For SBA lenders
Short answer
If a trust owns 20% or more of the business, the trustee(s) must meet the same citizenship or lawful permanent resident requirements as individual owners.
When a trust is an owner, the SBA "looks through" the trust to identify the individuals who ultimately control it. For revocable trusts, this typically means the grantor. For other trusts, it's the trustee(s) and potentially beneficiaries. These individuals must meet the U.S. citizenship or lawful permanent resident status requirements.
A business seeking a 7(a) loan is 30% owned by a revocable trust. The trustee, who is also the grantor of the trust, is a U.S. citizen. The lender verifies the trustee's citizenship and ensures they are a U.S. citizen or lawful permanent resident.
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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