{"ok":true,"canonical_url":"https://dealroom.so/for-lenders/questions/how-are-common-officers-or-shared-key-employees-between-businesses-evaluated-for-affiliati","api_url":"https://dealroom.so/api/public/questions/how-are-common-officers-or-shared-key-employees-between-businesses-evaluated-for-affiliati","question":"How are common officers or shared key employees between businesses evaluated for affiliation under SBA size standards?","topic":"Affiliation & size","audience":"lender","bot_mode":"lender","short_answer":"Common officers or shared key employees can trigger affiliation for SBA size determination, as this indicates common management or control, even if other ownership criteria are not met.","rule":"The SBA's affiliation rules (13 CFR 121.103) include 'common management.' If the same individuals serve as officers, directors, or key employees for two or more businesses, it suggests common management and control, leading to an affiliation determination. Their revenues and employee counts would then be combined for size standards.","example":"The CEO of 'Tech Solutions LLC' also serves as the COO for 'Software Innovations Inc.' Despite having different ownership structures, the shared key management personnel would likely trigger affiliation, requiring both companies' financials to be aggregated for SBA size standard calculations.","what_lenders_check":"Lenders must thoroughly investigate the management structure of the applicant business and any potentially affiliated entities. Identifying common management is crucial for accurate size determination and to prevent eligibility errors that could lead to a guaranty repair.","required_facts":["Common management","Shared employees","Key personnel","Affiliation trigger","Size standards","Control"],"source_families":["13 CFR Part 121 - Small Business Size Regulations","Affiliation and Lending Criteria for SBA Business Loan Programs - Final Rule","SOP 50 10 - Lender and Development Company Loan Programs"],"official_sources":[{"title":"13 CFR Part 121 - Small Business Size Regulations","url":"https://www.ecfr.gov/current/title-13/chapter-I/part-121"},{"title":"Affiliation and Lending Criteria for SBA Business Loan Programs - Final Rule","url":"https://www.federalregister.gov/documents/2023/04/10/2023-07173/affiliation-and-lending-criteria-for-the-sba-business-loan-programs"},{"title":"SOP 50 10 - Lender and Development Company Loan Programs","url":"https://www.sba.gov/sites/default/files/2025-05/SOP%2050%2010%208%20Technical%20Updates%20effective%206.1.2025.docx"}],"related_questions":[{"question":"When does a contractual relationship between two businesses trigger affiliation for size standard calculations?","url":"https://dealroom.so/for-lenders/questions/when-does-a-contractual-relationship-between-two-businesses-trigger-affiliation-for-size-s"},{"question":"How does ownership of options or warrants affect affiliation determination for SBA size standards?","url":"https://dealroom.so/for-lenders/questions/how-does-ownership-of-options-or-warrants-affect-affiliation-determination-for-sba-size-st"},{"question":"What are the size standard requirements for a business applying for a 7(a) loan if it operates internationally?","url":"https://dealroom.so/for-lenders/questions/what-are-the-size-standard-requirements-for-a-business-applying-for-a-7-a-loan-if-it-opera"},{"question":"What specific scenarios involving shared directors, officers, or key employees constitute 'common management' triggering affiliation for SBA size determination?","url":"https://dealroom.so/for-lenders/questions/what-specific-scenarios-involving-shared-directors-officers-or-key-employees-constitute-co"},{"question":"Under what conditions does a shared economic interest trigger affiliation for SBA size standard purposes?","url":"https://dealroom.so/for-lenders/questions/under-what-conditions-does-a-shared-economic-interest-trigger-affiliation-for-sba-size-sta"},{"question":"How does the 'totality of the circumstances' rule apply when determining affiliation for SBA size standards?","url":"https://dealroom.so/for-lenders/questions/how-does-the-totality-of-the-circumstances-rule-apply-when-determining-affiliation-for-sba"}],"related_terms":[{"term":"Key employees","url":"https://dealroom.so/glossary/key-employees"},{"term":"Officers","url":"https://dealroom.so/glossary/officers"},{"term":"SBA size determination","url":"https://dealroom.so/glossary/sba-size-determination"},{"term":"SBA size standard","url":"https://dealroom.so/glossary/sba-size-standard"},{"term":"Under-Collateralized","url":"https://dealroom.so/glossary/under-collateralized"},{"term":"Affiliated businesses","url":"https://dealroom.so/glossary/affiliated-businesses"}],"related_tools":[{"name":"SBA 7(a) payment & fee calculator","url":"https://dealroom.so/sba-7a/calculator"},{"name":"Find an active SBA 7(a) lender","url":"https://dealroom.so/lenders"}],"data_freshness":{"last_reviewed":"2026-06-13","sba_rule_sources_checked_through":"2026-06-13"},"citation":{"label":"DealRoom.so SBA 7(a) Q&A","url":"https://dealroom.so/for-lenders/questions/how-are-common-officers-or-shared-key-employees-between-businesses-evaluated-for-affiliati","source_type":"DealRoom Q&A"},"caveats":["Grounded in the current SBA rulebook; verify against official sources before relying on it for a live deal.","Not legal, tax, or financial advice and not an approval decision."]}