# What does a lender need to refinance debt with an SBA loan?

**Short answer:** A written analysis of why the debt is being replaced, copies of the notes and security documents, and payment history. SBA Terms and Conditions must identify the refinancing and itemize creditors paid $10,000 or more (SOP 50 10 8.1, App. 14, Para. A; App. 20).

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Last checked: 2026-11-08

The lender needs a written analysis, supporting documents for each debt, and specific entries in the SBA Terms and Conditions. Appendix 14, Paragraph A of SOP 50 10 8.1 lists them.

## The written analysis covers

1. The reason the debt was incurred
2. The factors showing the refinance will not pay a creditor in a position to sustain a loss
3. The reason for restructuring the debt
4. How the new loan will improve your financial condition
5. An itemization of debts where a creditor will receive $10,000 or more, plus the loan number and amount of any SBA debt
6. Why the debt no longer meets your needs

## Documents to gather

- Notes being refinanced, security agreements and leases
- The most recent credit card statement, when applicable, showing the holder and balance
- Transcripts for the most recent 12 months, or other proof of the debt (App. 20, Para. A)

On non-delegated loans, the lender submits these to SBA with the application. On delegated loans, it keeps them in the file.

## 7(a) Small and SBA Express

On these loans, all general refinancing requirements apply, a written credit memorandum is not required, and supporting documentation must be retained (App. 14, Para. B.2).

## What you certify

You certify before disbursement that the debt was used exclusively for the business, including any credit card, home equity line of credit (HELOC) or balance sheet debt (Sec. B, Ch. 6, Para. D.8).

## Sources

- [SOP 50 10 8.1, App. 14, Para. A, General Requirements, written analysis, documentation and SBA Terms and Conditions (p. 355)](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. 20, Para. A, Debt Refinancing (p. 416)](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. 14, Para. B, Program-Specific Requirements, Para. B.2 (p. 358)](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. B, Ch. 6, Para. D.8, Borrower Certifications (Para. D begins p. 207)](https://legacy.sba.gov/sites/default/files/2026-10/SOP%2050%2010%208.1%20Technical%20Policy%20Updates%20effective%20%2010.1.2026.docx)