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SBA Agency Financial Report, Fiscal Year 2025

Summary

This is the U.S. Small Business Administration's Agency Financial Report for FY 2025, covering October 1, 2024 through September 30, 2025. The message from the Administrator, dated January 21, 2026, closes with the name Kelly Loeffler, 28th Administrator. It says the agency guaranteed 85,000 loans through its 7(a) and 504 programs, totaling $44.8 billion, and delivered over $6 billion in disaster assistance supporting more than 51,000 disaster loans. It also says the FY25 audit by KPMG resulted in a 50% reduction in one year of material weaknesses, significant deficiencies and audit recommendations. A highlights table (dollars in thousands, unaudited) lists a principal program portfolio of $500,214,152 and total assets of $248,410,141.

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“SBA Agency Financial Report, Fiscal Year 2025.” Original at legacy.sba.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/sba-agency-financial-report-fiscal-year-2025-6f3d834e14/, SHA-256 4f798a9df9bcf24f7060d02e66f8c1aae600266d16a941fa61438f210b652a1d.

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              Fiscal Year 2025




Agency Financial
         Report
                                                                                                   Introduction (Unaudited)



  About This Report
  The U.S. Small Business Administration’s Agency Financial Report (AFR) for FY 2025 provides an over-
  view of the Agency’s financial and performance data to help Congress, the President, and the public
  assess the SBA’s stewardship over the resources entrusted to it. The AFR is the first of two required
  annual reports for federal agencies. The FY 2025 Annual Performance Report (APR) is the other re-
  port and is part of the FY 2027 Congressional Budget Justification (CBJ). The CBJ/APR is scheduled
  for publication in early 2026. The reports can be found at: www.sba.gov/performance.

  FY 2025 Highlights
  (Dollars in Thousands)

                                                                                   FY 2025 (unaudited)

      Principal Program Portfolio1                                                   $         500,214,152

      Total Assets                                                                   $         248,410,141
      Total Liabilities                                                              $         255,879,428
      Total Net Position                                                             $           (7,469,287)
      Total Net Cost of Operations                                                   $           12,124,418
      Total Budgetary Resources                                                      $           48,815,506




  1 The total portfolio consists of guaranteed business loans outstanding, guaranteed debentures,

     direct business loans, and direct disaster loans. The data include all performing loans and defaulted
     loans that have not been charged off.



U.S. Small Business Administration                                             Agency Financial Report Fiscal Year 2025   2
                                                                                                    Introduction (Unaudited)



  For More Information
  Information about the SBA’s programs is available at: www.sba.gov

  The SBA’s plans and reports are available at: www.sba.gov/performance

  Para información acerca de los programas de la SBA: www.sba.gov - “Translate” - “Select Language”

  Questions and comments regarding the content, presentation, and usefulness of this report are wel-
  come and may be addressed to: performance.management@sba.gov


  OR, YOU MAY WRITE TO:

             U.S. Small Business Administration
             Office of Performance, Planning, and the Chief Financial Officer
             409 Third Street, S.W.
             Washington, DC 20416

  OR, YOU MAY CALL:

             Deborah Chen, Deputy Chief Financial Officer
             Office of Performance, Planning, and the Chief Financial Officer
             (202) 205-6723

  FOLLOW US ON:
             www.facebook.com/sbagov
             www.x.com/sbagov (formerly Twitter)

             www.youtube.com/sba
             www.instagram.com/sbagov




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   3
                                                                                            Introduction (Unaudited)



  Table of Contents
  MESSAGE FROM THE ADMINISTRATOR                                                                           7
  MANAGEMENT’S DISCUSSION AND ANALYSIS (UNAUDITED)                                                       10
     The SBA’s Organization and Mission                                                                   11
     Executive Summary                                                                                    12
         Financial Results                                                                                12
         Performance Results                                                                              12
     The SBA’s Principal Programs                                                                         14
         Capital                                                                                          14
         Investment and Innovation                                                                        14
         Exporting                                                                                        15
         Contracting and Business Development                                                             15
         Counseling and Training                                                                          16
         Disaster Assistance                                                                              17
     Analysis of Performance Results                                                                      18
         Summary of Performance Results                                                                   18
         Verification and Validation of Performance Data                                                  20
         Operational Portfolio Analysis                                                                   20
     Significant Opportunities and Risks                                                                  28
         Financial Integrity and Risk Management                                                          28
         Disaster Assistance and Resilience                                                               29
         Technology, Automation, and Operational Innovation                                               29
         Changing Workforce Strategy                                                                      30
         Supporting U.S. Manufacturing and Industrial Competitiveness                                     30
     Analysis of Financial Results                                                                        31
         Background                                                                                       31
         Loan Guaranties                                                                                  31
         Credit Program Subsidy Reestimates                                                               33
         Financial Position                                                                               34
     Analysis of SBA’s Systems, Controls, and Legal Compliance                                            36
         Internal Control Environment                                                                     36
         Financial Management Systems Strategy                                                            38
     Management Assurances: FMFIA & FFMIA Assurance Statements for FY 2025                                40



U.S. Small Business Administration                                      Agency Financial Report Fiscal Year 2025   4
                                                                                              Introduction (Unaudited)



  FINANCIAL REPORTING (UNAUDITED)                                                                          43
     Message from the Chief Financial Officer                                                               44
     Inspector General’s Audit Report                                                                       46
     Independent Auditors’ Report on FY 2025 Financial Statements                                           48
     CFO Response to Draft Audit Report on FY 2025 Financial Statements                                     62
     Consolidated Balance Sheet and Related Notes                                                           67
  OTHER INFORMATION (UNAUDITED)                                                                            91
     Other Financial Statements and Related Notes                                                           92
     OIG Report on the Top Management and Performance Challenges                                          128
     Agency Response to the OIG Report on the Top Management and Performance Challenges 160
     Payment Integrity                                                                                    168
     Summary of Financial Statement Audit and Management Assurances                                       188
     Grant Programs                                                                                       192
     Civil Monetary Penalty Adjustment for Inflation                                                      193
  APPENDICES (UNAUDITED)                                                                                 195
     Appendix 1 – Contact SBA: Useful Websites and Numbers                                                196
     Appendix 2 – Glossary                                                                                197
     Appendix 3 – OIG Audit Follow-Up Activity                                                            205




U.S. Small Business Administration                                        Agency Financial Report Fiscal Year 2025   5
                                                                                                        Introduction (Unaudited)



                        The SBA’s Mission
                        Maintain and strengthen the nation’s economy by enabling the establishment and
                        vitality of small businesses and by assisting in the economic recovery of communities
                        after disasters.


  How This Report is Organized
  The U.S. Small Business Administration’s FY 2025 Agency Financial Report (AFR) provides financial
  and performance information for the fiscal year beginning October 1, 2024, and ending September
  30, 2025. This report presents the SBA’s operations, accomplishments, and challenges. Following
  a message from the SBA Administrator are four principal sections: Management’s Discussion and
  Analysis, Financial Reporting, Other Information, and Appendices.

                     MANAGEMENT’S DISCUSSION AND ANALYSIS
                     The Management’s Discussion and Analysis section provides a report of the Agency’s
                     overall financial position, program performance, and results of operations. It presents
                     the SBA’s history, organization, and principal programs. This section highlights financial
                     results and analysis; performance results; and analysis of systems, controls, and legal
                     compliance.
                     FINANCIAL REPORTING
                     The Financial Reporting section provides a detailed report of the SBA’s Consolidated
                     Balance Sheet and related Notes. It includes a message from the Chief Financial Officer,
                     the audit transmittal memorandum from the Inspector General, and the Independent
                     Auditors’ report.
                     OTHER INFORMATION
                     The Other Information section includes the other financial statements and notes.
                     This section also includes the Inspector General’s report on the Agency’s most serious
                     management and performance challenges along with recommended actions and a
                     summary of the financial statement audit and management assurances. Additionally,
                     the required supplementary information provides a combined statement of budgetary
                     resources.
                     APPENDICES
                     The Appendices provide supporting information, including a contact list of useful
                     websites and telephone numbers, a glossary, and a detailed report on audit follow-up
                     activity.




U.S. Small Business Administration                                                  Agency Financial Report Fiscal Year 2025   6
                                                                                                    Introduction (Unaudited)



  Message From The Administrator
                                     January 21, 2026

                                     I’m pleased to report record results for the U.S. Small Business Ad-
                                     ministration (SBA) in Fiscal Year (FY) 2025. Under President Donald
                                     J. Trump’s leadership, this Administration is reversing the damage
                                     of the Biden Administration’s failed economic policies. Accordingly,
                                     the SBA has restored the agency to its founding mission, along with
                                     reinstating long-absent financial and operational integrity. The era of
                                     mismanagement, neglect, incompetence, and a lack of oversight has
                                     ended – along with the bureaucratic expansion, partisan bias, and
                                     racial discrimination that characterized the last four years.

                                    The agency-wide reforms that the Trump SBA were able to effect in
                                    the span of just one year are consistent with the urgency and quality
  with which the Trump Administration is executing. There’s perhaps no clearer indication of that than
  in our independent audit, which showed that reversal of the deteriorating risk posture of the agency is
  well under way. The FY25 audit by KPMG resulted in a 50% reduction in just one year of the agency’s
  material weaknesses, significant deficiencies, and audit recommendations. It also marked the first
  year that these issues were isolated solely to the pandemic-era programs, and that is the result of our
  exceptional agency-wide leadership team.

  From 2020-2024, the agency doubled in size with a headcount that remained at pandemic-era staff-
  ing levels although the pandemic had long-since concluded. The vast majority – 90% – of employ-
  ees worked from home, as the agency spent hundreds of millions on wasteful grants, contracts and
  purchases. The SBA poured resources into partisan programs like the Green Lender Initiative, DEI
  contracting, and voter registration campaigns for their political constituencies ahead of the 2024
  presidential election.

  Amid the vacuum of focus on small businesses in favor of a political agenda, the agency’s core pro-
  grams suffered. The Biden SBA reduced prudent underwriting standards within the core 7(a) loan
  program, generating rising defaults, declining bank participation, and ending Fiscal Year 2024 with
  negative cash flow for the first time in more than a decade. Basic and common-sense guardrails like
  citizenship and birth date verification were nonexistent. The SBA’s Inspector General uncovered an
  estimated $200 billion in Paycheck Protection Program (PPP) and Covid Economic Injury Disaster
  Loan (EIDL) fraud, which the agency refused to investigate – exposing taxpayers to substantial losses.
  In federal contracting, the 8(a) Business Development Program was arbitrarily expanded – advancing
  the interests of “socially and economically disadvantaged” small businesses to advance DEI at the
  expense of deserving veteran- and women-owned small businesses.

  Against this backdrop, the Trump SBA returned to its founding mission of empowering job creators,
  delivering disaster relief, and driving economic growth - grounded in financial discipline, program
  integrity, fighting fraud and responsible oversight of taxpayer resources. Being able to identify our
  progress on these issues, address opportunities to improve, and to report to you are just a few of the
  reasons I called for an immediate audit upon being sworn in.



U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   7
                                                                                                    Introduction (Unaudited)


  FY25 marked a pivotal year in the fight to restore financial stewardship across the agency. SBA re-
  stored strong underwriting standards within the 7(a) and 504 loan programs, and reimplemented
  lender fees to preserve the zero-subsidy status that ensures our loan guarantees remain self-funding.
  Across the agency, SBA actioned common-sense oversight, risk management, and internal audit and
  compliance practices to ensure that every dollar deployed aligned with statutory intent and sound
  financial standards. Along with our action to immediately terminate the partisan programs of the past
  and launch multiple fraud investigations, these actions were taken deliberately to protect the long-
  term solvency of SBA programs, reinforce lender confidence, and reduce taxpayer exposure.

  As a result of these reforms, the SBA delivered record levels of capital while improving portfolio qual-
  ity and operational discipline. During FY25, the agency guaranteed 85,000 loans through its 7(a) and
  504 programs, totaling $44.8 billion, resulting in a record year for capital access in SBA’s 72-year his-
  tory. On average, the SBA approved 1,615 small business loans per week, supporting our job creators
  and economic growth while renewing underwriting rigor.

  Meanwhile, the agency launched numerous investigations and audits to root out fraud – working to
  hold criminals accountable in partnership with law enforcement. The agency initiated a nationwide
  investigation into PPP and EIDL fraud, as well as a full-scale audit of the 8(a) Program. Amid its ef-
  fort to end waste and abuse within the federal contracting marketplace, the agency also continued
  clearing legacy backlogs – most notably in the Veteran Small Business Certification Program – ensur-
  ing timely, accurate, and compliant determinations for eligible firms. These actions underscore the
  agency’s zero-tolerance approach to waste, fraud, and abuse – and its commitment to preserving
  taxpayer funds on behalf of legitimate job creators.

  Following the Biden SBA’s failure to ensure adequate disaster funding in 2024, the Trump SBA restored
  integrity to the disaster assistance program, which is a critical component of the SBA’s lending opera-
  tions. In FY25, the agency delivered over $6 billion in disaster assistance, supporting more than 51,000
  disaster loans with improved loan approvals in just 17 days, while maintaining strict eligibility and
  credit controls to protect taxpayer funds.

  The SBA’s Small Business Investment Company (SBIC) program also closed FY25 at a historic high,
  reaching $53 billion in combined private capital and SBA leverage, reflecting strong investor con-
  fidence and disciplined risk management. This growth was achieved while maintaining oversight
  standards designed to protect the government’s position and ensure long-term program viability as
  another zero-subsidy program to drive growth and innovation without taxpayer cost burdens.

  Collectively, these results powered over $100 billion in a single year to drive the private sector for-
  ward, while reflecting a renewed commitment to financial integrity, transparency, and accountability.
  The SBA’s FY25 performance demonstrates that strong oversight and record capital delivery are not
  competing priorities, but complimentary ones. By restoring discipline, and focusing on measurable
  outcomes, in just one year, the SBA is already better positioned to support America’s entrepreneurs,
  Main Streets and workers, while upholding the highest standards of fiscal responsibility.

  As we look ahead, we are more committed than ever to continuous improvement, modernization,
  rigorous oversight, accountability for fraud, and responsible stewardship of taxpayer resources. I am
  confident that the reforms implemented in FY25 have strengthened the foundation of SBA programs




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   8
                                                                                                  Introduction (Unaudited)


  and will continue to deliver durable, transparent, and auditable results for America’s small businesses.

  Sincerely,




  Kelly Loeffler
  28th Administrator




U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   9
         SECTION 1




         Management’s
Discussion and Analysis
                     (UNAUDITED)
                                                                         Management’s Discussion and Analysis (Unaudited)



  The SBA’s Organization and Mission
  In 1953, Congress created the SBA to aid, counsel, assist, and protect the interests of small
  businesses. As the nation’s only go-to resource and voice for small businesses, the SBA provides
  programs and services that help small businesses confidently start, grow, expand, or recover. The
  SBA is backed by the Federal Government and is the only cabinet-level federal agency fully dedicated
  to small business. The SBA’s headquarters is in Washington, D.C., and its business products and
  services are delivered through field personnel and a network of private sector and nonprofit partners
  in every U.S. state and territory.
  The SBA is currently developing the FY 2026-2030 Strategic Plan which will outline current SBA
  priorities and how the work of SBA offices supports those priorities. The plan will be found at the
  following site: https://www.sba.gov/document/support-sba-strategic-plan. For more information
  on current SBA priorities and plans, please reference the FY 2026 Congressional Budget Justifica-
  tion and FY 2026 Annual Performance Plan documents which can be found at the following site:
  https://www.sba.gov/document/report-congressional-budget-justification-annual-perfor-
  mance-report.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   11
                                                                            Management’s Discussion and Analysis (Unaudited)



  Executive Summary
  America’s 36 million small businesses play a critical role in job creation and retention. During the last
  two decades, small businesses have been responsible for creating two out of every three net new
  jobs. In turn, the U.S. Small Business Administration’s assistance to those firms and entrepreneurs
  helps drive a healthy economy.

  The SBA employs a variety of methods to support America’s small businesses. These methods
  include promoting equitable access to capital, federal contracting, counseling, and disaster
  assistance.

  The following sections highlight financial and performance results for the Agency. Additional
  information can be found in the Analysis of Financial Results and Summary of Performance Results
  sections. The complete set of performance results will be reported in the Annual Performance Report
  to be published in early 2026.

  FINANCIAL RESULTS
  The loans receivable portion of the SBA credit program portfolio is $234.3 billion driven by new loans
  disbursed of $3.5 billion, loans purchased of $5.2 billion and collections of $9.3 billion.

  For FY 2025, the SBA’s total budgetary resources were $17.3 billion, primarily used for staffing,
  operations, and $12.5 billion in loan subsidy costs. Approximately $2.3 billion remains available for
  future obligations. Total nonbudgetary resources for loan financing used to make direct loans and
  purchase guaranteed loans in default were $31.5 billion. These resources supported $26 billion in
  obligations, with the remaining balance available for future-year obligations or will be returned to
  Treasury.

  The SBA’s guarantied portion of the outstanding loan principal increased by $6.1 billion in FY 2025
  to $145.6 billion. During FY 2025, new guaranties disbursed by SBA participating banks were $31.8
  billion. (Note 5E)

  In FY 2025, SBA purchased $5.2 billion in defaulted guaranteed loans to honor SBA’s guaranties which
  exceeded the additional resources available to fund these claim payments (Note 14B), reflecting
  higher-than-expected defaults within the guarantied loan portfolio.

