# What limits a 504 refinance that creates no new jobs?

**Short answer:** Your headcount does. The 504 loan cannot exceed employees times $95,000 under SOP 50 10 8.1, Sec. C, Ch. 1, Para. C.10. 13 CFR § 120.882(g)(15) still prints $90,000, so ask your Certified Development Company (CDC) which figure applies.

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Last checked: 2026-11-08

Your headcount caps the loan. A no-expansion refinance can go forward without meeting the job objectives. The 504 loan then may not exceed your employee count times $95,000. Source: SOP 50 10 8.1, Sec. C, Ch. 1, Para. C.10 (Para. C begins p. 226).

## The $90,000 figure

13 CFR § 120.882(g)(15) still says $90,000. Its example is 47.5 employees times $90,000, or $4,275,000. The SOP uses the same headcount at $95,000, or $4,512,500. Ask your CDC which figure SBA will apply to your file.

## How employees are counted

Take full-time employees on the application date. Add part-time employees multiplied by their average weekly hours divided by 40. Thirty full-time employees and 35 part-time employees at 20 hours a week count as 47.5.

## When the cap applies

The cap applies only when the project does not meet the job objective or other economic development goals (Para. C.10). The job standard is one job per $95,000 guaranteed, or one per $150,000 for small manufacturers and energy public policy projects.

## Limits that still apply

- The 504 debenture limit of $5,000,000 for standard projects (Para. D.1).
- The 90% loan-to-value limit on the refinancing project (Para. C.10).
- Your business must have operated for the full two years before applying.

## Sources

- [SOP 50 10 8.1, Sec. C, Ch. 1, Para. C.10 (Para. C begins p. 226)](https://legacy.sba.gov/sites/default/files/2026-10/SOP%2050%2010%208.1%20Technical%20Policy%20Updates%20effective%20%2010.1.2026.docx)
- [SOP 50 10 8.1, Sec. C, Ch. 1, Para. D.1 (p. 241)](https://legacy.sba.gov/sites/default/files/2026-10/SOP%2050%2010%208.1%20Technical%20Policy%20Updates%20effective%20%2010.1.2026.docx)
- [13 CFR § 120.882(g)(15)](https://www.ecfr.gov/current/title-13/section-120.882)