# Do two SBA loans approved within 90 days count as one for fees?

**Short answer:** Yes. SBA counts 7(a) loans approved within 90 days of each other as one loan for the guaranty percentage and upfront fee. The rule covers affiliates and different lenders, under SBA Information Notice 5000-881797.

Canonical page: https://www.sbaexpress.loans/answers/sba-guaranty-fee-loans-within-90-days/
Last checked: 2026-11-08

SBA Information Notice 5000-881797 (p. 2) and SOP 50 10 8.1, Section A, Chapter 4, Para. C.1.a.ii (about p. 63) set the rule:

- two or more 7(a) loans approved within 90 days of each other count as one loan for the guaranty percentage and upfront fee

It covers loans with maturities over 12 months. It includes affiliates and loans from different lenders.

## How the later fee is calculated

The later loan's fee equals the fee on the combined amount, less the fee on the first loan. It is never negative.

SBA's example in Appendix 16, Para. A.1 (p. 387) is a $140,000 loan at 85%, then a $50,000 loan. The combined guaranty cannot exceed 75% of $190,000, or $142,500. The second loan's guaranty falls to 47%.

Applying the FY2027 fees to that example:

- First loan: 2% of $119,000 is $2,380.
- Combined: 3% of $142,500 is $4,275.
- Second loan: $4,275 less $2,380 is $1,895.

## Exceptions

- A short-term and a long-term loan are combined for the guaranty percentage only.
- Working Capital Pilot (WCP) and Export Working Capital Program (EWCP) loans are combined for the guaranty percentage and manufacturer fee relief. Their fees follow maturity.
- The Annual Service Fee is set per loan and never combined.

## Splitting loans

Lenders may not split loans to avoid fees (notice, p. 2). Two loans inside 90 days are tested together against the $150,000 and $700,000 fee lines.

## Sources

- [SBA Information Notice 5000-881797, FY2027 7(a) fees, p. 2 (effective October 1, 2026)](https://legacy.sba.gov/document/information-notice-5000-881797-fy-2027-7a-program-fees)
- [SOP 50 10 8.1, Sec. A, Ch. 4, Para. C.1.a.ii (about p. 63)](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, App. 16, Para. A.1 (p. 387)](https://legacy.sba.gov/sites/default/files/2026-10/SOP%2050%2010%208.1%20Technical%20Policy%20Updates%20effective%20%2010.1.2026.docx)