  PERFORMANCE RESULTS
  Capital: In FY 2025, the SBA approved over $45 billion, or more than 84,000 7(a) and 504 loans
  to small businesses; 7(a) loans, 504 loans, microloans, and surety bonds helped to support more
  than 897,000 American jobs. During FY 2025 the SBA invested more than $5.7 billion in over 1,100
  small businesses through the Small Business Investment Company program, which supported over
  154,000 jobs.

  Contracting: The SBA continued to partner with agencies across the Federal Government to expand
  small business contracting opportunities. In FY 2024, small businesses were awarded over $183.5
  billion in federal contracts. FY 2025 contracting numbers continue to be collected and certified.




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   12
                                                                        Management’s Discussion and Analysis (Unaudited)


  The Federal Government continued to exceed its service-disabled veteran-owned small business
  contracting goals but will face challenges meeting its small disadvantaged, HUBZone, and women-
  owned small business contracting goals.

  Counseling: The SBA helped entrepreneurs start more than 26,000 new businesses in FY 2025 and
  served over 660,000 unique clients. Additionally, in FY 2025, hundreds of thousands of American
  small businesses took advantage of counseling, mentoring, and training assistance through the SBA
  network, which includes 150 Women’s Business Centers (WBC), the largest WBC network in the SBA’s
  history, and 31 Veterans Business Outreach Centers (VBOC).

  Disaster Assistance: In FY 2025, the SBA approved more than 51,000 direct disaster loans for events
  such as floods, hurricanes, and tornadoes, totaling nearly $6 billion. The Agency managed 449
  disaster assistance declarations during FY 2025.




U.S. Small Business Administration                                          Agency Financial Report Fiscal Year 2025   13
                                                                           Management’s Discussion and Analysis (Unaudited)



  The SBA’s Principal Programs
  CAPITAL
  7(a) Loans—The SBA offers government guaranties on loans (up to $5 million) made by lenders
  to help expand access to capital for business owners who face challenges obtaining approval for
  financing. The SBA guaranties a portion of 7(a) loans made and administered by commercial lending
  institutions. Loans can be guaranteed for a variety of general business purposes.
  504 Certified Development Company Loans—The SBA works with CDCs, which are private
  nonprofit corporations, and private lenders to provide long-term financing (up to $5.5 million) to
  support investment in major assets, such as real estate and heavy equipment. The SBA guaranties
  the CDC’s portion of these loans.
  Microloans—The SBA provides loans to nonprofit intermediary lenders, which are community-
  based organizations with experience in lending and providing technical assistance, that in turn
  make these loans (up to $50,000) to small businesses needing small-scale financing and technical
  assistance for startup or expansion.
  Surety Bond Guarantees—A surety bond is a type of contract that guarantees the performance of
  a contractor. If one party does not fulfill its end of the bargain, the SBG program provides financial
  compensation to the other party. The SBA guarantees bonds issued by a surety company to
  encourage the surety company to provide bonds to small businesses, up to $6.5 million for non-
  federal contracts and up to $10 million for federal contracts.

  INVESTMENT AND INNOVATION
  Small Business Investment Companies—SBICs are privately owned and managed investment
  funds that use their capital plus funds borrowed, with an SBA guaranty (up to $175 million), to make
  equity and debt investments in qualifying small businesses.
  Small Business Innovation Research—The SBIR program stimulates high-tech innovation by
  reserving a specific percentage of federal research and development funds for small businesses.
  Small Business Technology Transfer—The STTR program reserves a specific percentage of federal
  research and development funding to award to small business and nonprofit research institution
  partners.
  Federal and State Technology Partnership Program–The FAST Partnership Program provides
  direct assistance to underserved innovation-based entrepreneurs to help increase their success in
  obtaining SBIR and STTR funding.
  Growth Accelerator Fund Competition Program–GAFC provides $50,000-$200,000 in funding
  to accelerators, incubators, co-working communities, makerspaces, and other organizations that
  provide entrepreneurial support, mentorship, and assistance to STEM/R&D entrepreneurs.




U.S. Small Business Administration                                             Agency Financial Report Fiscal Year 2025   14
                                                                              Management’s Discussion and Analysis (Unaudited)


  Regional Innovation Clusters–RICs promote innovation in regional ecosystems through on-
  the-ground collaborations between businesses, research, education, financing, and government
  institutions that work to develop and grow a particular industry or related set of industries in a
  geographic region.

  EXPORTING
  Export Loans—The SBA provides several types of export loans, including SBA Export Express loans
  (up to $500,000), Export Working Capital loans (up to $5 million), and International Trade loans (up
  to $5 million) that provide small businesses with enhanced export financing options to develop
  foreign markets, fund their export transactions, and/or support business expansion due to exporting
  success. In FY 2024, the SBA began the Working Capital Pilot (WCP) program, which is a modified
  version of the Export Working Capital program. The WCP provides a new working capital tool geared
  toward the new-to-export market.
  U.S. Export Assistance Centers—USEACs are staffed by SBA, Department of Commerce, and
  Export-Import Bank professionals. Together, their mission is to help small- and medium-sized
  businesses compete in today’s global marketplace by providing export marketing and finance
  assistance.
  State Trade Expansion Program—STEP provides grants to states to assist small businesses with
  the information and tools they need to succeed in export related activities. These activities include
  participation in foreign trade missions, foreign market sales trips, international marketing campaigns,
  export trade shows, and training workshops.

  CONTRACTING AND BUSINESS DEVELOPMENT
  Contracting Assistance to Small Businesses—Small business contracts represent the largest
  form of direct monetary support for small business in the Federal Government. The SBA provides
  certifications for four subgroups:

      •     Small Disadvantaged Businesses—This program provides assistance through the 8(a)
            Business Development program and set-aside contracting for businesses owned and
            controlled by socially- and economically disadvantaged individuals. For 9 years, a firm is
            assisted in gaining resources to compete for federal contracts and for contracts in the private
            sector.

      •     HUBZone Small Businesses—This program provides sole-source and set-aside contracting
            for firms located in designated economically disadvantaged geographical areas.
      •     Veteran-Owned Small Businesses and Service-Disabled Veteran-Owned Small
            Businesses—Certified VOSBs have additional opportunities to pursue sole-source and set-
            aside contracts at the Department of Veteran’s Affairs. The SDVOSB program allows federal
            agencies to set aside contracts for competition only among service-disabled veteran-owned
            small businesses.




U.S. Small Business Administration                                                Agency Financial Report Fiscal Year 2025   15
                                                                         Management’s Discussion and Analysis (Unaudited)


      •     Women-Owned Small Businesses—This program allows federal agencies to set aside
            certain contracts for competition only among small businesses owned by women.
  Empower to Grow (formerly 7(j) Management and Technical Assistance)—This program
  provides training to small businesses owned and controlled by economically and socially
  disadvantaged individuals; to small businesses located in areas of high unemployment and low
  income; to 8(a) and HUBZone small businesses; and to economically disadvantaged WOSBs.
  Mentor-Protégé Program—This program helps small businesses gain experience in and access to
  federal acquisition marketplace through formal partnerships with experienced firms.

  COUNSELING AND TRAINING
  Small Business Development Centers—SBDCs deliver an array of services to small businesses and
  prospective business owners using a network of 63 lead centers managing nearly 900 service delivery
  points throughout the United States and its territories.
  Women’s Business Centers—WBCs provide advising and training through more than 150 nonprofit
  educational centers across the nation. Many WBCs provide multilingual services, and some offer
  flexible hours allowing mothers with children to attend training classes.
  Boots to Business (B2B)—B2B is an entrepreneurial education and training program offered by the
  SBA as part of the Department of Defense Transition Assistance Program (TAP). The course provides
  an overview of entrepreneurship and applicable business ownership fundamentals. Active-Duty
  Service members (including National Guard and Reserve), veterans of all eras, and military/veteran
  spouses are eligible to participate.
  Native American Outreach—The program supports American Indians, Alaska Natives, and
  Native Hawaiians seeking to create, develop, and expand small businesses. It engages in outreach,
  technical assistance, and education, formulates and administers training programs, and coordinates
  entrepreneurial development opportunities through cosponsorship agreements with entities and
  other federal agencies.
  Veterans Business Outreach Centers—The SBA’s 31 VBOCs provide counseling and training
  services to veteran-owned and service-disabled veteran-owned small businesses and entrepreneurs,
  along with reserve component members who have an interest in either starting a new small business
  or expanding an established small business.
  SCORE—SCORE is a nonprofit association comprising nearly 10,000 volunteer business mentors that
  serve entrepreneurs with in-person mentoring and local training workshops. As the largest volunteer
  business mentor network in the Federal Government, SCORE adapts its structure and services to
  meet the needs of small businesses.
  Learning Center and Ascent—The SBA Learning Center is an online portal that hosts a variety of
  self-paced online training courses, quick videos, web chats, and other helpful tools to assist small
  business owners to explore and learn about business ownership. Ascent is an online learning portal
  with materials and tools for women entrepreneurs.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   16
                                                                             Management’s Discussion and Analysis (Unaudited)


  Community Navigator Pilot Program—Through the Community Navigator Pilot Program, the
  SBA engaged in targeted outreach to underserved communities through states, local governments,
  resource partners, and nonprofit organizations. As of May 31, 2024, the program ended its No Cost
  Extension Period and all program-related activities have concluded. The program is now in the full
  program closeout phase of the grant’s lifecycle.

  DISASTER ASSISTANCE
  Disaster Assistance—The SBA is the Federal Government’s primary source of financing for the
  long-term repair and rebuilding of disaster-damaged private property for homeowners, renters,
  businesses of all sizes, and private nonprofit organizations. It is the only form of SBA assistance that is
  not limited to small businesses.
  Shuttered Venue Operators Grants—The Economic Aid to Hard-Hit Small Businesses, Nonprofits,
  and Venues Act established these grants to support shuttered venues because of the COVID-19
  pandemic. Recipients were not required to repay the grants if funds were spent for eligible uses
  within established timeframes. The SBA continues to provide servicing and oversight for this
  program.




U.S. Small Business Administration                                               Agency Financial Report Fiscal Year 2025   17
                                                                          Management’s Discussion and Analysis (Unaudited)



  Analysis of Performance Results
  SUMMARY OF PERFORMANCE RESULTS
  The following section presents key FY 2025 performance data. The presentation is organized by key
  programmatic functions of the Agency. Detailed information on SBA program performance data,
  including explanations of variances, will be presented in the FY 2025 Annual Performance Report to
  be published in early 2026.
  Access to Capital, Investment & Innovation, and Contracting & Business Development

    Performance Measure                                              FY 2025 Goal          FY 2025 Actual

    Number of Jobs Supported by 7(a) Loans, 504 Loans,
                                                                             762,500                   897,145
    Microloans, and Surety Bonds

    Number of Jobs Supported by SBIC Financings                              140,000                   103,732

    Number of Jobs Supported by Businesses Receiving Export
                                                                               26,000               Data lag 1
    Grants and Loans

    Number of Jobs Supported by Federal Contract Set-Asides                  700,000                Data lag 2

    Number of New Business Starts through SBA Counseling and
                                                                               25,700                    17,242
    Training Programs


  Disaster Assistance and Recovery

    Performance Measure                                              FY 2025 Goal          FY 2025 Actual

    Small Business Employment in the United States (Millions)                     66.5              Data lag 3


    Number of Loans that Include Mitigation Measures                               626                       861




  1 FY 2025 Q4 STEP grant data not yet available. Full year data will be published in the FY 2025 Annual

     Performance Report.
  2 Federal contracting data continues to be certified by the SBA, and will be available by summer 2026.
  3 Full year data for FY 2025 have not yet been published. Source: Bureau of Labor Statistics; Business

     Employment Dynamics Data by Firm Size Class https://www.bls.gov/web/cewbd/table_f.txt


U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   18
                                                                      Management’s Discussion and Analysis (Unaudited)


  Mission Support and Advocacy

    Performance Measure                                           FY 2025 Goal         FY 2025 Actual

    Customer Satisfaction Rate of Financial Management Services
                                                                                4.0                       4.8
    for SBA Employees

    Federal Employee Viewpoint Survey Global Satisfaction Rate                73%                      N/A 4


    Inspector General Maturity Rating                                           3.8                     2.72




  4 OPM has foregone the FEVs survey in 2025.




U.S. Small Business Administration                                        Agency Financial Report Fiscal Year 2025   19
                                                                            Management’s Discussion and Analysis (Unaudited)



  VERIFICATION AND VALIDATION OF PERFORMANCE DATA
  Managing for results and integrating performance, financial, and budgetary information requires
  valid, reliable, and high-quality performance measures and data. Improving data quality continues to
  be a priority for the SBA. The SBA’s performance analysts work with program office leads across the
  Agency to acquire high-quality data. In addition to using output data internally from its systems, the
  SBA relies on data from resource partners, other federal agencies, and other government entities to
  assess its accomplishments and effectiveness.

  The SBA rigorously pursues the following strategies to ensure data quality: ensuring the validity of
  performance measures and data; fostering organizational commitment and capacity for data quality;
  assessing the quality of existing data; and responding to data limitations. For additional information
  regarding the SBA’s approach to verifying and validating performance data, see the Congressional
  Budget Justification and Annual Performance Report, updated annually.

  OPERATIONAL PORTFOLIO ANALYSIS
  The Operational Portfolio Analysis provides information on the SBA’s credit programs and does
  not reference the financial statements. The SBA is the taxpayers’ custodian of small business loan
  guaranties and direct loans with a portfolio of $516.8 billion in FY 2025.6 During FY 2025, the portfolio
  increased year over year by $57.9 billion, or 12.6 percent. The largest increase in dollar terms was
  the Agency’s disaster loan portfolio, which increased by $37.9 billion (13.2 percent). This increase is
  primarily attributable to an accounting policy updated in FY 2025 that delays charge off timing to
  maintain active balances longer in the collection process. Due to the updated accounting policy,
  direct or purchased guaranteed direct loans under the COVID-19 Economic Injury Disaster Loan
  (COVID-19 EIDL) program and Paycheck Protection Program (PPP) that were charged-off in prior
  years have been returned to an active status. The result of this policy change for the PPP portfolio
  led to a year-over-year increase of $6.4 billion (143.1 percent). All the remaining loan portfolios also
  increased on a year over year basis: the 504 loan portfolio increased by $2.1 billion (6.4 percent) and
  the 7(a) portfolio expanded by $9.3 billion (8.0 percent). The Small Business Investment Company
  (SBIC) portfolio increased by $1.8 billion (11.2 percent) and all other portfolios increased by $488
  million (15.5 percent) (see Chart I).




  6 The total portfolio consists of guarantied business loans outstanding, guarantied debentures, direct

     business loans, and direct disaster loans. The data include all performing loans and defaulted
     loans that have not been charged off.


