For SBA lenders
Short answer
Affiliation is triggered if a trust, or the trustee(s) and its beneficiaries, controls or has the power to control two or more businesses. The SBA looks beyond legal form to actual control.
Under SBA's affiliation rules, entities are affiliated when one controls or has the power to control the other, or a third party (or parties) controls or has the power to control both. For trusts, the SBA considers the power of the trustee to manage the trust's assets and the beneficiaries' ability to remove the trustee or terminate the trust as indicators of control, which can lead to affiliation between businesses held by the trust.
A family trust holds 100% ownership of Business A and 60% ownership of Business B. The same individual serves as trustee for both. Since the trustee controls both businesses, Business A and Business B are affiliated, and their revenues must be combined for SBA size standard purposes.
SOP 50 10 - Lender and Development Company Loan Programs
13 CFR Part 121 - Small Business Size Regulations
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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