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U.S. Small Business Administration

Effective May 1, 2026 for ITL manufacturers

The programs, in SBA’s own words and terms

Four products matter for this proposed factory: the 90% Made in America / International Trade Loan, the 504 plant loan, MARC revolving credit for manufacturers, and the Working Capital Pilot SBA is marketing to homebuilders. They are not interchangeable.

“America needs more housing, and manufactured housing is part of the solution.”
U.S. Department of Housing and Urban Development, Proposed rule announcement — manufactured housing · June 12, 2026 · HUD: expanding the definition of manufactured housing
“Layers of unnecessary regulatory barriers, slow permitting processes, and onerous mandates at all levels of government have delayed construction, restricted development, and driven up the costs of new housing. These constraints have made housing less affordable for many Americans. It is the policy of my Administration to reduce regulatory barriers to building homes and to steward taxpayer dollars in a manner that promotes housing affordability.”
Donald J. Trump, President of the United States · March 13, 2026 · Executive Order 14394: Removing Regulatory Barriers to Affordable Home Construction
SBA 7(a) • 90% guarantyprimary
7(a) International Trade Loan — “Made in America Loan Guarantee”
Live for manufacturers as of May 1, 2026. Guaranty: 90% (max SBA exposure $4.5 million). Maximum: $5 million gross loan.

Why this could fit a formed manufacturer

This is the 90% manufacturer guarantee. It is not a separate grant. It is the International Trade Loan inside 7(a). On March 31, 2026 SBA branded the expansion as the Made in America Loan Guarantee. Policy Notice 5000-877629 tells lenders that manufacturing NAICS sectors 31–33 are being adversely affected by international trade, so a qualifying ICF manufacturer does not have to separately prove import injury.

Eligible uses SBA lists

  • Acquire, construct, renovate, modernize, improve, or expand U.S. facilities and equipment used to produce goods
  • Working capital, capped at $2 million inside an ITL
  • Eligible debt refinance (SOP 50 10 8 rules still apply)

How to apply

Apply through an SBA 7(a) lender, not on sba.gov as a direct loan. Ask specifically for an International Trade Loan / Made in America guaranty. SBA Finance Managers and Lender Match can introduce lenders. Pairing with MARC or the Working Capital Pilot is explicitly contemplated in SBA’s March 31, 2026 announcement.

Program terms

Maximum loan
$5,000,000
SBA guaranty
90% (up to $4.5 million guaranteed)
Standard 7(a) comparison
75% guaranty on loans over $150,000; $3.75 million max SBA exposure
Working capital inside ITL
Maximum $2,000,000
Eligible NAICS
Sectors 31–33 (manufacturing). A formed manufacturer must stay in this range.
Eligibility theory
Export expansion OR adversely affected by import competition. Manufacturers may rely on SBA’s sector determination.
Who decides credit
Participating 7(a) lender (PLP delegated or SBA LGPC)
Required borrower form
SBA Form 1919

Do not miss

  • The 90% figure protects the lender, not the borrower. You still repay 100% of the note.
  • ITL proceeds cannot be used for inventory as a stand-alone purpose the way a standard 7(a) can. Working capital is allowed but capped at $2 million.
  • FY2026 manufacturer upfront-fee waiver applies only to 7(a) manufacturing loans of $950,000 or less. A $5 million ITL pays standard guaranty fees.
  • SBA Form 1919 requires the NAICS on the application to match the business activity code on IRS filings when applicable.

Sources: SBA, Made in America Loan Guarantee (Mar. 31, 2026); SBA Policy Notice 5000-877629; SBA 7(a) terms, conditions, and eligibility

SBA 504 • 100% guaranty on the debenturestack
CDC/504 Loan — plant, land, and long-life equipment
Standing program; manufacturer cap $5.5 million per project. Guaranty: SBA guarantees 100% of the CDC debenture sold to investors. Maximum: $5.5 million SBA portion per manufacturing project.

Why this could fit a formed manufacturer

504 is how you finance a factory without putting a $5 million 7(a) against real estate. The typical stack is 50% bank first mortgage, 40% SBA/CDC, 10% borrower equity. Manufacturers (primary NAICS 31–33, U.S. production) get the higher $5.5 million debenture. That is how a $5 million ask becomes a $12–14 million plant project.

Eligible uses SBA lists

  • Purchase or construct owner-occupied industrial buildings and land
  • Fit out a leased bay as an ICF production line
  • Long-term machinery and equipment with useful life of at least 10 years, including manufacturing AI-supported equipment under current SBA 504 descriptions

How to apply

Apply through a Certified Development Company (CDC) plus a first-mortgage bank. SBA Lender Match and the district office can name active CDCs. Package 504 real estate separately from the ITL equipment/working-capital loan.

Program terms

SBA / CDC share
Up to 40% of eligible project costs
Bank share
About 50%
Borrower equity
Minimum 10% (15–20% if startup or special-purpose building)
Manufacturer SBA cap
$5.5 million per eligible project
Implied max project at 40%
About $13.75 million if the full $5.5 million debenture is used
Job test (historical)
One job created or retained per $120,000 of SBA debenture for small manufacturers (SBA has updated the dollar test over time; confirm current 13 CFR 120.829 figure with the CDC)
FY2026 fee waiver
0% 504 upfront fee and 0% annual service fee for manufacturing loans approved Oct 1, 2025–Sep 30, 2026

Do not miss

  • As of September 10, 2026 the FY2026 504 manufacturer fee waiver has 20 days left and requires SBA approval — not just an application — by September 30, 2026. A brand-new factory package is unlikely to clear that window. Do not stall the ITL to chase an expiring waiver.
  • 504 does not fund inventory, payroll, or module work-in-process. That is 7(a) / MARC / WCP.
  • Owner-occupancy rules apply. This is not a spec housing-development loan.