U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   20
                                                                                                                     Management’s Discussion and Analysis (Unaudited)


      Chart I: Makeup of the SBA’s Outstanding Loan Portfolio

                                   800
                                                                                                                                                 7(a)
                                         All Other
                                   700                                                                                                           PPP

                                                                                                                                                 504
                                   600
                                         Disaster           All Other




  Outstanding Loans ($ Billions)
                                                                                                                     All Other                   SBIC
                                   500                                         All Other
                                                                                                  All Other
                                                     SBIC                                                                                        Disaster
                                           504
                                   400                                                                                                           All Other
                                                            Disaster
                                                                                                                     Disaster
                                                                               Disaster           Disaster
                                   300
                                           PPP

                                   200                                                                                            SBIC
                                                                        SBIC
                                                              504                          SBIC               SBIC     504
                                                              PPP                504       PPP
                                                                                                    504       PPP                 PPP
                                   100
                                                              7(a)               7(a)               7(a)               7(a)
                                           7(a)
                                    0
                                         FY 2021            FY 2022            FY 2023            FY 2024            FY 2025




U.S. Small Business Administration                                                                                       Agency Financial Report Fiscal Year 2025   21
                                                                                          Management’s Discussion and Analysis (Unaudited)


      New Guarantied Loans

      The quarterly average loan volume increased in FY 2025 with an average of $11.3 billion. Chart II
      demonstrates the trend in loan approvals since FY 2020.
      Chart II: Quarterly Gross 7(a) and 504 Loan Approvals

                                25




                                20




  Loan Approvals ($ Billions)
                                15
                                                                                                                FY 25 Avg:
                                                   FY 21 Avg:
                                                                                           FY 24 Avg:           11,272,997
                                                   11,188,716   FY 22 Avg:   FY 23 Avg:    9,447,236
                                10                              8,725,450    8,484,336
                                      FY 20 Avg:
                                      7,094,264

                                 5




                                 0
                                     Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4
                                        FY 2020    FY 2021     FY 2022     FY 2023     FY 2024      FY 2025

      At least three main factors contributed to the loan guaranty portfolio’s recent changes:

      Continuous Growth in the Economy — Real Gross Domestic Product in the United States
      increased throughout 2024 and has continued to grow during 2025, with a rate of 3.8 percent in the
      second quarter of 2025. The increase in real GDP in the second quarter primarily reflected a decrease
      in imports, which are a subtraction in the calculation of GDP, and an increase in consumer spending.
      These movements were partly offset by decreases in investment and exports.7

      Changes in Market Volatility — During 2022, the monthly inflation reached its highest point,
      peaking at 6.6 percent in September 2022 to end that year with a 6.2 percent monthly average before
      coming down during 2023 to an annual monthly average of 4.8 percent. In 2024 inflation came down
      further to an annual monthly average of 3.4. In 2025 inflation continued to ease with a monthly

      7 U.S. Department of Commerce, Bureau of Economic Analysis: https://www.bea.gov/data/gdp/

                     gross-domestic-product



U.S. Small Business Administration                                                            Agency Financial Report Fiscal Year 2025   22
                                                                                                  Management’s Discussion and Analysis (Unaudited)


      average of 2.9 through the first six months of the year. Inflationary pressures have significantly
      increased interest rates across the commercial and consumer loan market. Conversely, while the
      unemployment rate surged to a peak of 14.7 (April, 2020) during the COVID-19 pandemic period, it
      has decreased significantly throughout the 2021-2023 period, averaging 3.6 percent monthly for both
      2022 and 2023. In 2024 the unemployment rate increased slightly to an average of 4 percent monthly
      and has stayed roughly the same throughout the first nine months of 2025, peaking at 4.4 percent in
      September 2025 with a monthly average of 4.2 percent in 2025 year to date.8

      Market for Small Business Lending — Data from the Federal Deposit Insurance Corporation
      (FDIC) showed that the total market for business loans increased between 2019–2024 by 15 percent
      ($526 billion). However, 97.5 percent ($513.1 billion) of this increase comes from loans to nonsmall
      businesses,9 whereas total small business loans increased by only $12.9 billion. Thus, the ratio of
      small business loans compared with the total bank market has decreased between 2019–2024,
      with a marked decrease during the pandemic years of 2021–2022 (see Chart III). Furthermore, the
      banking industry’s trend toward consolidation, reflected in the reduction of commercial banks by
      12 percent10 between 2019–2024 makes the SBA’s guaranty products more critical for growing small
      businesses that may be denied credit in the private loan market.
      Chart III: Outstanding Commercial Loans to Small vs. Nonsmall Businesses

                                                                      3,471     3,467     3,401          Nonsmall Business Loans
                                                  2,999     3,099
                                        2,888




  Outstanding Loans ($ Billions)
                                                                                                         Small Business Loans




                                                   904
                                         721                 737       717       731      734


                                       CY 2019   CY 2020   CY 2021   CY 2022 CY 2023 CY 2024




                8 U.S. Department of Labor, Bureau of Labor Statistics: https://data.bls.gov/timeseries/lns14000000
                9 Nonsmall businesses are firms that have more than 500 employees. https://www.fdic.gov/

                                   quarterly-banking-profile/quarterly-banking-profile-q3-2025
      10 https://www.fdic.gov/bank/statistical/stats




U.S. Small Business Administration                                                                    Agency Financial Report Fiscal Year 2025   23
                                                                                       Management’s Discussion and Analysis (Unaudited)


      New Direct Loans

      In FY 2025, the SBA’s gross approvals for the Disaster Assistance loan program increased by 228
      percent to $5.5 billion against an FY 2024 total of $1.7 billion. As of FY 2023, the COVID 19-EIDL
      program is no longer approving loans for COVID-19, so disaster loan approvals are returning to a
      comparable level with to the pre-pandemic period. Chart IV illustrates the relative sum of disaster
      loans in FY 2025 by month, compared with the prior three fiscal years.
      Chart IV: Monthly Gross Disaster Assistance Loan Approvals



                                6000
                                                                                                                  FY 2022

                                5000                                                                              FY 2023

                                                                                                                  FY 2024




  Loan Approvals ($ Millions)
                                4000
                                                                                                                  FY 2025


                                3000



                                2000



                                1000



                                   0
                                       Oct   Nov   Dec   Jan   Feb   Mar   Apr   May     June July            Aug        Sept


      Aside from the FY 2020 -2022 COVID-19 EIDL loans, the top ten disasters that make up the portfolio’s
      outstanding balance includes lending from FY 2006 (hurricane Katrina), FY 2013 (hurricane Sandy), FY
      2018 (hurricanes Harvey, Irma, and Maria), FY 2021, (hurricane Ida), FY 2022 (hurricane Ian), FY 2024
      (hurricane Helene), and FY 2025 (hurricane Milton and wildfires in California).

      The SBA will continue to make disaster loans an important recovery tool for businesses,
      homeowners, and renters that survive a disaster.




U.S. Small Business Administration                                                         Agency Financial Report Fiscal Year 2025   24
                                                                            Management’s Discussion and Analysis (Unaudited)


  Portfolio Performance — Delinquencies

  Delinquency rates (i.e., borrowers who are late on their payments) are a leading indicator of
  the Agency’s charge-off rate (i.e., the rate of dollars spent to cover loans that defaulted). Thus,
  delinquency rates are a general indicator of the Agency’s and taxpayers’ future liabilities for these
  programs. A declining delinquency rate (see Chart V) is a positive indicator for the financial
  performance of any loan portfolio.

  Strong economic growth, strong profit performance, and tighter lending standards by financial
  institutions during the past several years have reduced delinquency rates generally for all business
  loans. Delinquency rates for the Agency’s major loan programs followed this national downward
  trend. Delinquency rates for the 7(a) loan program declined from the 3.8 percent peak in January
  2009 to 0.84 percent in February 2020, prior to the start of the COVID-19 pandemic. Similarly,
  delinquency rates for the 504 loan program likewise declined from the 5 percent peak in February
  2010 to 0.9 percent in February 2020.

  The CARES Act provided pandemic debt relief to current borrowers of 7(a) and 504 loans, authorizing
  the SBA to pay the principal, interest, and associated fees on existing loans for six months. This led to
  a delinquency rate of near zero percent in the last six months of FY 2020. With the expiration of CARES
  Act funds, both programs saw more variability in their delinquency rates during FY 2021-2022.

  As of July 2025, the average FY 2025 YTD 7(a) delinquency rate of 1.15 percent is higher than the
  FY 2024 average delinquency rate of 0.88 percent. The 7(a) rate remained low throughout FY 2025
  though, hovering around one percent every month despite generally trending slightly upwards.

  Monthly 504 delinquency rates decreased during 2023 following a period of greater variability in FY
  2021-2022, peaking at 3.4 percent in September, 2021. During FY 2022, the delinquency rate trended
  downward, but experienced high variability throughout that fiscal year. Starting in FY 2023, the 504
  delinquency rate is less volatile, and the average FY 2025 YTD 504 delinquency rate of 0.87 percent is
  only slightly above the FY 2024 average delinquency rate of 0.76 percent.

  The SBA will continue to monitor the variability and level of both 7(a) and 504 delinquency rates
  closely in the post-CARES Act environment.




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   25
                                                                            Management’s Discussion and Analysis (Unaudited)


  Portfolio Performance — Charge-Offs

  The 12-month charge-off rate for the 7(a) loan program sharply declined during FY 2016-2017, has
  continued to improve and remains very low. By July 2025 it has come down to 0.68 percent (see
  Chart V). The 7(a) loans not sold on the secondary market become a charge-off after all efforts to
  recover a delinquent balance were exhausted, such as liquidating the underlying collateral. The
  latent rise of the 7(a) charge-off rate in 2013 is attributable to recession-era loans that were charged-
  off after efforts to recover delinquent balances had been exhausted. Now that this effort to charge-off
  the recession-era loans is complete, the charge-off rate again closely trends with the delinquency
  rate in FY 2025.

  The 12-month charge-off rate for the 504 loan program had its historical high during FY 2013,
  peaking at 4.4 percent in January 2013, but dropping to the very low point of 0.08 percent by
  July 2025. This trend is not surprising, since the 504 loan program is an economic development
  program with a commercial real estate focus. As such, recovery rates of defaulted 504 loans are, with
  some noticeable time lag, significantly impacted by the pricing trend in this sector. The continued
  downward trend in the 504 delinquency rate during FY 2025 indicates that the volatility during FY
  2021-2022 period had little impact on the trajectory of 504 charge-off rates and as of July 2025, does
  not appear to have been a significant factor.

  Quarterly information on the status of the SBA’s loan portfolio, including outstanding balances and
  approvals by loan program and purchase rates, is available on the SBA’s website at www.sba.gov/
  performance.




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   26
                                                                                                                                   Management’s Discussion and Analysis (Unaudited)


    Chart V: Delinquency and Charge-Off Rates for the 7(a) and 504 Loan Programs by Fiscal
    Year
                                                                                         7(a) Loans

                      3.5%                                                                                                                       7(a) Delinquency Rate

                                                                                                                                                 7(a) Past 12 Months
                      3.0%                                           7(a) Past 12 Months
                                                                                                                                                 Charge-Off Rate
                                                                     Charge-Off Rate
                      2.5%




  Rate (Percentage)
                      2.0%

                      1.5%
                                                                                                                                      7(a) Delinquency Rate
                      1.0%

                      0.5%

                         0


                             FY 2013   FY 2014   FY 2015   FY 2016   FY 2017   FY 2018     FY 2019   FY 2020   FY 2021   FY 2022       FY 2023    FY 2024   FY 2025



                                                                                         504 Loans
                      5.0%
                                                                                                                                                 504 Delinquency Rate
                      4.5%
                                                                                                                                                 504 Past 12 Months
                      4.0%              504 Past 12 Months                                                                                       Charge-Off Rate
                                        Charge-Off Rate
                      3.5%




  Rate (Percentage)
                      3.0%

                      2.5%

                      2.0%                                                                                                    504 Delinquency Rate

                      1.5%

                      1.0%

                      0.5%

                      0.0%


                             FY 2013   FY 2014   FY 2015   FY 2016   FY 2017   FY 2018     FY 2019   FY 2020   FY 2021   FY 2022       FY 2023    FY 2024   FY 2025



U.S. Small Business Administration                                                                                                      Agency Financial Report Fiscal Year 2025   27
                                                                          Management’s Discussion and Analysis (Unaudited)



  Significant Opportunities and Risks
  The SBA is dedicated to equipping America’s entrepreneurs with the tools to start, grow, and sustain
  resilient businesses. In today’s dynamic economic and technological environment, the Agency faces
  risks that may affect program delivery and strategic priorities, alongside opportunities that can
  strengthen its impact and expand the reach of its services. By anticipating disruptions and identifying
  areas for improvement, the SBA can focus resources where they matter most, enhance program
  effectiveness, and help small businesses navigate an increasingly complex landscape. This proactive
  approach positions the Agency to optimize taxpayer resources, foster innovation, and promote
  resilience across the small business ecosystem.

  FINANCIAL INTEGRITY AND RISK MANAGEMENT
  The SBA remains committed to maintaining financial integrity and robust risk management practices
  across all programs. The COVID-19 pandemic revealed gaps in internal controls, loan underwriting,
  and risk monitoring, underscoring the need for enterprise-wide oversight mechanisms. To address
  these risks, the Agency continues to improve its Enterprise Risk Management (ERM) and Fraud Risk
  Management (FRM) programs, integrating lessons learned from prior audits and leveraging insights
  from the Government Accountability Office (GAO) and Office of Inspector General (OIG). The SBA is
  implementing advanced monitoring and analytical tools to identify emerging vulnerabilities, improve
  predictive risk modeling, and facilitate timely intervention in program management. The SBA is also
  developing a governance, risk and compliance (GRC) tool that will centralize governance, automate
  risk management, and stay compliant.

  Audit remediation remains a top priority. Resources are directed toward resolving outstanding
  findings from pandemic-era programs, ensuring recovery of ineligible funds, and closing gaps in
  program oversight. The Agency continues to refine loan underwriting standards, perform rigorous
  performance analyses, and apply detailed financial modeling to identify emerging lending risks.
  Looking forward, these efforts position the SBA to anticipate disruptions in program performance,
  address material weaknesses proactively, and continuously improve operational resilience. By
  embedding risk awareness into day-to-day processes, the SBA strengthens its capacity to safeguard
  public funds and guarantees that support reaches eligible small businesses without delay.




U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   28
                                                                           Management’s Discussion and Analysis (Unaudited)



  DISASTER ASSISTANCE AND RESILIENCE
  Natural disasters remain a growing challenge for small businesses and the communities they
  serve. In 2023 alone, the United States experienced 28 separate weather and climate events, each
  exceeding $1 billion in damages, marking a record-setting year for billion-dollar disasters.11 In 2024,
  there were 27 individual weather and climate disasters with at least $1 billion in damages, trailing
  only the record-setting 28 events analyzed in 2023.12 This reflects both the increasing frequency and
  intensity of disaster events, as well as the heightened economic vulnerability of small businesses
  in affected regions. The SBA’s Disaster Assistance program plays a critical role in mitigating these
  impacts by providing rapid support to businesses navigating disruption.

  The SBA promotes resilience through disaster mitigation loans, allowing businesses to finance
  improvements that reduce future vulnerability. Targeted field office outreach and community
  engagement programs extend the Agency’s reach in areas that are particularly at risk. Operational
  enhancements, including accelerated disaster declarations, streamlined loan processing, and
  specialized support for impacted regions, improve the Agency’s responsiveness. Investments in
  modernized systems and staff training enable quicker disaster response across all programs. By
  combining proactive mitigation with adaptive operational improvements, the SBA positions itself to
  reduce future disruption and accelerate recovery to communities nationwide.

  TECHNOLOGY, AUTOMATION, AND OPERATIONAL INNOVATION
  The rapid evolution of technology presents both opportunities and risks for small businesses.
  Through digital modernization, including secure platforms with integrated AI and advanced
  analytics, the SBA improves operational efficiency, enhances customer service, and supports
  informed decision-making. These technology-driven improvements also address operational risks by
  strengthening cybersecurity and reducing processing errors.

  Emerging technologies provide opportunities to expand access. Virtual training platforms and online
  tools extend the reach of SBA programs to communities with limited broadband infrastructure.
  These tools enable small business owners to receive guidance and access financial resources more
  efficiently. Simultaneously, operational process improvements, such as automated loan processing
  and integrated program management systems, support faster recovery during disasters and
  enhance internal coordination. By embracing these innovations, the SBA positions itself to adapt
  to technological change while mitigating potential operational risks, ultimately enabling small
  businesses to benefit from a more accessible support system.




  11 https://www.climate.gov/news-features/blogs/beyond-data/2023-historic-year-us-billion-

      dollar-weather-and-climate-disasters
  12 https://www.climate.gov/news-features/blogs/beyond-data/2024-active-year-us-billion-

      dollar-weather-and-climate-disasters


U.S. Small Business Administration                                             Agency Financial Report Fiscal Year 2025   29
                                                                         Management’s Discussion and Analysis (Unaudited)



  CHANGING WORKFORCE STRATEGY
  The SBA’s workforce is central to the Agency’s ability to deliver on its mission. Shifts in employee
  demographics, including an increasing proportion nearing retirement, combined with evolving
  workplace expectations, necessitate proactive workforce planning and training. The Agency is
  developing policies and programs to support hybrid work models, optimize field and headquarters
  office configurations, and guarantee continuity of institutional knowledge. Surveys of workspace
  requirements and employee feedback inform decisions on staffing allocations and technology
  support, enhancing the Agency’s overall effectiveness.

  Retention and recruitment remain critical considerations. Competition with private industry and
  other federal agencies creates pressure to attract and maintain highly skilled personnel. The SBA
  is enhancing training programs for field staff, equipping them with tools and guidance to support
  small businesses more effectively. Professional development initiatives focus on preparing staff
  for emerging challenges, including financial oversight, technology adoption, and customer service
  innovation. By integrating workforce resilience into planning, the SBA ensures the Agency can
  maintain mission-critical capacity, respond effectively to emerging business challenges, and
  continuously adapt to the evolving federal work environment.

  SUPPORTING U.S. MANUFACTURING AND INDUSTRIAL COMPETITIVENESS
  Small manufacturers are vital to the nation’s economic growth and industrial leadership. The SBA is
  leveraging opportunities to expand support for domestic manufacturing through financing, capital
  access, and program visibility. Initiatives such as the Made in America program provide tailored
  resources, including financing options, reshoring guidance, and increased visibility for federal
  support programs, enabling small manufacturers to scale operations, create jobs, and strengthen
  domestic supply chains.

  By connecting manufacturers with technical guidance and federal capital, the SBA helps reduce
  reliance on foreign supply chains, improve operational resilience, and support broader economic
  objectives. These efforts focus on long-term industrial competitiveness and domestic job creation.
  Through a combination of strategic investment, enhanced visibility of programs, and direct
  engagement with businesses, the SBA positions small manufacturers to contribute meaningfully to
  economic recovery and national industrial resilience.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   30
                                                                          Management’s Discussion and Analysis (Unaudited)



  Analysis of Financial Results
  BACKGROUND
  The SBA is a major Federal credit agency of the U.S. Government, and most the Agency’s $48.8
  billion budgetary resources support the SBA’s credit programs. The SBA provides direct loans to
  those impacted by disaster and partners with lenders and investors to provide small businesses with
  access to capital.

  Major factors that impact the SBA financial results include timing of borrowing and repayment of
  Debt to Treasury, annual reestimates, program changes, and disaster activity.

