SBA published SOP 50 10 8.1 on August 14, 2026, with an October 1, 2026 effective date. This is an upcoming-rule guide as of September 7, not a statement that the new requirements already apply. Confirm the controlling SBA loan-number and approval dates with your lender. Official SOP versions.
| Topic | Before October 1 under Appendix 13 | SOP 8.1 from October 1 |
|---|---|---|
| Structure | Term or revolving | Revolving at origination; term-out provisions apply |
| Manufacturer maximum | $5 million | $5 million |
| Other eligible industries | Manufacturing NAICS 31–33 | Specified wholesale and food-supply categories added; $2 million limit |
| Origination debt coverage | At least 1:1; fully amortizing analysis | At least 1.15:1 business DSC; global DSC at least 1:1 |
| Annual continuation review | At least 1:1; MARC interest-only calculation permitted | At least 1.10:1; fully amortizing calculation |
| Revolving maturity | Up to 20 years; draw period no longer than 10 years | Same maximum; repayment period at least as long as draw period |
Compare the current MARC appendix with Section B, Chapter 3 and the maturity appendix in SOP 8.1. The new origination analysis uses the approved maximum amount and fully amortizing repayment; an interest-only payment estimate is not an underwriting test.
What manufacturers should prepare
- A debt schedule including existing and proposed obligations, with balances, rates and maturity dates.
- Three years of historical financial statements or tax returns and current interim statements, where available.
- Supportable projections when historical performance does not meet the applicable test. Under the new SOP, qualifying projected business coverage is required within one year of disbursement.
- A fully drawn line scenario and amortization analysis, not just interest on the initial draw.
- Inventory and receivable records that support the amount requested and any borrowing-base controls.
Expanded industries do not mean every wholesaler qualifies
The new chapter includes NAICS 42 wholesale, with exclusions for automobile/other motor vehicle merchant wholesalers (423110) and wholesale trade agents/brokers (425120). It also lists NAICS 11 and specified grocery/warehousing codes 445110, 493120 and 493130. Manufacturers remain eligible under primary NAICS 31–33; businesses outside that group should have the lender verify the exact code and other SBA restrictions.
Annual review and use of proceeds
Annual review begins no later than the end of year two. Continuing to revolve depends on financial performance and other program requirements, not simply having paid interest. A line that fails the requirements must amortize; lenders may impose additional prudent controls. Proceeds remain for working capital and eligible working-capital debt refinancing, not fixed assets or buying ownership interests.
Prepare with the manufacturer checklist and keep the fiscal-year fee changes separate from underwriting changes. For general MARC context, see the program guide.
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