Lender Resources · SBA 7(a) and 504

SBA 7(a), SBA 504, USDA B&I and FSA Guaranteed Loans Compared

Last reviewed November 2026

Each government guaranteed loan program fits a different borrower and project. This table gives community bankers a quick side-by-side view, using figures from the official sources below as of November 2026.

At a glance

SBA 7(a)SBA 504USDA B&I (OneRD)FSA guaranteed farm loans
RulesSOP 50 10 8.1; 13 CFR 120SOP 50 10 8.1, Section C; 13 CFR 1207 CFR 50017 CFR 762; FSA Handbook 2-FLP
Who lendsThe bank, with an SBA guarantyThe bank (first lien) plus a CDC debenture (second lien)The bank, with a USDA loan note guaranteeThe bank, with an FSA guarantee
Typical usesWorking capital, equipment, real estate, business acquisitions, refinancingOwner-occupied real estate and long-life equipmentRural business projects: real estate, equipment, working capital, acquisitions, refinancingFarm ownership and farm operating loans and lines
SizeUp to $5 million; SBA Express up to $500,000; 7(a) Small up to $350,000Debenture up to $5 million per business; $5.5 million per project for small manufacturers and energy projectsUp to $25 million per borrower (more only for certain rural cooperatives with the Secretary's approval)Combined guaranteed limit of $2,558,000 for FY 2027, adjusted each year
Guarantee85% for loans of $150,000 or less, 75% above; 50% on SBA Express; SBA's share capped at $3.75 millionDebenture guaranteed 100% by SBA; the bank's loan is not guaranteedSet each fiscal year. FY 2026: 85% for loans under $5 million, 80% from $5 million to $25 millionUp to 90%; 95% in listed cases such as qualified beginning farmers
Equity10% for start-ups and most changes of ownership; otherwise the lender's analysis10% minimum; 15% or 20% for new businesses and special purpose propertyAs set in the conditional commitment and shown on the closing balance sheetBased on the lender's credit analysis and the conditional commitment
Owner guarantiesUnlimited guaranty from 20%+ ownersUnlimited guaranty from 20%+ owners on the 504 loanGuaranty from 20%+ owners, at least their ownership share of the guaranteed amountEntity members sign the note individually unless FSA waives it for owners under 10%
Who closesThe bank and its counselThe bank closes its loans; the CDC and CDC counsel close the 504 loan and debentureThe bank closes, then certifies conditions for the loan note guaranteeThe bank closes, then submits its certification and closing report
FeesUpfront and annual SBA fees set each fiscal yearCDC and debenture fees, often financedFY 2026: 3% guarantee fee and 0.55% annual retention fee for standard loansGuarantee fee set by FSA; none on certain loans

Choosing among them

  • Owner-occupied real estate with a long fixed-rate need often fits 504, where the bank keeps a first lien on about half the project.
  • Business acquisitions, working capital and mixed uses of proceeds usually point to 7(a).
  • Larger rural projects, including those above SBA limits, may fit USDA B&I if the project is in an eligible rural area and the borrower meets the program's tests.
  • Agricultural producers buying land or financing operations look to FSA guaranteed loans.
  • Some projects combine programs, such as a 7(a) loan alongside a 504 project. SBA's rules on combined limits and the order of approvals apply.

Timing note for USDA B&I

USDA announced a pause, beginning Friday, November 20, 2026, at 5 p.m. Eastern, on new B&I applications and servicing requests until a new portal launches in 2027. Check USDA's OneRD Guarantee page for the current status before planning a B&I closing or servicing request. Banks with B&I projects in the pipeline should also talk with the USDA state office about timing.

This guide is general information for lenders and borrowers, not legal advice. Reading it does not create an attorney-client relationship. SBA, USDA and FSA rules change often, so confirm the current program requirements and the terms of your loan's authorization or commitment before relying on it. Kennedy Sutherland LLP is a private law firm. It is not affiliated with or endorsed by SBA, USDA or FSA.

Sources

Sources checked November 2026.

Closing an SBA or USDA loan?

Kennedy Sutherland LLP has closed loans for lenders under the SBA 7(a), SBA 504, USDA Business and Industry, REAP and FSA guaranteed loan programs. The firm offers lender counsel for these closings, CDC-side 504 debenture closing work, and conventional commercial loans. Fixed-fee quotes are available for SBA and USDA loan closings. Initial consultations for lenders are free.

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