  The SBA borrows funds to fund the difference between the loan’s estimated cost and the amount of
  the loan disbursed for disaster and business direct loan programs. Funds are also borrowed to fund
  cash shortfalls related to the timing of disbursements and collection of resources. (Note 8)

  The cost of loan programs is reestimated annually. Based upon the reestimates, additional
  funds are made available to the SBA with an upward reestimate funded by permanent indefinite
  appropriations, or they are returned to Treasury with a downward reestimate. (Note 14)

  Program changes have had a driving impact on SBA costs and balances. In particular, COVID
  programs resulted in a marked increase in loans disbursed in prior fiscal years, whereas in the current
  fiscal year the SBA has transitioned to recovering these program costs and returning to the traditional
  business loan guarantees and disaster lending programs.

  The SBA provides direct loans to support individuals and businesses impacted by disasters. These
  payments assist communities return to normalcy in the wake of a disaster.

  The SBA supports small businesses’ access to capital by guaranteeing loans from lenders. Loan
  guarantees allow lenders to share the risk of default with the SBA. The SBA’s 2025 guarantee
  programs charged lenders sufficient fees to allow the programs to operate with zero subsidy from the
  government. Lenders work with borrowers to determine their needs and credit worthiness.

  LOAN GUARANTIES
  During FY 2025 SBA guarantied $31.8 billion of new loans disbursed by SBA’s lending partners. Loan
  guarantees and the related disbursements are disclosed in SBA’s financial disclosures. (Note 5E)




U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   31
                                                                                         Management’s Discussion and Analysis (Unaudited)


    Guarantied Loans Disbursed

                 $350
                              304.0
                 $300
                 $250

  ($ Billions)
                 $200
                 $150
                 $100
                                                                                31.8
                  $50                         32.6         27.0      27.3
                      $0
                             FY 2021         FY 2022      FY 2023   FY 2024    FY 2025


    If a borrower defaults on an SBA guarantied loan SBA reimburses the lender for the guarantied
    portion of the loan. The SBA added $5.01 billion defaulted loan guarantees to its credit receivables in
    FY 2025.
    Purchases of Guarantied Loans

                                                            11.99
                 12
                 10
                  8

  ($ Billions)
                                                 5.90
                  6                                                           5.01
                                                                     4.39
                  4
                  2        1.19
                                      0.72
                  0
                       FY 2020    FY 2021       FY 2022    FY 2023 FY 2024    FY 2025




U.S. Small Business Administration                                                           Agency Financial Report Fiscal Year 2025   32
                                                                                                  Management’s Discussion and Analysis (Unaudited)



   CREDIT PROGRAM SUBSIDY REESTIMATES
   Credit Program Subsidy Reestimates reflects the net subsidy reestimates for the guaranteed
   business and direct disaster loan programs from FY 2020 through FY 2025. The Disaster Assistance
   loan program had a net upward reestimate of $9.7 billion in FY 2025 compared to a $1.8 billion
   downward reestimate in FY 2024. Further detail on subsidy reestimates can be found in Note 14 of
   the financial statements in the Other Information section of this report.
   Credit Program Subsidy Reestimates

                                                                                 34.000
                  34
                  32
                  30                                          28.000
                  28
                  26
                  24
                  22
                  20
                  18
                  16
                  14


  ($ Billions)
                  12                                                                                                 9.700
                  10
                   8
                   6
                   4                                  2.700
                   2
                   0
                  -2                                                                      (1.203) (1.800) (0.600)               (0.839)
                  -4
                                            (3.800)
                  -6                                                   (5.198)
                  -8
                                  (5.700)
                 -10
                 -12
                 -14
                 -16
                 -18
                 -20   (19.000)
                           FY 2020              FY 2021           FY 2022            FY 2023            FY 2024             FY 2025


                                                                                                       Direct Disaster Loans

                                                                                                       Direct Business Loans

                                                                                                       Guaranteed Business Loans




U.S. Small Business Administration                                                                    Agency Financial Report Fiscal Year 2025   33
                                                                             Management’s Discussion and Analysis (Unaudited)



  FINANCIAL POSITION
  ASSETS

  The SBA had total assets of $248.4 billion at the end of FY 2025. Assets consist primarily of Fund
  Balance with Treasury and Credit Program Receivables and Related Foreclosed Property.

      The following major activity impacted Fund Balance with Treasury

  •     Spending Authority collections of $10.5 billion

  •     New Borrowings $14.8 billion less repayments of $30.1 billion (Note 8)

  •     Loans Disbursed $3.5 billion (Note 5E)

  •     Default Claims paid $5.2 billion (Note 14B)

  •     Reestimate Collections net of disbursements $-1.4 billion
  LIABILITIES

  The SBA had total liabilities of $255.9 billion at the end of FY 2025. Liabilities consist primarily of
  the Principal Payable to the Bureau of Fiscal Service, Liability for Loan Guaranties, and Downward
  Reestimate Payable to Treasury.

  The Principal Payable to the Bureau of the Fiscal Service is $249.3 billion a decrease of $15.3 billion
  from FY 2024 because of repayment of debt of $30.1 billion exceed new borrowings of $14.8 billion.
  Repayment of debt is driven by spending authority collections in the current year and prior year that
  have not been used to liquidate debt. (Note 8)

  Loan Guarantee Liabilities is the estimate of the net present value of the future amount the SBA will
  pay, net of fee collections, to liquidate expected purchases of guarantied loans under its guarantied
  loan programs. Loan Guarantee Liability is $3.0 billion at the end of FY 2025 -- a decrease of $1.8
  billion due to a decrease in estimated recoveries. (Note 14B)

  Downward Reestimate Payable to Treasury was $2.8 billion at the end of FY 2025, representing
  a decrease of $7 billion from FY 2024. The decrease was primarily due to a smaller downward
  reestimate for Disaster loans. (Note 14)
  NET POSITION

  Cumulative Results of Operations is the cumulative difference between unfunded expenditures
  and financing sources since the inception of the Agency. The cumulative results of operations were $
  (11.6) billion at the end of FY 2025 a $4.3 billion decrease from FY 2024 primarily because of unfunded
  subsidy reestimates. Subsidy reestimates determined at year-end are funded in the following year.

  Unexpended Appropriations increased $1 billion to $4.2 billion at the end of FY 2025 from FY 2024
  primarily because the appropriations received were greater than the amount of funded spending
  from the current year. The increase affected Budgetary Financing Sources and Ending Net Position.




U.S. Small Business Administration                                               Agency Financial Report Fiscal Year 2025   34
                                                                            Management’s Discussion and Analysis (Unaudited)


  NET COST OF OPERATIONS

  Net Cost of Operations was $12.1 billion in FY 2025. Net Costs of Operations primarily reflect the costs
  of SBA credit programs subsidy expenses during the year for new loans and subsidy reestimates
  at year-end. The primary component of the net cost was a Disaster Assistance program upward
  reestimate of $9.7 billion due to lower than projected collections on COVID EIDL loans. (Note 14E)
  BUDGETARY RESOURCES

  Total Budgetary Resources for FY 2025 of $48.8 billion include Budgetary balances of $17.3 billion
  and Non-budgetary credit reform financing balances of $31.5 billion. Non-budgetary credit reform
  financing accounts record cash flows from post-1991 direct loans and loan guarantees.

  Budgetary resources include a carryover from the prior year of $4.2 billion, appropriations of $11.9
  billion, and spending authority of $1.2 billion which funded $12.5 billion of obligations. Of the
  remaining $4.7 billion unobligated balance $2.3 billion can fund future obligations, Non-budgetary
  resources include a carryover from the prior year of $7.8 billion, $14.5 billion of borrowing authority
  and $9.2 billion of spending authority which funded $26 billion of obligations. The remaining
  unobligated balance of $5.5 billion will be used to fund default claims and repay debt to Treasury.




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   35
                                                                            Management’s Discussion and Analysis (Unaudited)



  Analysis of the SBA’s Systems, Controls, and
  Legal Compliance
  INTERNAL CONTROL ENVIRONMENT
  The SBA believes that maintaining integrity and accountability in all programs and operations is
  critical for demonstrating consistently responsible stewardship over assets and resources and is a
  sign of responsible leadership. The SBA’s commitment to integrity, ethical values, and an effective
  system of internal controls helps to ensure that every employee remains dedicated to the efficient
  delivery of services to customers and maximizes desired program outcomes. Accordingly, the SBA
  has developed and implemented management, administrative, and financial system controls to
  reasonably ensure that:

  •     Programs and operations achieve intended results efficiently and effectively;
  •     Resources are used in accordance with the mission of the Agency;

  •     Programs and resources are protected from waste, fraud, and mismanagement;

  •     Program and operation activities are in compliance with laws and regulations; and

  •     Reliable, complete, and timely data are maintained and used for decision-making at all levels.

  Each office within the SBA is required to implement or maintain effective internal controls over
  operations, reporting, and compliance to achieve programmatic goals. Each year, the SBA conducts
  an assessment of internal control as required by the Federal Managers’ Financial Integrity Act
  (FMFIA) of 1982 in accordance with the Office of Management and Budget (OMB)’s Circular No. A-123,
  Management’s Responsibility for Enterprise Risk Management and Internal Control. The FMFIA
  requires that the assessment results be reported to the President and Congress in a statement of
  assurance. The SBA Administrator provides the statement of assurance based on the self-assessment
  of program managers, internal control reviews, and audits and reviews done by the Government
  Accountability Office (GAO) and SBA’s Office of the Inspector General (OIG). Although some
  foundational elements are currently in place, SBA continues to operate under modified assurance
  levels due to unresolved material weaknesses.

  For FY 2025, SBA’s non-compliance with OMB Circular A-123 requirements reflects the impact of
  organizational changes and inconsistencies in execution of internal control across multiple program
  offices. The SBA has faced challenges in sustaining a consistent control environment and effective
  oversight body, which has diminished the overall effectiveness of internal control processes. SBA
  prioritized the following actions to stabilize the control environment and mitigate audit risk:

  •     Engage with external auditors to align expectations and mitigate audit risks;

  •     Prioritize immediate compliance needs, especially those tied to OMB Circular A-136 and financial
        reporting deadlines; and

  •     Continue performing corrective action plans and remediation activities for known deficiencies,
        even if full resolution is not feasible within the fiscal year.


U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   36
                                                                         Management’s Discussion and Analysis (Unaudited)


  As part of fiscal year 2026 planning, the Office of Performance, Planning, and the Chief Financial
  Officer (OPPCFO) has begun implementing initiatives to strengthen the agency’s control
  environment, beginning with defining roles and responsibilities for internal controls, and
  standardizing documentation. OPPCFO will also improve the trainings and tools designed for
  program support offices and district offices, to support management in assessing and documenting
  the effectiveness of internal controls within their respective areas of responsibility. These
  improvements will align with the internal control framework outlined in GAO’s Standards for
  Internal Control in the Federal Government, known as the Green Book.

  In 2025, the SBA continued its oversight and monitoring efforts related to the pandemic programs
  created by legislation. The methodology applied to all programs established by the Coronavirus Aid,
  Relief, and Economic Security (CARES) Act, Economic Aid Act, and American Rescue Plan Act (ARPA).
  Although most of the pandemic programs have ceased making disbursements they are still included
  in our oversight and monitoring efforts through ongoing audit remediation activities.

  In FY 2025, the SBA implemented a new audit remediation strategy through collaboration between
  OPPCFO and responsible program offices targeting five key target areas identified as having the
  greatest impact on strengthening control activities and advancing progress toward an unmodified
  financial statement audit opinion. This approach produced meaningful improvements in internal
  controls related to SVOG, RRF, Financial Reporting, Service Organizations, and Access Controls.
  Additional audit remediation efforts were performed in areas such as COVID EIDL, PPP, ELC, Debt
  Relief Program, and Information Technology.

  In FY 2026, the SBA will develop a refreshed financial statement audit remediation strategy to
  continue its efforts toward achieving a clean audit opinion and strengthening financial accountability
  across the agency.

  Related to the SBA’s effort to report accurate and complete financial statements, the Agency delivers
  enterprise level cybersecurity and privacy services that empower the SBA to better support the small
  business community through robust yet flexible processes and mechanisms.

  The Information Security Division is in the process of procuring a new Governance Risk Platform
  tool and Security Training Platform which will allow SBA to mature its Security Program, thereby
  enhancing its security posture. Additionally, OCIO successfully closed several audit findings
  pertaining to user separations and network MFA. This should be reflected with an increased FISMA
  maturity rating for FY25.

  The SBA will continue to incorporate the changes derived from the evaluation criterion and continue
  developing its cybersecurity program in the areas of configuration management, cybersecurity
  training, asset management, vulnerability management, supply chain risk evaluation and
  management, red team penetration testing, network segmentation, Dev/Sec/Ops, risk quantification,
  and automation of controls assessments.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   37
                                                                            Management’s Discussion and Analysis (Unaudited)



  FINANCIAL MANAGEMENT SYSTEMS STRATEGY
  The goal of the SBA’s Financial Management Systems Strategy is to provide accurate financial
  information to support transparency on the financial performance of the agency to all stakeholders;
  provide management with timely and accurate data to support management analysis and decision-
  making; and enable the Agency to keep pace with its lending partners and effectively use automation
  to achieve operational efficiency.

  Over the past year, SBA’s strategy to achieve these goals has been focused on:

  •     Compliance with Laws & Regulations. As demonstrated throughout the FY 2025 Agency
        Financial Report, the SBA seeks to comply with all Federal financial management system
        requirements, including the Federal Financial Management Improvement Act of 1996, which
        requires that the Agency’s financial management systems comply with Federal financial
        management systems requirements, applicable Federal accounting standards, and the U.S.
        Standard General Ledger at the transaction level.13 For compliance with DCIA, the Agency
        undertook the reversal from charge-off of over 1.1 million loans for subsequent referral to
        Treasury Debt Management Service (DMS), as well as pursuing authority with DOJ to refer
        potentially fraudulent loans to Treasury for collection. For compliance with executive orders, the
        Agency acquired new Treasury Services (AVS/EVS) for future implementation.

  •     Producing reliable and timely financial information. Provide timely and accurate data to
        support management analysis and decision-making, enable the Agency to keep pace with its
        lending partners, and effectively use automation to achieve operational efficiency.

  •     Cost-effective Service delivery. Through the Presidents efforts to reduce wasteful
        spending, the SBA is assessing our IT infrastructure to improve security posture and gain cost
        efficiencies. The Agency held detailed system spending reviews to coordinate IT spending,
        determine strategic contract consolidations, and assess improvements in mission delivery.
        Other improvements include further integration and consolidation of grant making with the
        Department of Health and Human Services (HHS) Grant Solutions, a QSMO designated provider.

  As SBA reflects on the accomplishments and lessons learned from this past year, we believe that
  adjusting our focus slightly will better enable us to support our goal of timely and accurate financial
  information to support transparency and Agency analysis and decision making. In the coming year,
  we plan to focus on the following key areas:

  •     Compliance with Laws, Regulations, and Executive Orders. While we made significant
        progress in the past year, we need to continue work towards greater compliance in a number of
        areas, including DCIA referral; continuing to work towards legal methods of referral to Treasury


  13 The Federal Financial Management Improvement Act of 1996 promotes more effective federal

      financial management by ensuring that financial management systems provide accurate, reliable,
      and timely financial management information to the government’s managers. Compliance with
      the FFMIA provides the basis for the continuing use of reliable financial management information
      by program managers, the President, Congress, and the public.


U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   38
                                                                             Management’s Discussion and Analysis (Unaudited)


        for the Agency fraud population; implementation of requirements related to executive orders,
        especially EO 14247 Modernizing Payments To and From America’s Bank Account and EO
        14249 Protecting Americas Bank Account Against Fraud, Waste, and Abuse. Significantly, OMB
        has pending guidance (required under EO 14249) regarding the consolidation of core financial
        management systems. This guidance, when issued, may have significant future impact on the
        Agency’s Financial Systems Strategy & Environment.

  •     Financial Systems Reconciliations. To provide more timely and accurate Financial Data,
        the Agency needs to implement additional reconciliations to ensure that transactions from
        the point of entry all the way through to the Agency General Ledger and Financial Statements
        are reconciled on a regular, recurring basis. Discrepancies identified should be inventoried,
        root-causes identified, and processes established to manage and correct differences between
        systems. These reconciliations should be a centralized resource that gives visibility and control to
        program offices, as well as serving as an early warning system to identify emerging problems and
        ensure that differences, when present, are known, controlled, and mitigated.

  •     Internal Controls. Internal controls are critical to the accuracy, quality, and timeliness of
        financial data. The Agency has an opportunity to re-evaluate the control environment to ensure
        that controls are operating as intended; that the control environment adapts to changing risks
        with the implementation of new controls; and the implementation of a systematic approach
        to risk identification, evaluation, control implementation, and monitoring. The feedback loop
        of financial systems reconciliations and control evaluation & implementation is a significant
        opportunity for the Agency to exploit.




