Roughly 1,000 to 1,400 SBA 7(a) change of ownership loans a year will fall under the quality of earnings requirement in SOP 50 10 8.1, based on SBA's own loan level data. In fiscal year 2025 the SBA approved 7,533 change of ownership 7(a) loans, and 1,355 of them were for $2.1 million or more, which is the smallest loan that can finance a $3,000,000 purchase price with the minimum 10 percent equity injection and a seller note. The count is growing quickly: it was 773 in fiscal 2023 and is on pace for about 1,170 in fiscal 2026. Those loans are concentrated in a small number of lenders. The top 25 lenders made 59 percent of them and the top 100 made 86 percent.
The SBA publishes a loan level data set for every 7(a) approval under the Freedom of Information Act. Each record includes the lender, the gross approval amount, the approval date, the industry code, and a business age field that identifies change of ownership loans. We used the data set covering fiscal years 2020 through the first nine months of fiscal 2026 (October 2025 through June 2026).
The SOP threshold is a $3,000,000 business purchase price, not a loan amount, and the data set does not record purchase price. So we approximated it from loan size:
Source: SBA 7(a) FOIA data, approvals by fiscal year. Change of ownership loans are those coded "Change of Ownership" in the SBA business age field.
Three things stand out.
The covered population is roughly one loan in six by count and more than half by dollars. Loans of $2.1 million or more were 18 percent of change of ownership approvals in fiscal 2025 but 53 percent of the dollars approved. The rule is aimed at the larger, riskier end of the market where the SBA guaranty exposure is greatest.
The population has grown 75 percent in two years. Loans of $2.1 million or more went from 773 in fiscal 2023 to 1,355 in fiscal 2025. Change of ownership lending overall grew about 50 percent over the same period, so the mix is shifting toward larger acquisitions.
Most covered loans are between $2.1 million and $5 million. In fiscal 2025, 291 loans were between $2.1 million and $2.5 million, 252 between $2.5 million and $3.0 million, 392 between $3.0 million and $4.0 million, 259 between $4.0 million and $5.0 million, and 161 above $5.0 million (the 7(a) maximum). For most lenders, the typical QoE engagement will be on a business purchased for $3 million to $6 million.
In fiscal 2025, 258 lenders approved at least one change of ownership loan of $2.1 million or more, out of 706 lenders that made any change of ownership loan. Only 58 lenders made five or more, and only 26 made ten or more. The five most active were Live Oak Bank (164), Huntington National Bank (99), First Internet Bank of Indiana (73), GBank (71), and Readycap Lending (40).
The practical consequence is that a few dozen lenders will need a repeatable QoE process with an approved vendor and a standard engagement letter, while a few hundred lenders will encounter the requirement once or twice a year and need a provider they can engage quickly without building a program.
By state of the lender, North Carolina (Live Oak, First Citizens, Truliant), Ohio (Huntington, Fifth Third), California, Indiana, and Texas account for the largest shares, which reflects where the national SBA lenders are headquartered rather than where the businesses are located.
Among fiscal 2025 change of ownership loans of $2.1 million or more, the most common industries were accommodation and food services (271 loans, largely hotels and restaurants), construction (181), retail (224 across the two retail sectors), professional and technical services (105), personal and repair services (101), health care (92), wholesale (81), and manufacturing (121). Hotels, in particular, are a large share of the biggest loans and often involve real estate, which raises allocation questions for the purchase price test.
The count is an estimate, and it is more likely to be low than high:
Taken together, a working planning number for lenders and providers is about 1,000 to 1,400 covered acquisitions a year, with the trend rising.
Most covered lenders will have somewhere between one and a few dozen engagements a year. The cost of the report can be passed to the borrower, financed, and counted toward the equity injection, so the fee is rarely the obstacle. The obstacle is time: the report must be engaged at loan number and delivered before closing, and a slow provider adds weeks to an acquisition that is usually already on a tight timeline. Lenders should choose a provider on turnaround, credit committee defensibility, and a fixed fee they can quote to the borrower on day one.
No. It applies to loans that receive an SBA loan number on or after October 1, 2026.
The trend since fiscal 2023 is up sharply, driven by more acquisitions and larger deal sizes. We will update this analysis each quarter as new FOIA data is released.
Yes. Credex Advisors can provide the count of covered loans for any lender in the data set. Email info@credexadvisors.com.