For SBA lenders
Short answer
Lenders must verify foreign-sourced equity injections with documentation demonstrating the funds were available to the borrower for at least 90 days or through acceptable transaction records to a U.S. account.
The SBA requires a 90-day seasoning period for equity injection funds to ensure they are truly from the borrower's own resources and not short-term debt. For foreign accounts, lenders must obtain statements or verifiable transaction records, ideally tracing funds through a U.S. correspondent bank or a U.S. branch of the foreign bank.
A borrower provides a statement from their personal savings account in Canada, showing $100,000 for equity injection. The lender requests 90 days of statements, a swift transfer record to a U.S. account, and a source of funds explanation to ensure compliance.
Insider move
Lenders are concerned with Anti-Money Laundering (AML) and Know Your Customer (KYC) compliance, verifying the legitimacy and source of funds, identifying potential undisclosed third-party debt, and ensuring the funds are not subject to quick repatriation.
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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