The SBA is going to look at who owns the trust as the ultimate owners of the business, not the beneficiaries. If the owners are foreign born, then it will not qualify. Sorry.

^redacted‌ When you say “who owns the trust,” can you please clarify what you mean in the context of an irrevocable trust? Legally speaking, an irrevocable trust isn’t “owned” in the traditional sense. Once funded, the grantor typically relinquishes ownership; the trustee holds legal title and control of the assets, and the beneficiaries hold the equitable interest. My understanding has been that, for SBA purposes, the analysis often focuses on indirect owners and control, which in many cases points toward the beneficiaries (and sometimes the trustee), rather than the grantor — particularly with properly structured irrevocable trusts. That said, SBA guidance in this area has been evolving. Have you seen an SBA lender or the SBA actually decline a loan where: - the irrevocable trust held <20%, - the trustee was a U.S. citizen, and - all beneficiaries were U.S. citizens, - but the grantor was not? Would be helpful to understand whether this is based on specific credit decisions you’ve seen or more of a general interpretation. Thanks Brad. adding others who may have seen specific cases as well: ^redacted‌ ^redacted‌