For SBA lenders
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.
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.
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.
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
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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