Sources: SBA 504 loans; SBA manufacturer fee waiver FY2026

SBA 7(a) • manufacturer-onlystack
7(a) Manufacturers’ Access to Revolving Credit (MARC)
Launched September 3, 2025; SOP 50 10 Appendix 13. Guaranty: 85% ≤ $150,000; 75% above $150,000. Maximum: $5 million.

Why this could fit a formed manufacturer

MARC is SBA’s first loan product built only for manufacturers (NAICS 31–33). It is working capital: steel coil, fasteners, module WIP, deposits on jobs. SBA says MARC can sit next to 7(a) and 504. It does not replace the 90% ITL for equipment.

Eligible uses SBA lists

  • Any short-term manufacturing working-capital need
  • Inventory and new production jobs
  • Revolving line leveraging equity in existing plant or equipment

How to apply

Same 7(a) lender channel. Ask whether the lender is trained on MARC (SBA posted lender training September 12, 2025). Use MARC for the revolving steel/WIP book after the ITL funds the line.

Program terms

Maximum loan
$5,000,000 (applicant + affiliates)
Guaranty
75% on a $5 million line (standard 7(a) percentages)
Revolving maturity
Up to 20 years (10 years revolving, then term-out)
Term loan maturity
Up to 10 years
Max rate over $350,000
Cannot exceed base rate + 3.0%
Equity injection
No minimum equity injection based on use of proceeds (unlike some 7(a) structures)
Collateral
Lien on business assets; vehicles and trading assets excepted in SBA’s MARC summary

Do not miss

  • Combined 7(a) exposure still matters. You cannot stack a $5 million ITL and a $5 million MARC as if they were unlimited. The statutory 7(a) guaranteed-balance cap is $3.75 million generally and $4.5 million for a qualifying international-trade / export loan.
  • Primary NAICS must start with 31, 32, or 33. A construction code on the tax return knocks this out.

Sources: SBA MARC launch (Sep. 3, 2025); SOP 50 10 Appendix 13 — MARC

SBA 7(a) pilot • through July 31, 2027 unless extendedadjacent
7(a) Working Capital Pilot — homebuilder / project lines
SBA highlighted this for U.S. homebuilders on March 3, 2026. Guaranty: 85% ≤ $150,000; 75% above $150,000. Maximum: $5 million project-based line.

Why this could fit a formed manufacturer

SBA highlighted WCP for homebuilders as project-based financing of eligible direct costs — labor, materials, subcontractors — at up to 100%, subject to program rules and lender underwriting. A proposed manufacturer that only sells factory systems is not a WCP homebuilder. WCP belongs on a licensed construction affiliate that actually performs residential projects — not on Paparazzi Marketing Group LLC, and not on day one of a factory.

Eligible uses SBA lists

  • Up to 100% of direct project costs (labor, materials, subcontractors)
  • Residential developments, including Opportunity Zones
  • Revolving or non-revolving, single- or multi-phase contracts

How to apply

Participating 7(a) lenders. SBA told builders to email 7aWCP@sba.gov for a working-capital specialist.

Program terms

Maximum line
$5,000,000
Advance rate
Up to 100% of direct project costs (SBA homebuilder announcement)
Term
Up to 60 months
Guaranty fee
0.25% first 12 months; 0.275% each additional 12-month period
Specialist inbox
7aWCP@sba.gov

Do not miss

  • WCP is a monitored line (transaction-based or asset-based). It is not a term loan to buy a factory.
  • If the factory only sells systems to other developers, WCP may fit the developer better than the manufacturer. If a later licensed affiliate sets modules on contracted projects, WCP could become a second tool for that affiliate — after 12 months of operations. Paparazzi Marketing Group LLC is marketing, not a homebuilder.
  • Pilot currently scheduled through July 31, 2027.

Sources: SBA homebuilder WCP announcement (Mar. 3, 2026)

Eligibility that sits under every 7(a) / 504

Form 1919 makes the applicant certify compliance with 13 CFR §§ 120.100, 120.110, 121.301 and related rules, including 51% U.S. citizen or LPR ownership and control.

For-profit U.S. small business
A formed manufacturer must operate for profit in the United States and fall under the SBA size standard for its primary NAICS. Other concrete product manufacturing (327390) is an employee-based size standard. Affiliates count, including Paparazzi Marketing Group LLC.
Ownership and control
The applicant must be at least 51% owned and controlled by U.S. citizens or lawful permanent residents. Form 1919 requires that certification.
Personal guaranty
Every individual owning 20% or more generally signs an unlimited personal guaranty (13 CFR 120.160(a); SBA Form 148). Form 413 personal financial statements are required for those owners.
Taxes current
Form 1919 certifications require the business to be current on federal, state, and local taxes. Two years of filed returns is a start, not a substitute for being paid up.
Ability to repay
Lenders underwrite cash flow, not the political headline. A $5 million ten-year note at roughly Prime+3 needs on the order of $750,000–$800,000 a year in debt service and about 1.25x coverage. Offtake contracts, existing steel revenue, and owner liquidity have to support that.
Collateral
SBA does not decline solely for weak collateral on many 7(a) loans, but a $5 million manufacturing file will still take liens on acquired assets, plant, and business assets. Life insurance on the principal is commonly required.