# What does SBA not count as same-institution debt?

**Short answer:** SBA lists three cases in SOP 50 10 8.1, App. 14, Para. A.4.e. They are an interim loan approved within 90 days, an undisbursed construction loan, and a seller's loan paid off in an Initial Acquisition.

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Last checked: 2026-11-08

Appendix 14, Paragraph A.4.e of SOP 50 10 8.1 lists three situations SBA does not treat as refinancing same-institution debt.

## The three carve-outs

1. **Interim loan.** The loan was made for purposes other than real estate construction. The lender must have approved it within 90 days before issuance of a Preferred Lender Program (PLP) loan number. 13 CFR 120.452(a)(2) carries a matching exception.
2. **Undisbursed construction loan.** The debt is a construction loan that has not been disbursed when the PLP loan number is issued.
3. **Seller's loan in an Initial Acquisition.** The seller's loan is being paid off with proceeds of the buyer's loan in an Initial Acquisition change of ownership.

## Why it matters

If a debt falls outside these cases and the lender is the same, the same-institution rules apply. That means a 36-month transcript and the limit on reducing credit exposure through delegated authority.

## Bridge advances

After a loan has an SBA loan number and before disbursement, a lender or its affiliate may make interim advances, also called bridge loans. The 7(a) proceeds may reimburse them, and the lender need not notify SBA (App. 14, Para. A, Interim Advances).

## SBA Express files

The carve-outs refer to a PLP loan number. Appendix 14, Paragraph B.2 applies the general refinancing rules to Express without restating them. Ask your lender how it applies them on an Express file.

## Sources

- [SOP 50 10 8.1, App. 14, Para. A, General Requirements, Para. A.4.e and Interim Advances (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)
- [13 CFR § 120.452](https://www.ecfr.gov/current/title-13/section-120.452)
- [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)