# Who does not need to complete SBA Form 159?

**Short answer:** SOP 50 10 8.1, Section A, Chapter 4, Para. D.8 lists seven exceptions, including your accountant for routine statements, the closing attorney, the lender's appraiser and an SBA-reviewed Lender Service Provider.

Canonical page: https://www.sbaexpress.loans/answers/sba-form-159-not-required/
Last checked: 2026-11-08

SOP 50 10 8.1, Section A, Chapter 4, Para. D.8.d (about p. 79) lists who is not an Agent for Form 159 purposes:

- Your accountant, for financial statements prepared in the normal course and unrelated to the loan application
- A state-certified or state-licensed appraiser the lender uses to appraise collateral
- A Lender Service Provider working under an SBA-reviewed agreement
- A Qualified Source the lender uses for an independent business valuation
- An environmental professional the lender uses to assess the collateral
- Any attorney in connection with the SBA loan closing
- A real estate agent earning a commission on a sale of real estate tied to the loan

## Where the line falls

- An accountant who prepares statements specifically for the loan application is covered, and that work must be disclosed (Form 159, p. 1).
- An attorney who does more than closing work can be an Agent. SBA's definition of Agent names attorneys (Para. D.2, citing 13 CFR § 103.1(a)).
- Out-of-pocket closing costs are not reported on Form 159 (Para. C.2.c).

## Lender Service Provider fees

An LSP's pay from the lender is not reported on Form 159, and the lender cannot pass it to you (Para. D.2).

If anyone else is paid to help with your application, expect to sign a Form 159 for that person.

## Sources

- [SOP 50 10 8.1, Sec. A, Ch. 4, Para. D.8.d (about p. 79)](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. A, Ch. 4, Para. D.2, Agents (about p. 72)](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. A, Ch. 4, Para. C.2.c (about p. 69)](https://legacy.sba.gov/sites/default/files/2026-10/SOP%2050%2010%208.1%20Technical%20Policy%20Updates%20effective%20%2010.1.2026.docx)
- [SBA Form 159 (08-21), p. 1](https://legacy.sba.gov/document/sba-form-159-fee-disclosure-compensation-agreement)