Bank Statement Requirements for SBA Small Loans

SBA Procedural Notice Control #5000-876777 brought an end to the SBSS Score use effective March 1, 2026. With that came a new requirement in processing small loans, the requirement to obtain and analyze the two most recent months of

commercial bank activity or statements on the primary operating account

and include them within their credit file. Bank statements are

• Not required for startups that are not currently in operation and

• Not required for a change of ownership if there is no other debt.

The lender is to confirm in the bank statements that the debt payment terms indicated on the Debt Schedule submitted by the borrower match those on bank statements.

What are you looking for in the statements?

In the simplest terms, lenders are to be looking for omissions. Does the applicant have debt payments they have not disclosed? The collected statements should provide enough detail to identify daily, weekly or monthly payments not disclosed on the debt schedule provided by the applicant. Bank statements today provide pretty good detail of transactions but if you are unable to discern between a monthly expense versus a monthly debt payment ask the applicant to clarify.

Although not specifically stated, why not look to see if deposits made to the account are consistent with expected revenues. Lower than expected deposits may be a red flag or just the typical seasonality/cyclicality of the business. Remember, you're responsible for making sound credit decisions.