For SBA lenders
Short answer
A lender determines affiliation for size purposes by examining the control exercised by the trustee(s) or executor(s) of the trust or estate over the business, or by the beneficiaries themselves.
When a business is owned or controlled by a trust or estate, the SBA will look through the entity to identify the individuals who actually control its operations or assets. If these individuals, or the beneficiaries, also control other businesses, affiliation may be triggered, requiring the combined entities to meet the SBA size standards.
A business is 100% owned by an irrevocable trust. The lender identifies the trustee as an individual who also owns and operates two other businesses. The lender must assess the trustee's control over all three entities to determine if affiliation exists for SBA size standard calculations.
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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