U.S. Small Business Administration                                               Agency Financial Report Fiscal Year 2025   39
                                                                          Management’s Discussion and Analysis (Unaudited)



  Management Assurances: FMFIA and FFMIA
  Assurance Statement for Fiscal Year 2025
  SBA management is responsible for maintaining effective internal controls, managing risks, and
  ensuring that financial management systems operate in accordance with applicable laws and regula-
  tions. This responsibility includes compliance with the Federal Managers’ Financial Integrity Act (FM-
  FIA) of 1982, the Federal Financial Management Improvement Act (FFMIA) of 1996, and the standards
  set forth in OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management
  and Internal Control. In fulfillment of these requirements, the Agency has conducted comprehensive
  assessments of its internal controls and financial management systems for Fiscal Year (FY) 2025. This
  letter provides management’s assurance regarding the effectiveness of these controls and the sub-
  stantial compliance of financial systems. The Agency remains committed to transparency, account-
  ability, and continuous improvement in all operations.

  AMENDING PRIOR AGENCY DEFICIENCIES
  Our SBA management team recognized the Agency’s deteriorating control environment upon enter-
  ing office a few months into FY 2025. In an effort to move away from a toxic control environment un-
  der the Biden Administration, SBA senior management immediately hired leaders with the necessary
  skillsets to set a new course at the Agency and remedy the ineffective internal control environment.
  In just nine months, the SBA has established a strong governance framework to address operational
  and financial risks, as well as inform an appropriate allocation of resources. The Agency successfully
  restored prudent lending standards and returned the 7(a) portfolio to a zero-subsidy model, thereby
  protecting taxpayer dollars. Under the Trump Administration, SBA’s senior management has already
  generated real progress in substantially remediating non-pandemic related material weaknesses and
  significant deficiencies.

  MATERIAL WEAKNESSES AND REMEDIATION
  Based on the results of FY 2025 assessments, SBA management provides reasonable assurance that
  internal controls were generally effective, except for the following material weaknesses:

  •     Controls over COVID-19 Economic Injury Disaster Loans (EIDLs)

  •     Controls over Paycheck Protection Program (PPP) Loan Guarantees

  •     Entity Level Controls

  In addition, the auditor reported a material weakness related to controls over the subsidy reestimate.
  SBA management acknowledges the conditions but has concluded that one of the cited conditions
  is encompassed within the SBA’s existing material weaknesses related to controls over COVID-19 EIDL
  loans and controls over PPP loan guarantees. Because the root causes and corrective actions over-
  lap, SBA management does not classify this as a separate material weakness. Management conclud-
  ed that the remaining condition does not rise to the level of a material weakness.

  The FFMIA requires federal agencies to implement and maintain financial management systems that
  substantially comply with federal financial management systems requirements, federal account-


U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   40
                                                                         Management’s Discussion and Analysis (Unaudited)


  ing standards, and the United States Standard General Ledger. While the auditor reported that the
  Agency does not comply with certain federal financial systems requirements and federal accounting
  standards, SBA management’s assessment did not identify substantial FFMIA noncompliance. SBA
  management believes the identified deficiencies were caused by factors external to the core financial
  management systems, rather than a limitation in the system’s design or ability to prepare financial
  statements, disclosures, and related information. Based on the FFMIA criteria, the SBA is providing
  reasonable assurance that its financial management systems substantially comply with FFMIA stan-
  dards for FY 2025.

  CONCLUSION
  Based on FY 2025 assessments, SBA management provides reasonable assurance that internal con-
  trols over operations, reporting, and compliance, as well as the financial management systems, are
  effective and substantially compliant with federal requirements. Management acknowledges remain-
  ing material weaknesses and continues to implement structured remediation actions with measur-
  able results. The SBA remains committed to transparency, accountability, and continuous improve-
  ment to safeguard public resources and maintain durable internal controls across all programs and
  functions.




  Kelly Loeffler
  Administrator
  January 21, 2026




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   41
                                                                            Management’s Discussion and Analysis (Unaudited)



  SUMMARY OF MATERIAL WEAKNESSES
  1. Controls over COVID-19 EIDLs Need Improvement

  SBA management identified deficiencies in the implementation of an accounting policy change that
  occurred in the last quarter of the fiscal year. Specifically, management identified that there were
  loans that were eligible for reinstatement that were not reinstated as of September 30, 2025. This oc-
  curred because SBA did not have sufficient time prior to fiscal year end to complete the process of re-
  versing previously recorded charge off transactions for the impacted loans. The SBA will continue to
  develop corrective actions to analyze the completeness and accuracy of the population and design
  and implement controls related to the charge-off and reinstatement process.
  2. Controls over PPP Loan Guarantees Need Improvement

  SBA management identified deficiencies in the controls related to the review of PPP loan forgiveness.
  Specifically, a funds recovery process for the PPP program has not been approved or implemented.
  In addition, SBA identified that certain post payment reviews that have not been completed due to
  staffing constraints and volume. The population of forgiven PPP loans requires a risk-based, compre-
  hensive analysis to determine if additional post payment reviews may be needed and to ensure there
  is an accurate and complete population of PPP Loan Guarantees. The SBA continues to implement a
  corrective action plan to analyze the population of forgiven PPP loans and prioritize decision making
  related to a possible funds recovery plan.
  3. Entity Level Controls Need Improvement

  SBA management identified deficiencies in the entity level controls system to produce reliable and
  accurate financial reporting. Specifically, operational challenges impeded the SBA’s ability to support
  effective entity level controls. Deficiencies were identified in: (a) the SBA’s establishment of an effec-
  tive control environment, (b) performance of effective risk assessment procedures, (c) design and
  implementation of effective control activities, (d) information and communication control processes,
  and (e) monitoring processes. The agency is prioritizing strengthening its internal control frame-
  work in accordance with the Government Accountability Office’s (GAO) Standards and the Office
  of Management and Budget (OMB) Circular A-123, Managements Responsibility for Enterprise Risk
  Management and Internal Control. The SBA continues to implement corrective actions by engaging
  and communicating with the program offices early to assess, monitor, and address identified risks
  and associated controls and the effects on financial reporting and compliance with relevant laws and
  regulations.




U.S. Small Business Administration                                              Agency Financial Report Fiscal Year 2025   42
SECTION 2




 Financial
Reporting
            (UNAUDITED)
                                                                                          Financial Reporting (Unaudited)



  Message From the Chief Financial Officer
                                     January 21, 2026

                                     I am pleased to issue the Small Business Administration’s (SBA) FY
                                     2025 Agency Financial Report as of September 30, 2025. This report
                                     presents the Agency’s financial results in accordance with U.S. Of-
                                     fice of Management and Budget (OMB) guidance, and the financial
                                     statements have been developed within Generally Accepted Ac-
                                     counting Principles.

                                      The SBA remains fully committed to advancing its mission of sup-
                                      porting America’s small businesses while strengthening operational
                                      integrity, program oversight, and strategic management. Throughout
                                      FY 2025, the Agency continued to reinforce internal controls and
                                      apply rigorous oversight mechanisms to safeguard taxpayer funds.
  Under the current administration, SBA has prioritized enterprise-wide initiatives designed to improve
  oversight, reduce fraud risk, and improve program outcomes across its operating portfolio.

  The FY 2025 Agency Financial Report reflects meaningful, evidence-based progress resulting from
  sustained leadership focus, cross-functional collaboration, and disciplined execution of corrective
  action plans. During the fiscal year, three previously identified material weaknesses and two previ-
  ously identified significant deficiencies were fully remediated, and one material weakness was down-
  graded to a significant deficiency. Importantly, material weaknesses and significant deficiencies
  unrelated to COVID-19 pandemic-era programs have now been substantially resolved, demonstrating
  measurable improvement in SBA’s core financial management and control environment.

  These results reflect deliberate, methodical efforts to address longstanding issues while simultane-
  ously stabilizing operations that were significantly stressed during the unprecedented scale and
  speed of pandemic response programs. Management has taken care to distinguish between legacy
  risks arising from emergency-era programs and the control framework governing SBA’s current and
  future operations.

  Key Accomplishments in FY 2025 include:

  •     Strengthened controls over general information technology systems, guaranteeing that financial
        and operational data is securely processed, reconciled, and reported

  •     Rigorous evaluation and monitoring of service organizations, which enhances oversight of out-
        sourced functions and reduces risk of errors or misstatements

  •     Implementation of accounting and funds recovery policies and procedures for COVID-19
        pandemic-era programs, improving documentation, reconciliation, and recoverability of funds
        distributed under these programs

  •     Improved documentation, reconciliation and reporting processes across business lines, support-
        ing greater transparency and facilitating audit readiness



U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025   44
                                                                                           Financial Reporting (Unaudited)


  Collectively, these actions reinforce SBA’s stewardship of taxpayer funds and demonstrate man-
  agement’s evidence-driven approach to financial integrity. They also reflect the Agency’s ability to
  balance operational complexity with the need for robust controls, even in high-volume, high-risk
  program environments.

  We remain focused on sustaining these improvements and building upon them in the year ahead.
  The remaining material weaknesses are related to entity-level controls and complex challenges
  related to the COVID-19 pandemic era programs. In FY 2026, the agency will refine the corrective ac-
  tion plans for each remaining material weakness. The Agency recognizes strong entity-level controls
  are foundational to effective financial management and reliable financial reporting. Accordingly, the
  Agency is prioritizing strengthening its internal control framework in accordance with the Govern-
  ment Accountability Office’s (GAO) Standards and OMB Circular A-123, Managements Responsibility
  for Enterprise Risk Management and Internal Control.

  During the audit, management and the auditors held differing professional judgements related to
  assertions over the completeness of the COVID-19 EIDL loan program and the severity classification
  of identified control deficiencies. While these disagreements did not prevent the completion of the
  audit, they do contribute additional complexities around resolving certain audit findings. Manage-
  ment respects the independent role of the auditors and values their perspectives, and we remain
  committed to constructive engagement to resolve these matters. We will continue to evaluate audi-
  tor recommendations, and where appropriate, refine our processes and controls to address areas of
  concern.

  I would like to thank our financial management staff, program offices, auditors, and the SBA leader-
  ship team for their dedication and professionalism throughout this process. Their work is the foun-
  dation of SBA’s continued financial integrity and ensures that taxpayer funds are managed responsi-
  bly while supporting the nation’s small business community.

  Sincerely,




  Nathan Davis

  Chief Financial Officer and Chief Risk Officer




U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025   45
                                                                                                           Financial Reporting (Unaudited)




                                             OFFICE OF INSPECTOR GENERAL
                                         U.S. SMALL BUSINESS ADMINISTRATION



                DATE:         January 21, 2026
                TO:           Kelly Loeffler
                              Administrator
                FROM:         William W. Kirk
                              Inspector General
                SUBJECT: Independent Auditors’ Report on SBA’s Fiscal Year 2025 Financial Statements
                         (Report 26-03)
                I am pleased to present the attached independent auditors’ report on the U.S. Small Business
                Administration’s (SBA) financial statement for fiscal year (FY) 2025. The Chief Financial Officers
                Act of 1990, as amended, requires the Inspector General or an independent auditor, as
                determined by the Inspector General, to audit SBA’s financial statements.

                We contracted with the independent certified public accounting firm KPMG LLP to conduct an
                audit of SBA’s consolidated balance sheet as of September 30, 2025 and the related notes.
                KPMG was not engaged to audit the consolidated statement of net cost, consolidated statement
                of changes in net position, and combined statement of budgetary resources. Our contract
                required KPMG to conduct the audit in accordance with Government Auditing Standards (GAS)
                and Office of Management and Budget Bulletin No. 24-02, Audit Requirements for Federal
                Financial Statements.

                KPMG issued a disclaimer of opinion on the consolidated balance sheet as of September 30,
                2025. The basis for the disclaimer was that because of control deficiencies identified, SBA was
                unable to provide adequate evidential matter in support of a significant number of transactions
                and account balances related to the Paycheck Protection Program and Economic Injury Disaster
                Loan programs. Additionally, management was unable to provide sufficient appropriate audit
                evidence to support the data used to develop assumptions used in the subsidy allowance
                estimate for SBA’s direct loan and loan guaranty programs.

                During the audit, KPMG identified four material weaknesses and one significant deficiency in
                internal control over financial reporting. We note that SBA made considerable progress
                addressing prior year audit findings, resulting in the successful remediation of two material
                weaknesses (controls over general information technology and controls over the evaluation of
                service organizations) and the downgrading of one material weakness (controls over monitoring


                         409 Third St. SW, Washington, DC 20416 • (202) 205-6586 • Fax (202) 205-7382




U.S. Small Business Administration                                                            Agency Financial Report Fiscal Year 2025   46
                                                                                                         Financial Reporting (Unaudited)




               Restaurant Revitalization Fund and Shuttered Venue Operators Grant programs) to a significant
               deficiency. Appendices I and II of this report describe details of KPMG’s conclusions about the
               material weaknesses and significant deficiency. KPMG also identified three instances of
               noncompliance with applicable laws or other matters, which are discussed in Appendix III of this
               report.

               We reviewed KPMG’s report and related documentation and inquired of its personnel. Our
               review, as differentiated from an audit of the financial statements in accordance with GAS, was
               not intended to enable us to express, and we do not express, opinions on 1) SBA’s financial
               statements or internal control over financial reporting; 2) whether SBA’s financial systems
               complied substantially with the Federal Financial Management Improvement Act of 1996
               requirements; 3) or conclusions on compliance and other matters. KPMG is responsible for the
               attached auditors’ report dated January 21, 2026 and the conclusions expressed. Our review
               disclosed no instances where KPMG did not comply in all material respects with GAS.

               We appreciate the cooperation and assistance extended to KPMG and our office during the
               audit. Should you or your staff have any questions, please contact me or Andrea Deadwyler,
               Assistant Inspector General for Audits, at (202) 205-6586.

               cc:    Bill Briggs, Deputy Administrator, Office of the Administrator
                      Wesley Coopersmith, Chief of Staff, Office of the Administrator
                      Ben Grayson, Deputy Chief of Staff, Office of the Administrator
                      Robin Wright, Chief Operating Officer, Office of the Administrator
                      Nathan Davis, Chief Financial Officer and Chief Risk Officer, Office of Performance,
                        Planning, and the Chief Financial Officer
                      Deborah Chen, Deputy Chief Financial Officer, Office of Performance, Planning, and the
                        Chief Financial Officer
                      Thomas Kimsey, Associate Administrator, Office of Capital Access
                      Chris Stallings, Associate Administrator, Office of Disaster Recovery and Resilience
                      Wendell Davis, General Counsel, Office of General Counsel
                      Michael Simmons, Attorney Advisor, Office of General Counsel

               Attachment




U.S. Small Business Administration                                                          Agency Financial Report Fiscal Year 2025   47
                                                                                                                                                  Financial Reporting (Unaudited)




                                              KPMG LLP
                                              Suite 12000
                                              1801 K Street, NW
                                              Washington, DC 20006




                                                                 Independent Auditors’ Report


            Inspector General
            U.S. Small Business Administration:

            Administrator
            U.S. Small Business Administration:

            Report on the Audit of the Consolidated Financial Statement
            Disclaimer of Opinion
            We were engaged to audit the consolidated balance sheet of the United States (U.S.) Small Business
            Administration (SBA) as of September 30, 2025, and the related notes to the consolidated balance sheet (the
            consolidated financial statement).

            We do not express an opinion on the accompanying consolidated financial statement of the SBA. Because of the
            significance of the matter described in the Basis for Disclaimer of Opinion section of our report, we have not been
            able to obtain sufficient appropriate audit evidence to provide a basis for an audit opinion on the consolidated
            financial statement.

            Basis for Disclaimer of Opinion
            The SBA’s pandemic relief programs include the Paycheck Protection Program, Economic Injury Disaster Loan
            program, Restaurant Revitalization Fund program, and Shuttered Venue Operators Grant program, which were
            authorized by the Coronavirus Aid, Relief, and Economic Security Act of 2020 and related legislations. These
            programs affect a substantial proportion of SBA’s consolidated financial statement. As of the date of our audit
            report, management was still in the process of designing and implementing corrective actions to remediate control
            deficiencies identified in the prior and current years. These control deficiencies contributed to SBA’s inability to
            provide relevant and reliable information to support a significant number of transactions and account balances
            related to these programs. Additionally, management was unable to provide sufficient appropriate audit evidence to
            support the data used to develop assumptions used in the subsidy allowance estimate for SBA’s direct loan and
            loan guaranty programs. As a result of these matters, we were unable to determine whether any adjustments might
            have been necessary related to the Credit Program Receivables and Related Foreclosed Property, Net; Downward
            Reestimate Payable to Treasury; Loan Guarantee Liabilities; and the related notes.

            Other Matters
            Report on Certain Fiscal Year 2025 Information
            We were not engaged to audit the consolidated statements of net cost and changes in net position, and combined
            statement of budgetary resources for the year ended September 30, 2025, and the related notes to these
            statements. Accordingly, we express no opinion on them.

            Interactive Data
            Management has elected to reference to information on websites or other forms of interactive data outside the
            Agency Financial Report to provide additional information for the users of its consolidated financial statement. Such
            information is not a required part of the consolidated financial statement or supplementary information required by
            the Federal Accounting Standards Advisory Board. The information on these websites or the other interactive data



                                              KPMG LLP, a Delaware limited liability partnership, and its subsidiaries are part of
                                             the KPMG global organization of independent member firms affiliated with KPMG
                                              International Limited, a private English company limited by guarantee.




