For SBA lenders
Short answer
Common ownership by an ESOP can trigger affiliation if the ESOP owns a controlling interest (typically 50% or more) in multiple businesses, or if the same individuals (e.g., trustees, plan administrators) control the ESOPs of different businesses.
The SBA applies affiliation rules based on ownership, management, and contractual relationships. If an ESOP has the power to control, or actually controls, more than one entity through its ownership stake or through the individuals managing the ESOP, those entities can be deemed affiliated for size standard purposes.
An ESOP owns 60% of Company A and 70% of Company B. Both companies operate in different industries. For SBA size determination, Company A and Company B would be considered affiliated, and their revenues/employees combined to determine eligibility, regardless of their operational independence.
13 CFR Part 121 - Small Business Size Regulations
SOP 50 10 - Lender and Development Company Loan Programs
SBA Table of Size Standards
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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