For SBA lenders
Short answer
Common management triggers affiliation for SBA size determination when identical or overlapping officers, directors, or key employees control the management and daily business operations of two or more entities. This common control leads to aggregating the entities' revenues or employees for size purposes.
SBA rules dictate that entities are affiliated if they have common management, meaning one or more individuals or entities control the management of two or more businesses. This typically occurs when the same person or group of people serve as officers, directors, or key employees (those who have critical influence over the strategic direction or operational decisions) in multiple businesses. The SBA looks beyond titles to actual influence and control. When common management is established, all businesses under that common management are aggregated to determine compliance with SBA size standards.
A lender evaluates a 7(a) loan application for 'Company A.' During due diligence, they discover the same individual serves as CEO for Company A and also for 'Company B,' which operates in a similar industry. This common CEO role, exercising control over both entities, triggers affiliation, requiring the lender to combine the revenues of Company A and Company B for size standard determination.
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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