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            has not been subjected to any of our auditing procedures, and accordingly we do not express an opinion or provide
            any assurance on it.

            Responsibilities of Management for the Consolidated Financial Statement
            Management is responsible for the preparation and fair presentation of the consolidated financial statement in
            accordance with U.S. generally accepted accounting principles, and for the design, implementation, and
            maintenance of internal control relevant to the preparation and fair presentation of the consolidated financial
            statement that is free from material misstatement, whether due to fraud or error.

            Auditors’ Responsibilities for the Audit of the Consolidated Financial Statement
            Our responsibility is to conduct an audit of the SBA’s consolidated financial statement in accordance with auditing
            standards generally accepted in the United States of America (GAAS), Government Auditing Standards, issued by
            the Comptroller General of the United States, and Office of Management and Budget (OMB) Bulletin No. 24-02,
            Audit Requirements for Federal Financial Statements, and to issue an auditors’ report. However, because of the
            matter described in the Basis for Disclaimer of Opinion section of our report, we were not able to obtain sufficient
            appropriate audit evidence to provide a basis for an audit opinion on the consolidated financial statement.

            We are required to be independent of the SBA and to meet our other ethical responsibilities, in accordance with the
            relevant ethical requirements relating to our audit.

            Required Supplementary Information
            U.S. generally accepted accounting principles require that the information in the Management’s Discussion and
            Analysis and Required Supplementary Information sections be presented to supplement the basic consolidated
            financial statement. Such information is the responsibility of management and, although not a part of the basic
            consolidated financial statement, is required by the Federal Accounting Standards Advisory Board who considers it
            to be an essential part of financial reporting for placing the basic consolidated financial statement in an appropriate
            operational, economic, or historical context. We were unable to apply certain limited procedures to the required
            supplementary information in accordance with GAAS because of the significance of the matter described in the
            Basis for Disclaimer of Opinion paragraph. We do not express an opinion or provide any assurance on the
            information.

            Other Reporting Required by Government Auditing Standards
            Report on Internal Control Over Financial Reporting
            In connection with our engagement to audit the SBA’s consolidated financial statement as of September 30, 2025,
            we considered the SBA’s internal control over financial reporting (internal control) as a basis for designing audit
            procedures that are appropriate in the circumstances for the purpose of expressing an opinion on the consolidated
            financial statement, but not for the purpose of expressing an opinion on the effectiveness of the SBA’s internal
            control. Accordingly, we do not express an opinion on the effectiveness of the SBA’s internal control. We did not
            test all internal controls relevant to operating objectives as broadly defined by the Federal Managers’ Financial
            Integrity Act of 1982.

            Our consideration of internal control was for the limited purpose described in the preceding paragraph and was not
            designed to identify all deficiencies in internal control that might be material weaknesses or significant deficiencies
            and therefore, material weaknesses or significant deficiencies may exist that were not identified. However, as
            described in the accompanying Appendices I and II, we identified certain deficiencies in internal control that we
            consider to be material weaknesses and significant deficiencies.

            A deficiency in internal control exists when the design or operation of a control does not allow management or
            employees, in the normal course of performing their assigned functions, to prevent, or detect and correct,
            misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal
            control, such that there is a reasonable possibility that a material misstatement of the entity’s financial statement




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            will not be prevented, or detected and corrected, on a timely basis. We consider the deficiencies described in the
            accompanying Appendix I to be areas of material weaknesses.

            SBA management did not report the material weakness, Controls over Subsidy Reestimate Need Improvement, in
            its Statement of Assurance, included in Management's Discussion and Analysis section of the accompanying
            Agency Financial Report.

            A significant deficiency is a deficiency, or a combination of deficiencies, in internal control that is less severe than a
            material weakness, yet important enough to merit attention by those charged with governance. We consider the
            deficiencies described in the accompanying Appendix II to be significant deficiencies.

            Report on Compliance and Other Matters
            In connection with our engagement to audit the SBA’s consolidated financial statement as of September 30, 2025,
            we performed tests of its compliance with certain provisions of laws, regulations, contracts, and grant agreements,
            noncompliance with which could have a direct and material effect on the consolidated financial statement.
            However, providing an opinion on compliance with those provisions was not an objective of our engagement, and
            accordingly, we do not express such an opinion. The results of our tests disclosed instances of noncompliance or
            other matters that are required to be reported under Government Auditing Standards or OMB Bulletin No. 24-02,
            and which are described in the accompanying Appendix III.

            We also performed tests of the SBA’s compliance with certain provisions referred to in Section 803(a) of the
            Federal Financial Management Improvement Act of 1996 (FFMIA). Providing an opinion on compliance with FFMIA
            was not an objective of our engagement, and accordingly, we do not express such an opinion. The results of our
            tests disclosed instances, described in the accompanying Appendix III as item C, in which the SBA’s financial
            management systems did not substantially comply with the (1) Federal financial management systems
            requirements, and (2) applicable Federal accounting standards. The results of our tests disclosed no instances in
            which the SBA’s financial management systems did not substantially comply with the United States Government
            Standard General Ledger at the transaction level.

            Additionally, if the scope of our work had been sufficient to enable us to express an opinion on the consolidated
            financial statement, other instances of noncompliance or other matters may have been identified and reported
            herein.

            SBA’s Response to Findings
            Government Auditing Standards requires the auditor to perform limited procedures on the SBA's response to the
            findings identified in our engagement and described in the accompanying Appendix IV. The SBA’s response was
            not subjected to the other auditing procedures applied in the engagement to audit the consolidated financial
            statement and, accordingly, we express no opinion on the response.

            Purpose of the Other Reporting Required by Government Auditing Standards
            The purpose of the communication described in the Report on Internal Control Over Financial Reporting and the
            Report on Compliance and Other Matters sections is solely to describe the scope of our testing of internal control
            and compliance and the results of that testing, and not to provide an opinion on the effectiveness of the SBA’s
            internal control or compliance. This communication is an integral part of an engagement to audit in accordance with
            Government Auditing Standards in considering the SBA’s internal control and compliance. Accordingly, this
            communication is not suitable for any other purpose.




            Washington, DC
            January 21, 2026




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                                                                                                                   Appendix I
                                                   U.S. Small Business Administration
                                                           Material Weaknesses
              The following deficiencies are considered to be areas of material weaknesses in internal controls over financial
              reporting.
                   1. Controls over Coronavirus Disease 2019 (COVID-19) Economic Injury Disaster Loans (EIDLs)
                      Need Improvement

                   2. Controls over Paycheck Protection Program (PPP) Loan Program Need Improvement

                   3. Controls over Subsidy Reestimate Need Improvement

                  4. Entity Level Controls Need Improvement

              Background
              The COVID-19 EIDL direct loan and PPP guaranty loan programs were authorized and funded by the
              Coronavirus Aid, Relief, and Economic Security Act of 2020, and the Paycheck Protection Program and
              Health Care Enhancement Act. The referenced laws are collectively referred to as the CARES Act and
              related legislation. The CARES Act and related legislation were passed by Congress to provide emergency
              assistance in response to the extensive effects of the public health and economic crisis arising from the
              COVID-19 pandemic. The COVID-19 EIDL and PPP programs affect a substantial proportion of the
              consolidated financial statement.

              The 7(a) Loan Guaranty Program, SBA’s primary business loan program, provides loan guarantees to lenders
              that allow them to provide financial help for small businesses.

              1. Controls over COVID-19 EIDLs Need Improvement

              The COVID-19 EIDL transactions were approved in fiscal years 2020 through 2022. These loans have a 30-
              year term, and the originating payment start date was deferred by the SBA for up to 30 months after the loan
              disbursement. The payment deferral period ended for a significant number of COVID-19 EIDLs beginning in
              fiscal year 2023 and continued into fiscal year 2024. As COVID-19 EIDLs began repayment in fiscal years 2023
              and 2024, a substantial number became delinquent, and many were identified by management as potentially
              fraudulent. Consequently, management charged off many of these delinquent and potentially fraudulent
              COVID-19 EIDLs. In fiscal year 2025, management implemented a funds recovery accounting policy for
              COVID-19 EIDLs and concluded that all COVID-19 EIDLs previously charged off on the basis of a prior charge-
              off policy should be reinstated and recorded as Credit Program Receivables in accordance with SFFAS 2. As a
              result of the updated funds recovery accounting policy, SBA reinstated a large volume of COVID-19 EIDLs as
              Credit Program Receivables. Management reinstated these loans based on the anticipation of further
              collectability.

              Management did not design and implement adequate monitoring controls over the COVID-19 EIDL portfolio to
              ensure reliable financial reporting as of the end of the fiscal year. Management’s analysis did not support the
              completeness and accuracy of the COVID-19 EIDL population of loans and related data elements as of the
              balance sheet date. Management did not sufficiently design and implement a review control to identify a
              complete population of loans with eligibility concerns that are critical in assessing the completeness and
              accuracy of the COVID-19 EIDL Credit Program Receivable balances. In addition, the monitoring controls for
              reviewing the loan status of COVID-19 EIDLs were not adequately designed to detect instances where the
              recorded loan status was not supported by the underlying accounting records or loan life cycle events.




                                                                      




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              Management did not apply consistent accounting treatment of COVID-19 EIDLs with fraud-related hold codes
              where there is no anticipated further collectability. As a result, a sub-population of loans with these fraud-
              related hold codes were not excluded from the Credit Program Receivable balance based on management’s
              fiscal year 2025 funds recovery accounting policy.

              Further, management’s review controls over their reinstatement process did not provide sufficient evidence to
              support the completeness and accuracy of the COVID-19 EIDL population as of the balance sheet date. For
              example, a sub-population of charged-off loans that management intended to reinstate had not been reinstated
              as of fiscal year-end and therefore were not reflected in the Credit Program Receivable balance. In addition,
              management reinstated certain loans which were not eligible for reinstatement.

              These deficiencies were caused by challenges, such as complexity and considerable effort, in retroactively
              generating the necessary point-in-time historical population data from the current system used for the portfolio
              analysis as of the end of the fiscal year. Additionally, management’s review controls were not adequately
              designed and implemented to identify a complete and accurate population of COVID-19 EIDLs with potential
              eligibility concerns. Further, the reinstatement controls implemented by management were not implemented
              effectively to complete all eligible loan reinstatements before fiscal year-end. Finally, management’s information
              systems were not designed to properly update the loan status of COVID-19 EIDLs to ensure the loan status
              was correct and supported by the underlying transactions.
              The following criteria were considered with respect to the matters described in the preceding paragraphs:

                       •   GAO’s Green Book, Principle 3, Establish Structure, Responsibility, and Authority; Principle 6,
                           Define Objectives and Risk Tolerances; Principle 7, Identify, Analyze, and Respond to Risks;
                           Principle 9, Identify, Analyze, and Respond to Change; Principle 10, Design Control Activities;
                           Principle 11, Design Activities for the Information System; Principle 12, Implement Control
                           Activities; and Principle 16, Perform Monitoring Activities

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              The deficiencies described above may result in a material misstatement of the Credit Program
              Receivables and Related Foreclosed Property, Net and Downward Reestimate Payable to Treasury line
              items, and related elements in the consolidated financial statement.

              Recommendations – Controls over COVID-19 EIDLs Need Improvement

              We recommend the Administrator coordinate with the Associate Administrator for the Office of Capital
              Access to:
                       1. Establish and document a process to generate, save, and securely retain complete data
                          extracts of loan populations and relevant data elements (e.g., loan status, balances) as of the
                          date that management’s analyses are performed (such as the fiscal year-end). This process
                          will ensure relevant data is maintained by management to support their analyses for financial
                          reporting purposes.

                       2. Implement a comprehensive, risk-based, and proactive process that regularly assesses the
                          loan population for potential fraud or ID theft concerns (e.g. periodic systematic reviews, data
                          analytics, or other proactive monitoring controls). (2024, recommendation 1)

                       3. Apply consistent accounting treatment of non-performing loans with open agency hold codes.

                       4. Consistently implement financial reporting controls to ensure the Credit Program Receivable
                          balance is completely and accurately stated throughout the fiscal year. If new policies are
                          implemented, conduct an analysis to assess the financial reporting implications. (2024,
                          recommendation 2)




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                       5. Review controls over information technology program changes within the applicable systems
                          of record for loan accounting so that they are designed, implemented and operating
                          effectively, to ensure changes are appropriate and function as intended, and the information
                          systems reflect the underlying accounting transactions. (2024, recommendations 3 & 4)

              2. Controls over PPP Loan Program Need Improvement

              The PPP program terms, authorized by the CARES Act and related legislation, permitted for the
              forgiveness of PPP loan guarantees if the borrower met the forgiveness criteria. To request forgiveness,
              borrowers submit the forgiveness application to the lenders for approval. The lenders will subsequently
              notify SBA of their forgiveness decision and submit the request to SBA.

              Management’s post-payment review control was not sufficiently designed and implemented to determine
              the appropriate status and financial reporting impact of PPP loans forgiven as of September 30, 2025.
              Specifically, management indicated that post-payment reviews were conducted on only two percent of the
              total population of forgiven PPP loans. Additionally, management’s process and related control activities
              for recovering funds of PPP loans with eligibility concerns that were identified and confirmed after
              forgiveness were not fully documented or implemented. While management established a funds recovery
              accounting policy, the implementation of related control activities was ongoing as of fiscal year-end.

              These deficiencies were caused by the volume of forgiveness payments and management’s ability to remediate
              other deficiencies, which prevented SBA from completing all corrective actions. Consequently, the risk
              assessment process did not adequately evaluate or address the risks associated with post-payment review and
              funds recovery for PPP loans.

              The following criteria were considered with respect to the matter described in the preceding paragraphs:

                       •   GAO’s Green Book, Principle 3, Establish Structure, Responsibility, and Authority; Principle 6,
                           Define Objectives and Risk Tolerances; Principle 7, Identify, Analyze, and Respond to Risks; and
                           Principle 10, Design Control Activities

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              The deficiencies described above may result in a material misstatement to the Credit Program
              Receivables and Related Foreclosed Property, Net, and Downward Reestimate Payable to Treasury line
              items, and other related elements in the consolidated financial statement.
              Recommendations – Controls over PPP Loan Program Need Improvement
              We recommend the Administrator coordinate with the Associate Administrator for the Office of Capital
              Access to:
                       6. Establish regular monitoring and reporting control activities to track progress of post payment
                          reviews, to ensure timely and effective decision making related to implementation of funds
                          recovery policies and procedures. (2024, recommendation 7)

                       7. Strengthen the risk assessment process and conduct a risk-based, comprehensive analysis of
                          the entire population of forgiven PPP loans to identify whether additional reviews may be
                          needed in determining the complete and accurate population for funds recovery. (2024,
                          recommendation 8)




                                                                      




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              3. Controls over Subsidy Reestimate Need Improvement

              Statement of Federal Financial Accounting Standards Number 2, Accounting for Direct Loans and Loan
              Guarantees, requires that direct loans and loan guarantees obligated after September 30, 1991, be
              recorded on a present value basis consistent with the intent of the Federal Credit Reform Act of 1990. As
              such, SBA developed an estimation methodology to reestimate annually the future net cash inflows and
              outflows for the COVID-19 EIDLs and PPP loan portfolios as of the end of the fiscal year.
              Management’s review controls were not adequately designed and implemented over the data inputs used
              in the PPP and 7(a) Loan Guaranty subsidy reestimate models. Specifically, management did not provide
              sufficient documentation to evidence adequate review controls to validate the reliability of loan data used
              in key assumptions for the cash flow PPP model to develop the subsidy cost estimates. Further,
              management did not provide sufficient appropriate audit evidence to support the reliability for all key data
              elements used in the 7(a) reestimate model.
              In addition, management did not design and implement adequate review controls over the data inputs
              used for COVID-19 EIDLs subsidy reestimate. The reviews were in process as of the end of the fiscal year
              and not appropriately designed to identify a complete and accurate COVID-19 EIDLs population of
              outstanding loans disbursed to eligible recipients.

              These deficiencies were caused by management’s inability to coordinate and obtain the supporting
              documentation necessary to provide sufficient appropriate audit evidence to support the relevant data
              elements. Additionally, the control environment was insufficient with respect to the design and implementation
              of controls over the review of the PPP and COVID-19 EIDL portfolios. This review control was not sufficiently
              precise to ensure that the data inputs used for the reestimate models were complete and accurate.
              The following criteria were considered with respect to the matter described in the preceding paragraphs:

                       •   GAO’s Green Book, Principle 3, Establish Structure, Responsibility, and Authority; Principle 10,
                           Design Control Activities; Principle 13, Use Quality Information; and Principle 14, Communicate
                           Internally

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              The deficiencies described above may result in a material misstatement to the subsidy reestimate
              impacting the Liability for Loan Guarantees, the Allowance for Direct Loan Receivables, and the
              Downward Reestimate Payable to Treasury and the related elements in the consolidated financial
              statement.

              Recommendations – Controls over Subsidy Reestimate Need Improvement

              We recommend the Administrator coordinate with the Chief Financial Officer to:
                       8. Identify and implement a method to improve SBA’s ability to demonstrate evidence of
                          adequate support and controls over relevant data elements in a timely manner.

