For SBA lenders
Short answer
Lenders must verify the SDIRA structure complies with IRS rules (ROBS plan), that funds are not pledged as collateral for the 7(a) loan, and that specific documentation is provided.
Using retirement funds via a Rollover for Business Start-ups (ROBS) plan is a complex equity injection method. Lenders must confirm the ROBS plan is legally established and compliant with IRS and DOL regulations. The SDIRA funds, structured as a loan to the operating company (borrower), must not be secured by any collateral that also secures the SBA loan. Documentation includes the ROBS plan, loan agreement from SDIRA to C-corp, and proof of funds transfer.
A borrower uses $100,000 from their SDIRA, structured through a ROBS plan, for equity injection. The lender requires the ROBS plan documents, the loan agreement between the C-corp and the SDIRA, and bank statements showing the transfer of funds. The lender also verifies that the C-corp's note to the SDIRA is not collateralized by assets pledged to the SBA loan.
Insider move
Lenders must exercise extreme caution with ROBS structures due to their complexity and potential for IRS/DOL violations. Non-compliance can lead to severe penalties for the borrower and jeopardize the SBA guaranty. Thorough legal review of the ROBS plan is essential.
13 CFR Part 120 — Business Loans
Office of the Federal Register · Federal regulation
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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