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SBA 7(a) + 504 combined

Two ceilings that
no longer consume each other

The cumulative cap across both programmes went from $5m to $10m on 4 July 2026. The individual caps did not move — a single 7(a) still stops at $5m and the CDC debenture at $5m, or $5.5m on a qualifying public-policy project. This is not a $10m loan. It is two facilities that used to cancel each other out, modelled together.

  • Two programmes, one project504 funds fixed assets and nothing else. 7(a) funds the operating business, working capital and closing. The split is not a preference — it is what each programme is permitted to touch.
  • Three ceilings, not one$5m on a single 7(a), $5m on the debenture, $10m combined. Only the third moved. A structure built on “$10m” as one facility cannot exist.
  • Both sides take an injection10% of the fixed assets on the 504 side and 10% of everything else on the 7(a) side, separately. A stack showing one injection understates the cheque.
  • Fees, one-time and ongoingGuaranty fee on the guaranteed portion at a tiered rate, CDC fees, bank points, and the annual service fees that appear on no settlement statement.
  • Coverage under rate shockOnly the 7(a) is priced on Prime. The debenture fixes when it sells, and the bank first is conventional paper that reprices at its call rather than with the index — so a Prime move hits one piece of this stack directly and the others on their own schedule.
  • Eligibility gatesOccupancy, job creation, the alternative size standard and debt service coverage. Pass or fail, and they fail late.
Combined cap504 splitGuaranty fee tiersOngoing feesBlended rateDSCRRate shockOccupancyJob creationStandby seller noteBalloon and call
Informational only — not financial, tax, legal or SBA eligibility advice. Rates are illustrative and move; caps, eligibility and sequencing follow SBA rules that change. This models Policy Notice 5000-879058 as announced and does not model the Made in America Manufacturing Finance Act, which is pending rather than law. Confirm current terms with a CDC and a 7(a) lender before acting.