Recent SBA guidance has expanded the reach and usability of the International Trade Loan (ITL) program, particularly for manufacturers and businesses operating in the food supply chain. SBA issued Policy Notice 5000-877629 on 4/2/26 with an effective date of 5/1/26 and offered training on the 7(a) Connect Call 4/21/26.
In addition, WBD staff attended NAGGL’s webinar on 4/22/26 to understand the ITL program’s new eligibility pathways, fee waivers, and underwriting standards that lenders should consider as they evaluate opportunities under this program.
Broader Eligibility and Industry Expansion
The ITL program continues to support businesses engaged in Export Development as well as those adversely affected by import competition. Notably, the SBA has expanded this Adverse Impact category to include manufacturers and businesses within the food supply chain. Eligible industries are specifically identified by NAICS codes listed in the SBA Policy Notice, relieving borrowers within those codes from having to document adverse impact.
For Export Development ITLs, borrowers are still required to provide an Export Business Plan, and loan proceeds must be tied to increasing export sales or entering new export markets. Lenders must also confirm export destinations against the Ex‑Im Bank Country Limitation Schedule.
Both types of ITL have a statutory requirement to improve the Applicant’s competitive position. The lender is required to explain how the proposed financing will positively impact the business, which would be addressed in the credit memo when outlining the business purpose and expected benefits of the loan.
Program Parameters – Differences between ITL and 7(a) are shown in bold below
- Maximum loan amount of $5 million – Same as 7(a)
- 90% SBA guaranty, with maximum guaranteed portion of $4.5 million – 7(a) is 85% guaranty on loans up to $150,000 or 75% on larger loans, with maximum of $3.75 million
- Borrower’s up-front guaranty fee and lender’s on-going servicing fee are based on guaranteed portion – ITL will have higher fees than 7(a)
- SBA currently waiving borrower’s up-front guaranty fee on loans up to $950,000 for manufacturers (NAICS starting 31, 32 or 33) – Same as 7(a)
- Maximum interest rates and allowable Base Rates – Same as 7(a), including variable options tied to WSJ Prime, 30‑day SOFR, 5- or 10-year Treasury
- Minimum 10% equity injection when financing a start-up (operating less than 12 months) or complete change of ownership – Same as 7(a)
Eligible Uses of Proceeds for ITL
- Purchase, construct, renovate, modernize, improve or expand building (including leaseholds) or equipment to be used in the U.S. to produce goods or services – 7(a) also allows Inventory
- Working capital capped at $2 million – 7(a) has no cap on Working Capital
- Debt refinance that meets eligibility requirements outlined in SOP 50 10 8
- Export Development ITLs allow only complete changes of ownership – Partner buyouts and partial changes of ownership are not eligible
- Adverse Impact ITLs allow 3 options for change of ownership:
- Expansion where borrower has been operating a business in the same 6-digit NAICS code at least 2 years
- Partial change of ownership with at least 1 original owner remaining
- Purchase by current employees including ESOP transactions
Collateral Requirements
- 1st lien on assets financed with loan, however SBA may allow 2nd lien with exception to policy approved by 7aDelegatedLoanApps@sba.gov (for PLP lenders) or 7aLoanProgram@sba.gov (for GP lenders)
- If loan is not “fully secured,” ITL does not require mortgages on real estate with equity of at least 25% owned by any Co-Borrowers or 20% or more owners of Applicant as required on 7(a) loans over $350,000