                       9. Continue implementing review controls in collaboration with relevant program offices for the
                          PPP and COVID-19 EIDL portfolios to accumulate relevant, complete and accurate data on
                          which to base the reestimate. (2024, recommendation 23)

              4. Entity Level Controls Need Improvement

              Management faced challenges in maintaining an adequate entity level controls system and enterprise risk
              management infrastructure and did not design or implement effective controls necessary to achieve its intended
              objective of reliable and accurate financial reporting. The significance of the internal control matters indicated
              weaknesses across several entity level control categories. The following conditions were identified.



                                                                       




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              A. Control Environment

              Management did not establish an effective control environment. The following deficiencies were identified:

                       •   Management did not establish an agency-wide oversight body to govern the internal control system
                           during the fiscal year.

                       •   Management did not establish a formal internal control plan to support the entity’s financial
                           reporting objectives. In addition, there was no formal planning and accountability for the design and
                           testing of controls.

                       •   Management did not effectively identify and remediate gaps in personnel roles and responsibilities
                           within the agency’s organizational structure, particularly regarding the delegation of authority and
                           assignment of roles within certain program offices.

              B. Risk Assessment

              Management did not perform effective risk assessment processes. The following deficiencies were identified:

                       •   Management did not establish a coordinated agency-wide risk assessment framework and a
                           comprehensive evaluation of financial reporting. In addition, management did not perform an
                           analysis of program and agency changes to address evolving risks specific to the fiscal year.

                       •   Management did not implement adequate risk assessment processes to effectively identify,
                           analyze, and respond to relevant financial and reporting compliance risks for fiscal year 2025. For
                           example, management did not sufficiently evaluate the risks related to the large-scale
                           reinstatement of certain pandemic program transactions or consider the potential impact on the
                           completeness of related portfolio balances in the consolidated financial statement. Additionally,
                           management did not adequately respond to the increased risk of noncompliance with applicable
                           laws arising from the significant volume of loans in delinquency status during fiscal year 2025.

              C. Control Activities

              Management did not adequately design and implement effective control activities. The following deficiencies
              were identified:

                       •   Management did not develop or implement agency-wide internal control testing plans during the
                           fiscal year to support the entity’s financial reporting and compliance objectives, respond to relevant
                           risks, or to achieve an effective internal control system.

                       •   Management did not adequately design or implement controls within the relevant program offices
                           to operate at a sufficient level of precision to achieve the reporting objective of preparing financial
                           statements free from material misstatement. For instance, the COVID-19 EIDLs and PPP loan
                           review processes were not designed to ensure that the reviews conducted were precise enough to
                           confirm that the related balances were free of material misstatement.

              D. Information & Communication

              Management did not adequately design and implement effective information and communication control
              processes. Specifically, management did not establish an agency-wide oversight body during the fiscal year to
              govern the internal control system. As a result, quality information on internal controls, policies, and procedures
              was incomplete, insufficient, unavailable, and impeded effective communication across all levels of authority
              and lines of responsibility to achieve internal control objectives.




                                                                        




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              E. Monitoring
              Management did not design and implement effective monitoring processes. The following deficiencies were
              identified:

                       •   Management did not establish formal internal control testing plans at the agency-wide level,
                           resulting in a lack of effective monitoring activities to evaluate the effectiveness of internal controls
                           across the agency.

                       •   While certain deficiencies identified in the prior year were remediated, management did not fully
                           design and implement corrective action plans to effectively remediate prior year findings in the
                           current fiscal year.

              These deficiencies were caused by operational challenges that impeded the agency’s ability to support
              effective entity level controls throughout the fiscal year. A transition plan was under development at the end of
              the fiscal year to respond to resource constraints in order to properly prioritize and execute the agency’s
              enterprise risk management process, including the establishment of an agency-wide oversight body,
              development of internal control testing plans, and risk assessment frameworks.

              The following criteria were considered with respect to the matters described in the preceding paragraphs:

                       •   GAO’s Green Book, Principle 2, Exercise Oversight Responsibility; Principle 4, Demonstrate
                           Commitment to Competence; Principle 6, Define Objectives and Risk Tolerances; Principle 7,
                           Identify, Analyze, and Respond to Risks; Principle 9, Identify, Analyze, and Respond to Change;
                           Principle 10, Design Control Activities; Principle 12, Implement Control Activities; Principle 13, Use
                           Quality Information; Principle 14, Communicate Internally; Principle 16, Perform Monitoring
                           Activities; and Principle 17, Evaluate Issues and Remediate Deficiencies

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              As a result of the deficiencies described above, we noted that without the proper level of entity level controls
              in place and operating effectively, there is an increased risk that a material misstatement in the consolidated
              financial statement, and noncompliance with the relevant laws and regulations would neither be prevented
              nor detected and corrected in a timely manner.

              Recommendations – Entity Level Controls Need Improvement

              We recommend that the Administrator coordinate with the Chief Financial Officer to:

                       10. Finalize and implement the transition plan to respond to resource constraints, which includes
                           establishing the proper delegation of authority for personnel roles and responsibilities,
                           ensuring the agency can properly design and effectively operate entity level controls
                           throughout the fiscal year.

                       11. Establish an agency-wide oversight body to provide governance, guidance, information and
                           communication over internal control systems and risk management activities.

                       12. Design, implement, and document comprehensive internal control testing plans and regularly
                           monitor and evaluate the effectiveness of internal controls. (2024, recommendation 32)

                       13. Coordinate with key stakeholders to develop robust risk assessment frameworks to identify,
                           analyze, and respond to emerging or evolving risks across the agency. (2024,
                           recommendation 31)




                                                                         




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                                                                                                                  Appendix II
                                                   U.S. Small Business Administration
                                                          Significant Deficiencies

              Monitoring of Restaurant Revitalization Fund and Shuttered Venue Operators Grant Programs Need
              Improvement
              A. Monitoring of RRF Awards
              The period to use RRF awards for eligible purposes expired in fiscal year 2023. SBA relies on award
              recipients to submit Post Award Reports to disclose the amount of the award used on eligible purposes prior to
              expiration. If any amount of the award was not used for eligible purposes before expiration, the unused funds
              must be returned to SBA. In fiscal year 2025, SBA implemented a process for funds recovery for RRF awards
              with eligibility concerns.

              Management did not sufficiently design and implement monitoring controls to evaluate the accuracy and
              completeness of accounts receivable balances impacted by their recovery of funds efforts. Management
              reviewed a sample of RRF awards and completed testing at the end of the fiscal year. However,
              management did not perform a detailed analysis and extrapolation of results. Further, management did
              not assess whether additional testing was needed to support the balances recorded at fiscal year-end.

              These deficiencies were caused by management’s risk assessment process not incorporating a final evaluation
              of sample results to determine whether the sampling risk was appropriate and supported their adjustments to
              accounts receivable related to the recovery of funds for RRF awards.
              The following criteria were considered with respect to the matters described in the preceding paragraphs:

                       •   GAO’s Green Book, Principle 10, Design Control Activities; and Principle 16, Perform Monitoring
                           Activities

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              The deficiencies described above may result in a misstatement to the Other than Intragovernmental
              Accounts Receivable, Net, line item and the related elements in the consolidated financial statement.
              Recommendations – Monitoring of RRF Awards
              We recommend the Administrator coordinate with the Associate Administrator for the Office of Capital
              Access to:
                       14. Design and implement key monitoring control procedures earlier in the fiscal year to allow
                           adequate time for thorough execution, review, and analysis before year-end. (2024,
                           recommendation 15)

                       15. Conduct a risk-based, comprehensive analysis of the RRF sample review results to identify
                           whether additional reviews may be needed in determining the complete and accurate
                           population for funds recovery. (2024, recommendation 16)

              B. Monitoring of SVOG Awards
              The period to use SVOG funds for eligible purposes expired in fiscal year 2023. The SBA relies on award
              recipients to submit an Expense Report and Standard Form (SF) 425, Federal Financial Report, to disclose the
              amount of the award used for eligible purposes prior to expiration. If any amount of the award was not used for
              eligible purposes before expiration, the unused funds must be returned to SBA. In fiscal year 2025, SBA
              implemented a process for funds recovery for SVOG awards with eligibility concerns.




                                                                      




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              Management’s monitoring controls over SVOG awards to ensure compliance with the CARES Act and
              related legislation, as well as accurate financial reporting at fiscal year-end were not fully implemented.
              Specifically, as of September 30, 2025, certain awards lacked a submitted Expense Report or SF-425.
              Management also selected samples of SVOG awards to assess the accuracy of report submissions and
              recipient eligibility. However, sample reviews were not completed by the end of the fiscal year.
              Furthermore, management’s funds recovery process was not fully implemented for SVOG awards with
              identified eligibility concerns to support the balances recorded at year-end.

              These deficiencies were caused by the design and implementation of the funds recovery procedures occurring
              close to fiscal year-end, resulting in insufficient time to thoroughly execute sample reviews.
              The following criteria were considered with respect to the matters described in the preceding paragraphs:

                       •   Federal Accounting Standards Advisory Board (FASAB) Statement of Federal Financial Accounting
                           Standards 1 (SFFAS 1): Accounting for Selected Assets and Liabilities

                       •   GAO’s Green Book, Principle 10, Design Control Activities; and Principle 13, Use Quality
                           Information

              The deficiencies described above may result in a misstatement to the Other than Intragovernmental
              Accounts Receivable, Net, line item and the related elements in the consolidated financial statement.
              Recommendations – Monitoring of SVOG Awards
              We recommend the Administrator coordinate with the Associate Administrator for the Office of Disaster,
              Recovery, and Resilience to:
                       16. Complete the outstanding sample reviews to identify the complete population of recipients that may
                           not have been eligible to receive awards or that may have spent awards on ineligible expenses in
                           accordance with the program’s terms. This will ensure the data provided to the Office of
                           Performance, Planning, and the Chief Financial Officer (OPPCFO) is complete, accurate and
                           reported in a timely manner for year-end financial reporting. (2024, recommendations 18 & 19)




                                                                      




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                                                                                                                   Appendix III
                                                   U.S. Small Business Administration
                                                      Compliance and Other Matters
              A. Debt Collection Improvement Act of 1996, as amended (DCIA)

              Certain provisions of the DCIA require agencies to notify and refer debts that are delinquent by 120 days or
              more, for purposes of administrative offset and centralized collection, to the U.S. Department of Treasury
              (Treasury).
              Management did not refer delinquent loans to the Treasury for collection within the required timeframe.
              Management identified and communicated that approximately 481,258 COVID-EIDLs and 81,782 PPP loans
              were noncompliant with DCIA requirements for the fiscal year ended September 30, 2025.
              In addition, management did not design and implement effective controls to identify and refer delinquent loans
              that meet the criteria for referral to Treasury to ensure compliance with DCIA requirements.
              The conditions identified were caused by inadequate design and implementation of risk assessment and
              monitoring processes that enable management to identify, analyze, and respond to the relevant risks of
              noncompliance and to ensure delinquent loans were identified and referred to Treasury within the required
              timeframe. Also, the deficiencies were caused by inadequate system configuration in place to refer delinquent
              loans to Treasury within the appropriate timeframe.
              The following criteria were considered with respect to the matter described in the preceding paragraphs:

                       •   DCIA

                       •   GAO’s Green Book, Principle 9, Identify, Analyze, and Respond to Change; Principle 10, Design
                           Control Activities; and Principle 16, Performing Monitoring Activities.

              As a result of delays and absence of referrals of delinquent borrowers and guarantors to Treasury, SBA did
              not comply with DCIA requirements.

              Recommendations – DCIA

              We recommend the Administrator coordinate with the Associate Administrator for the Office of Capital Access
              to:
                       17. Reevaluate delinquency policies and procedures, such as system controls and configurations, to
                           ensure borrowers are notified timely of delinquency, and if applicable, subsequently referred within
                           the required timeframe. (2024, recommendation 52)

                       18. Update risk assessment and monitoring controls to address and mitigate noncompliance risks
                           related to DCIA. (2024, recommendation 51)

                       19. Document the review and assessment of current and prospective processes and policies to ensure
                           they address compliance risks. (2024, recommendation 50)




                                                                       




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              B. Federal Managers’ Financial Integrity Act of 1982 (FMFIA)

              Management did not perform an internal control assessment as required under FMFIA and did not comply with
              FMFIA and the related OMB Circular No. A-123 requirements. Specifically, management did not:

                       •   Document a comprehensive evaluation of internal control over financial reporting regarding current
                           programs while giving consideration to relevant risks during the fiscal year.

                       •   Design or establish a formal internal control program, including the design and implementation of
                           risk assessment processes and testing across SBA programs and functions.

                       •   Ensure their own assurance process was sufficient to identify material weaknesses and significant
                           deficiencies that existed during the fiscal year in addition to those identified by external auditors.

              This noncompliance was caused by operational challenges that impeded the agency’s ability to support
              effective entity level controls and FMFIA compliance throughout the fiscal year. A transition plan was under
              development at the end of the fiscal year to properly prioritize and execute the agency’s enterprise risk
              management process, which led to insufficient oversight and validation in management’s assurance process.

              The following criteria were considered with respect to the matter described in the preceding paragraphs:

                       •   Section 2 of FMFIA

                       •   OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk Management and
                           Internal Control

              Management did not comply with FMFIA and the related OMB Circular No. A-123 requirements, which may
              lead to not identifying the appropriate risks and key controls, and not detecting internal control or compliance
              deficiencies. The risk of not detecting and correcting control deficiencies could result in misstatements to the
              consolidated financial statement.

              Recommendations – FMFIA

              We recommend the Administrator coordinate with the Chief Financial Officer to:
                       20. Strengthen controls, such as entity level controls, manual controls, general information technology
                           controls, and system application controls by developing standardized procedures for assessing and
                           reporting on internal controls across all offices within SBA. (2024, recommendation 53)

                       21. Collaborate with appropriate program office management to assess internal control testing results
                           and revise corrective action plans to remediate identified control deficiencies. (2024,
                           recommendation 54)

                       22. Update existing policies and implement effective monitoring controls that incorporate independent
                           validations of program offices’ Statement of Assurance (SOA) process. Ensure that SOAs from all
                           program offices are thoroughly documented and independently reviewed for completeness and
                           accuracy, providing a reliable basis for the Administrator’s SOA. (2024, recommendation 55)




                                                                        




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              C. Federal Financial Management Improvement Act of 1996 (FFMIA)

              Management did not establish and maintain financial management systems that substantially comply with the
              following FFMIA requirements:

                       •   Federal Financial Management Systems Requirements. As discussed in Appendix I – Material
                           Weaknesses, control deficiencies over direct and guaranty loan transactions do not enable reliable
                           and accurate financial reporting, do not ensure compliance objectives are met.

                       •   Federal Accounting Standards. The deficiencies identified and reported in Appendix I – Material
                           Weaknesses, provide an indication that SBA’s financial systems were substantially noncompliant
                           with applicable federal accounting standards. For example, management did not apply consistent
                           accounting treatment over the COVID-19 EIDL and PPP loan programs.

              Management did not substantially meet FFMIA requirements because of the reasons discussed in Appendix I –
              Material Weaknesses and due to an inadequate agency-wide control environment to implement the provisions
              of the CARES Act and related legislation with sufficiently designed and implemented controls.
              The following criteria were considered with respect to the matter described in the preceding paragraphs:

                       •   Section 803(a) of FFMIA

                       •   GAO’s Green Book, Section 2, Establishing an Effective Internal Control System

                       •   Appendix D to OMB Circular No. A-123, Compliance with the Federal Financial Management
                           Improvement Act of 1996

              Management did not substantially comply with FFMIA, increasing the risk that transactions are incorrectly
              recorded to the general ledger, impacting the completeness, existence, and accuracy of the balances in the
              consolidated financial statement.

              Recommendations – FFMIA

              We recommend the Administrator coordinate with the Chief Financial Officer to:
                       23. Address the control deficiencies over transactions arising from the implementation of the
                           CARES Act and related legislation by working with the Office of Capital Access and the Office
                           of Disaster Recovery and Resilience to implement the recommendations in Appendix I –
                           Material Weaknesses. (2024, recommendation 56)




                                                                      




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                              CFO Response to Audit Report on FY 2025 Financial Statements


                 DATE:               January 21, 2026

                 TO:                 William Kirk, Inspector General

                 FROM:               Nathan Davis, Chief Financial Officer and Chief Risk Officer

                 SUBJECT:            FY 2025 Financial Statement Audit



                The Small Business Administration (SBA) has reviewed the Independent Auditors’ Report issued
                by KPMG, which includes a disclaimer of opinion on the Agency’s FY 2025 Consolidated Balance
                Sheet. The independent audit of the Agency’s financial statements and related processes is a core
                component of SBA’s financial management program, and management takes the results of this
                audit seriously.

                The FY 2025 Agency Financial Report (AFR) reflects meaningful improvements resulting from
                sustained leadership focus, cross-functional collaboration and disciplined execution of corrective
                action plans. During the fiscal year, material weaknesses related to Controls over Service
                Organizations and Controls over General Information Technology were fully remediated. In
                addition, significant deficiencies related to Controls over Payments for Debt Relief and Controls
                over Reporting of Contingencies were also fully remediated. Further, the material weakness
                related to Controls over Monitoring of Restaurant Revitalization Fund and Shuttered Venues
                Operators Grant Programs was downgraded to a significant deficiency. These outcomes
                demonstrate tangible progress in strengthening SBA’s financial management and internal control
                environment.

