Big changes to the SBA 7a loan requirements announced last week - https://www.sba.gov/sites/default/files/###-###-#### /Policy%20Notice%20-%20Citizenship%20Requirements%20EO14159%20%28FINAL%###-###-#### %29.pdf. This is their implementation of an executive order (https://www.whitehouse.gov/presidential-actions/2025/01/protecting-the-american-people-against-invasion/).

Going forward the SBA will require lenders to certify that 100% of beneficial owners are citizens of the US, US Nationals or Lawful Permanent Residents. We anticipate the big lenders will push back against this regulatory burden. If this is interpreted and enforced to the letter it's going to change the cap table on deals.