For SBA lenders
Short answer
A lender assesses affiliation through shared key employee functions by identifying individuals holding critical operational roles across multiple businesses, even if not formally officers or directors, to determine if they exercise control.
Affiliation can arise when a single individual or group of individuals manages or controls two or more businesses, regardless of ownership percentage. This extends beyond formal titles to those who perform key functions or exert substantial influence over strategic decisions, operations, or resource allocation across entities, indicating potential control.
A lender reviews two businesses with separate owners but discovers the same Chief Operating Officer (COO) and head of sales manage both entities. The lender would evaluate if these shared key employees exercise sufficient control to establish affiliation, requiring the businesses to combine their revenues for size standard determination.
13 CFR Part 121 - Small Business Size Regulations
SOP 50 10 - Lender and Development Company Loan Programs
Affiliation and Lending Criteria for SBA Business Loan Programs - Final Rule
Last checked 2026-06-13. Official sources control — verify before relying on any rule for a live deal.
Last reviewed 2026-06-13 · SBA sources checked through 2026-06-13. DealRoom analysis of public SBA 7(a) lending records (FY2020–present). Grounded in the current SBA rulebook; verify against the official sources above before relying on it for a live deal. Not legal, tax, or financial advice, and not an approval decision.
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