For SBA lenders
Short answer
No, the sunset of the SBSS score does not eliminate the requirement for a credit memo or documented credit analysis for 7(a) Small Loans; lenders must still document their underwriting decision and adherence to prudent lending standards.
While the SBSS score provided an initial eligibility screen, its removal shifts the full responsibility of credit assessment to the lender. This necessitates a comprehensive credit memo that justifies the loan decision based on financial analysis, cash flow, collateral, and character, demonstrating prudent underwriting practices.
A lender approves a $300,000 7(a) Small Loan. Although no SBSS score is required, the credit analyst still prepares a detailed credit memo outlining the borrower's strengths and weaknesses, projections, collateral analysis, and the rationale for approval, aligning with the lender's internal policies and SBA's prudent lending standards.
Sunset of SBSS Score for 7(a) Small Loans
SOP 50 10 - Lender and Development Company Loan Programs
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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