# What closing costs can an SBA lender pass on to me?

**Short answer:** A lender may collect necessary out-of-pocket costs, such as filing and recording fees, appraisals and environmental reports, plus hourly legal fees. SOP 50 10 8.1, Section A, Chapter 4, Para. C.2 and 13 CFR § 120.221 set the list.

Canonical page: https://www.sbaexpress.loans/answers/sba-loan-closing-costs/
Last checked: 2026-11-08

SOP 50 10 8.1, Section A, Chapter 4, Para. C.2.c (about p. 69) lets a lender collect necessary out-of-pocket expenses. They must be itemized and kept in the loan file for SBA's review.

## Examples in the SOP

- Filing or recording fees
- Photocopying and delivery charges
- Collateral appraisals and environmental reports obtained under SBA policy
- Other direct charges related to closing

## Legal fees

Legal services must be billed by the hour (13 CFR § 120.221(e)). A licensed attorney must do the work, or someone under an attorney's direct supervision. A lender's in-house counsel can be reimbursed at direct cost with reasonable overhead, but never above the cost of outside counsel.

## Other amounts at closing

- **Upfront guaranty fee:** the lender may pass it to you, and loan proceeds can pay it.
- **Packaging fee:** permitted within SBA's limits.

Out-of-pocket costs do not go on SBA Form 159, but they must be available for SBA's review.

## What to ask for

Get a written list before you close. The lender must itemize fees in writing and tell you that you need not buy unwanted services (Para. C.2.a). Amounts vary by lender, location and collateral. The SOP gives no standard total.

## Sources

- [SOP 50 10 8.1, Sec. A, Ch. 4, Para. C.2.c, Out-of-Pocket Expenses (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)
- [SOP 50 10 8.1, Sec. A, Ch. 4, Para. C.2.a, Packaging Fees (about p. 67)](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 § 120.221(c), Out-of-pocket expenses](https://www.ecfr.gov/current/title-13/section-120.221)
- [13 CFR § 120.221(e), Legal services](https://www.ecfr.gov/current/title-13/section-120.221)