The capital stack
504 finances fixed assets. 7(a) finances everything else. The split below is not a preference — it is what each programme is permitted to fund.
SBA 7(a)Business, working capital and closing · 10.00% variable, 10yr$4.52M
Bank first mortgage — senior lienConventional, no SBA guaranty · 8.75%, 25yr · 50% of fixed assets$2.55M
504 CDC debenture — second lienFixed 6.3% for 25 years · cap $5.00M · 40% of fixed assets$2.04M
Seller note on full standbyCounts toward the injection · no principal or interest during the SBA loan$251K
Borrower cash$510K at 10% on fixed assets, $251K on the 7(a) side$761K
Total project$10.12M
$6.56M
SBA exposure · cap $10.0M
$94K
Total monthly · 8.82% blended
1.48×
DSCR after owner salary
Both sides need an injection. The 504 takes 10% on the fixed assets and the 7(a) takes 10% on everything else — $1.01M in total, of which $761K is cash. A stack that shows only the 504 injection understates the cheque by $502K.
Only two of those four lines count against the $10m ceiling. The 7(a) balance and the CDC debenture are SBA exposure. The bank first mortgage is conventional lending and the equity is yours — neither touches the cap.
The $5m cap binds the debenture, not the project. At 40% the 504 side alone supports a fixed-asset project of about $12.50M before the debenture caps out — the bank first mortgage carries the rest and never touches the SBA ceiling.
What changed on 4 July 2026
Before
$5.00M
One $5m ceiling across both programmes. $5.00M of 7(a) left nothing for the debenture, whatever the project needed.
From 4 July 2026
$6.56M
Two independent $5m ceilings. $4.52M of 7(a) and $2.04M of debenture, side by side on one project.
$1.56M of SBA capacity this deal could not have reached before. The same project, the same underwriting — the ceiling was the only thing in the way.
Both programmes are within their individual caps and the combined exposure is under $10m.
Sequencing is not settled. The SBA framed this as borrowers who secure a 7(a) first then accessing 504 capacity. Whether an existing 7(a) borrower can reach the new 504 capacity retroactively, and how quickly lenders update their credit policies, are both open. Confirm with the CDC and the 7(a) lender before structuring around it.