For SBA lenders
Short answer
It depends. If the trust is a revocable grantor trust, the grantor's eligibility (citizenship/LPR) is key. If it's an irrevocable trust, the trustee and beneficiaries' citizenship/LPR status and control must be evaluated.
For trusts, the SBA 'looks through' the entity to the individuals who own or control the business. For revocable trusts, the grantor is considered the owner. For irrevocable trusts, all trustees and those owning 20% or more of the beneficial interest must generally be U.S. citizens or lawful permanent residents (LPRs) residing in the U.S. A foreign national trustee could be an issue if they are considered the controlling party and do not meet the residency requirements.
A business is owned by an irrevocable trust. The primary trustee is a foreign national who lives abroad, while the beneficiaries are U.S. citizens. The lender would likely find the business ineligible because the foreign national trustee, as a controlling party, does not meet the SBA's citizenship and residency requirements.
SOP 50 10 - Lender and Development Company Loan Programs
Policy Notice 5000-876441 - Citizenship and Residency Requirements
Procedural Notice 5000-876626 - Revised Applicant Ownership, Citizenship and Residency
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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