September 2025, job creation requirement adjustment; and 88 FR 30379, 11 May 2023.

    13 CFR Part 120, including §120.862 economic development objectives, §120.890 interim financing, and §120.971 allowable fees.

    SBA Monthly and Yearly Activity Report, 504 approvals by fiscal year.

    SBA 504 CDC Lender Activity Report.

    TMC Financing announcement, 2 October 2025.

    National Association of Development Companies, SOP 50 10 8 summary.

    Eagle Compliance debenture pricing data, August 2026; SomerCor effective rate schedule, July 2026.

    SBA Office of Inspector General reporting on 504 and 7(a) charge-off and recovery rates.

    LendingTree analysis of US Bureau of Labor Statistics Business Employment Dynamics data.

    Prepared by feasibility-study-consultant.com. Programme terms including debenture limits, equity tiers, occupancy thresholds, the job creation standard, fees and fee waivers are periodically revised — the job figures by Federal Register notice and the fees each fiscal year — and should be confirmed with a Certified Development Company for any live transaction. The aggregate cap on energy public policy projects has moved between removal and reported restoration and should be verified per deal. Charge-off and recovery figures are normal-condition averages derived from analyses citing SBA Office of Inspector General reporting rather than a single current published table. Feasibility study requirements are risk-based rather than a bright-line SOP mandate, and individual CDC and lender overlays vary. Debenture pricing changes monthly. This is not legal, tax or lending advice. Last updated: August 6, 2026.