                The auditors identified material weaknesses related to the internal controls over four areas:
                COVID-19 Economic Injury Disaster Loans (EIDL), Paycheck Protection Program (PPP) Loan
                Program, Subsidy Reestimate, and Entity Level Controls. Management agrees that certain
                conditions identified in the audit report and associated with these material weaknesses were the
                result of the auditors’ inability to obtain sufficient and appropriate audit evidence. However,
                management does not fully concur with several underlying characterizations and contributing
                factors that are presented within the audit report for the reported material weaknesses related to
                internal controls over COVID-19 EIDL and Subsidy Re-estimate. In particular,
                     •   Management disagrees with the characterization that the COVID-19 EIDL population
                         analysis was inadequate as of the balance sheet date (September 30, 2025). Management
                         assessed the population and concluded that it was complete and appropriate for financial
                         reporting purposes. Management acknowledges, however, that certain data attributes
                         supporting this analysis were not available in the form requested by KPMG at the time of
                         their audit procedures (December 2025), due to the inability to reproduce the population at




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                         a prior point in time. This limitation reflects challenges associated with retrospective audit
                         evidence requirements rather than deficiencies in management’s assessment as of the
                         reporting date. (Material Weakness 1)

                         Additionally, management disagrees with the auditors’ conclusions regarding certain
                         review controls. SBA does not believe that additional reviews of the population for potential
                         fraud or identity theft would alter management’s assessment of the completeness of the
                         population for financial reporting purposes. (Material Weakness 1, Recommendation 1)

                         Management agrees that a material weakness exists related to controls over COVID-19
                         EIDLs because of inconsistent accounting treatment of the COVID EIDL population and
                         the need for improvements in the controls over the reinstatement process implemented in
                         the fourth quarter of FY 2025. (Material Weakness 1)

                     •   Management does not believe that there is a clear or likely indicator that SBA does not have
                         adequate controls over the data inputs used in the 7(a) Loan Guaranty subsidy reestimate
                         model. The conditions noted by the auditor in the reported subsidy reestimate material
                         weakness were primarily due to the timing of when the audit procedure was initiated and
                         performed; the complexity involved with obtaining documentation from third parties,
                         which increases the amount of time necessary to obtain supporting documents; and the
                         fact that this was the first time this audit procedure was performed, which led to a
                         “learning curve” for both the auditor and SBA as to the best approach for testing and
                         obtaining documentation for audit evidence. Although SBA does not agree that the
                         conditions reported are likely to result in a material misstatement, SBA is committed to
                         identifying and implementing a method that improves SBA’s ability to demonstrate
                         evidence of adequate support and controls over the over the data elements in a timely
                         manner. (Material Weakness 3)

                         Additionally, management disagrees with the inclusion of PPP and COVID-19 EIDL within
                         the reported material weakness related to controls over the subsidy reestimate. The
                         underlying conditions and impacts associated with PPP and COVID-19 EIDL are already
                         reflected within Material Weaknesses 1 and 2. Because the root causes and corrective
                         actions overlap, inclusion within the subsidy reestimate material weakness is duplicative
                         and may be misleading. Additionally, as indicated above, management disagrees with the
                         auditor regarding COVID-19 EIDL review controls. SBA does not believe additional
                         reviews of the population would alter its assessment of completeness of the population.
                         (Material Weakness 3, Recommendation 9)

                     •   Management does not agree that SBA is not in substantial compliance with the FFMIA.
                         SBA’s core financial management systems are substantially compliant with Federal
                         financial management systems requirements, applicable Federal accounting standards and




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                         USSGL at the transaction level. The deficiencies the auditor cited as causing FFMIA non-
                         compliance were due to factors external to the core financial management systems, rather
                         than a limitation in the system’s design or ability to prepare financial statements,
                         disclosures and related information. For example, SBA’s assessment is that the material
                         weaknesses cited by the auditor are related to the COVID-19 EIDL and PPP programs are
                         the result of material uncertainty regarding completeness of populations and potential
                         funds recovery policy decisions. As such, management does not believe this constitutes
                         substantial FFMIA noncompliance. (Compliance C, Recommendation 23)

                Management respects the independent role of the auditors and values their perspectives, and
                we remain committed to constructive engagement to resolve these matters. At the same time,
                management believes it is important to distinguish between limitations associated with large-
                scale COVID-19 pandemic-era programs, which were executed under emergency conditions,
                and the effectiveness of SBA’s current control environment governing ongoing operations.

                Notwithstanding these differences, management recognizes the seriousness of the conditions
                contributing to the disclaimer of opinion. SBA remains focused on sustaining the improvements
                achieved in FY 2025 and building upon them in the year ahead. Management will continue to
                evaluate auditor recommendations and, where appropriate, refine our processes and controls to
                address identified areas of concern.

                We appreciate the efforts of the Office of the Inspector General and KPMG, and we remain
                committed to continued progress in strengthening SBA’s financial management and oversight
                capabilities.




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                                                                                                                 Appendix V

                                           Auditors’ Response to Management’s Response

              We acknowledge SBA management’s response to our Independent Auditors’ Report, presented in Attachment
              IV, and commend their commitment to financial management and the accountability for and transparency of
              their programs. SBA management agreed with two of the areas of material weakness included in our report,
              Controls over Paycheck Protection Program (PPP) Loan Program Need Improvement and Entity Level Controls
              Need Improvement. However, management did not agree in part with the other two areas of material
              weaknesses included in our report, Controls over Coronavirus Disease 2019 (COVID-19) Economic Injury
              Disaster Loans (EIDLs) Need Improvement and Controls over Subsidy Reestimate Need Improvement.
              Additionally, management did not agree with our finding over the agency’s substantial noncompliance with
              Federal Financial Management Improvement Act of 1996 (FFMIA).

              We have reviewed management’s responses and have determined that all aspects of the material weaknesses
              in internal control over financial reporting and substantial noncompliance with FFMIA remain appropriate. We
              provide the following additional information related to the Controls over Coronavirus Disease 2019 (COVID-19)
              Economic Injury Disaster Loans (EIDLs) Need Improvement, Controls over Subsidy Reestimate Need
              Improvement, and our findings related to substantial noncompliance with the Federal Financial Management
              Improvement Act of 1996 (FFMIA).

              In the area of COVID-19 EIDL:

              •   Management indicated that they assessed the COVID-19 EIDL portfolio and determined it was complete
                  and accurate. However, the data supporting management’s analysis and conclusion did not substantiate
                  management’s analysis performed. We identified examples where loans were included in the COVID-19
                  EIDL population and the Credit Program Receivable balance at September 30, 2025, however these loans
                  were recorded with a zero balance in management’s analysis. As a result, the data utilized in
                  management’s analysis did not support management’s conclusion regarding the completeness and
                  accuracy of the COVID-19 EIDL population. Further, management indicated that their inability to provide
                  supporting evidence over the COVID-19 EIDL population was due to an audit evidence requirement.
                  However, OMB Circular A-123, Management's Responsibility for Internal Control, requires management to
                  establish and maintain effective internal controls to ensure reliable financial reporting. As part of this
                  responsibility, management must maintain sufficient documentation to support its financial transactions and
                  account balances.

              •   Management indicated that they believe additional review would not alter their assessment of the
                  completeness of the COVID-19 EIDL population. However, management’s review control is not designed to
                  remove COVID-19 EIDLs with similar eligibility concerns from the portfolio in a consistent manner. We
                  identified COVID-19 EIDLs with similar eligibility characteristics that were both included in the Credit
                  Program Receivable balance as of September 30, 2025, and written off to be excluded from this balance,
                  which resulted in inconsistent accounting treatment. As a result, management did not design and
                  implement adequate monitoring controls and review processes to support the completeness and accuracy
                  of the COVID-19 EIDL portfolio and related financial data as of year-end.

              In the area of the Subsidy Reestimate:

              •   Management disagrees with our finding that SBA did not have adequate controls over the data inputs.
                  However, management did not provide the necessary supporting documentation for the integral data
                  related to borrower characteristics and the underlying loans used in the 7(a) Loan Guaranty subsidy
                  reestimate model. Management attributed the material weakness in the 7(a) Loan Guaranty reestimate to
                  the nature and timing of the audit procedures and complexity involved in obtaining supporting
                  documentation from third parties. However, it is management’s responsibility to maintain, support, and
                  report the information for the loan guaranty reestimate. The material weakness resulted from




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                   management’s ineffective coordination with third parties to obtain the necessary supporting documentation
                   for the relevant data elements. As a result, the loan guaranty reestimate material weakness existed as of
                   September 30, 2025.

              •    Management indicated that elements of material weakness entitled Controls over Subsidy Reestimate
                   Need Improvement are already covered by material weaknesses entitled Controls Over COVID-19 EIDLs
                   Need Improvement and Controls Over PPP Loan Program Need Improvement. This is not accurate, as the
                   material weakness entitled Controls Over Subsidy Reestimate Need Improvement specifically pertains to
                   the controls over the data inputs used in the subsidy reestimate models, while the material weaknesses
                   entitled Controls Over COVID-19 EIDLs Need Improvement and Controls Over PPP Loan Program Need
                   Improvement address separate findings relating to the controls over the COVID-19 EIDL portfolio and
                   controls over the post-payment review of forgiven PPP loans, respectively.

              In the area of FFMIA:

              •    Management indicated that they believe SBA’s financial management systems are in substantial
                   compliance with Federal financial management systems requirements and Federal accounting standards.
                   FFMIA defines Federal financial management systems as software, hardware, processes, procedures, and
                   controls necessary to support financial management. In our evaluation of management’s compliance with
                   FFMIA and based on the Basis for Disclaimer of Opinion and the material weaknesses identified, we
                   determined that management was unable to demonstrate substantial compliance with Federal financial
                   management systems requirements. Additionally, management was unable to consistently, completely, and
                   accurately record and account for balances and transactions in accordance with generally accepted
                   accounting principles, resulting in substantial noncompliance with Federal accounting standards.




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  Financial Statement and Notes
  The U.S. Small Business Administration prepares its financial statement as a critical aspect of ensur-
  ing accountability and stewardship for the public resources entrusted to the SBA. Preparation of this
  statement is also an important part of the SBA’s financial management goal of providing accurate and
  reliable information that may be used to assess performance and allocate resources.

  SBA’s management is responsible for the accuracy and propriety of the information contained in the
  principal financial statement and the quality of internal controls.

  The Consolidated Balance Sheet and related Notes are found in this section. All other financial state-
  ments and related Notes are found in the Other Information section of this report.

  The Consolidated Balance Sheet summarizes the assets, liabilities, and net position by major
  category as of the reporting date. Intragovernmental assets and liabilities resulting from transactions
  between federal agencies are presented separately from assets and liabilities resulting from transac-
  tions with the public.

  The Notes to the Consolidated Balance Sheet provide information to explain the basis of the ac-
  counting and presentation used to prepare the Consolidated Balance Sheet and to explain specific
  items in the statement. These also provide information to support how particular accounts have been
  valued and computed.




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  (Dollars in Thousands)
                                                              U. S. Small Business Administration
                                                    CO N S O L I D AT E D B A L A N C E S H E E T
                                                           As of September 30, 2025 (Unaudited)
                                                                                                                             2025
   ASSETS (Note 3)
   Intragovernmental Assets
      Fund Balance with Treasury (Note 2)                                                                             $       13,712,860
      Accounts Receivable, Net (Note 4)                                                                                               377
      Advances and Prepayments                                                                                                       5,874
   Total Intragovernmental Assets                                                                                             13,719,111
   Other than Intragovernmental Assets
      Cash and Other Monetary Assets                                                                                                 9,893
      Accounts Receivable, Net (Note 4)                                                                                          276,726
      Loans Receivables, Net:
         Credit Program Receivables and Related Foreclosed Property, Net (Note 5)                                            234,337,317
      Property, Plant and Equipment, Net (Note 6)                                                                                   56,051
      Advances and Prepayments                                                                                                      11,043
   Total Other than Intragovernmental Assets                                                                                 234,691,030
   Total Assets                                                                                                       $     248,410,141
   LIABILITIES
   Intragovernmental Liabilities
      Accounts Payable:
          Accounts Payable, Capital Transfers:
              Net Assets of Liquidating Funds Due to Treasury (Note 9)                                                $                75
          Accounts Payable                                                                                                           9,684
      Debt:
          Loans Payable:
              Principal Payable to the Bureau of the Fiscal Service (Note 8)                                                 249,335,902
      Advances from Others                                                                                                           8,293
      Other Liabilities:
          Benefit Program Contributions Payable                                                                                     15,628
          Liability to the General Fund of the U.S. Government for Other Non-Entity Assets:
              Downward Reestimate Payable to Treasury (Note 5)                                                                 2,869,138
      Other (Note 10)                                                                                                            102,303
   Total Intragovernmental Liabilities                                                                                       252,341,023

   Other than Intragovernmental Liabilities
   Accounts Payable                                                                                                              166,610
      Federal Employee Salary, Leave, and Benefits Payable (Note 11)                                                                87,733
      Post-Employment Benefits Payable (Note 11)                                                                                    27,747
      Loan Guarantee Liabilities (Note 5)                                                                                      3,019,305
   Other Liabilities:
          Accrued Grant Liability                                                                                                   55,775
          Surety Bond Guarantee Program Future Claims (Note 7)                                                                      89,590
          Other (Note 10)                                                                                                           91,641
   Total Other than Intragovernmental Liabilities                                                                              3,538,401
   Total Liabilities                                                                                                        255,879,424
   Commitments and Contingencies (Note 12)
   NET POSITION
   Unexpended Appropriations - Funds from Other Than Dedicated Collections                                                     4,151,458
   Cumulative Results of Operations - Funds from Other Than Dedicated Collections                                            (11,620,741)
   Total Net Position                                                                                                        (7,469,283)
   Total Liabilities and Net Position                                                                                 $     248,410,141

   The accompanying notes are an integral part of this statement.




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  Note 1. Reporting Entity and Summary of
  Significant Accounting Policies
  REPORTING ENTITY
  The Small Business Act of 1953 created the Small Business Administration as an independent federal
  agency. The SBA’s mission is to maintain and strengthen the nation’s economy by enabling the estab-
  lishment and vitality of small businesses and by assisting in the economic recovery of communities
  after disasters. The SBA operates through the execution of a congressionally approved budget that
  funds its programs.

  The SBA is a component of the U.S. Government. For this reason, some of the assets and liabilities
  reported by the entity may be eliminated for Government-wide reporting because they are offset by
  assets and liabilities of another U.S. Government entity. These financial statements should be read
  with the realization that they are for a component of the U.S. Government.

  BASIS OF ACCOUNTING AND PRESENTATION
  The Consolidated Balance Sheet was prepared to report the financial position of the Agency, as
  required by the Chief Financial Officers Act of 1990 and the Government Management Reform Act
  of 1994. The Consolidated Balance Sheet was prepared from the Agency’s financial records in ac-
  cordance with Generally Accepted Accounting Principles (GAAP), issued by the Federal Accounting
  Standards Advisory Board (FASAB), and the Office of Management and Budget (OMB) Circular A-136,
  Financial Reporting Requirements, as revised.

  The accounting structure of federal agencies is designed to reflect both the accrual and budgetary
  accounting transactions. Under the accrual method of accounting, revenues are recognized when
  earned and expenses are recognized when a liability is incurred, without regard to receipt or pay-
  ment of cash. Budgetary accounting facilitates compliance with legal constraints and controls over
  federal funds.

  The Federal Credit Reform Act (FCRA) of 1990 governs the SBA’s accounting transactions for direct
  loans and loan guaranties made in FY 1992 and thereafter. Under the FCRA, the liability for loan guar-
  anties is determined as the summarized discounted present value of the estimated future net cash
  inflows and outflows for each fiscal year’s cohort of guaranties. For direct loans, the Credit Program
  Receivables and Related Foreclosed Property, Net is the discounted present value of the estimated
  future net cash flows for all the loan cohorts composed of outstanding FCRA loans receivable ad-
  justed to net present value with an allowance for subsidy. A cohort of loans receivable or guarantied
  loans is all the direct loans obligated, or loan guaranties committed, in a given fiscal year. Increases
  to individual loans in a cohort that are made in a subsequent fiscal year are accounted for in the
  subsequent year’s loan cohort. Cohort cash flows include loan repayments, recoveries on defaulted
  guaranties and loan fees received by the SBA that are due from the lenders and borrowers when the
  loan is made and during the life of the loan cohort, as well as expenditures by the SBA for defaulted
  guaranties, loan servicing expenses, and other required SBA expenditures. An initial allowance or li-
  ability for loan guaranties is established in the original year of the loan cohort. The initial amount



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  the allowance and liability for each cohort is reestimated annually at fiscal year-end, and the adjust-
  ed amount is included in the SBA’s annual financial statements.

  USE OF ESTIMATES
  The SBA’s management makes assumptions and uses estimates to prepare the financial statements
  based upon the facts that exist when the statements are prepared. The SBA also uses economic
  assumptions provided by the Office of Management and Budget in preparing the estimates. Actual
  results may differ from those assumptions and estimates. The most significant differences between
  actual results and these estimates may occur in the valuation of credit program receivables and
  liabilities for loan guaranties under guidelines in FCRA. The SBA recognizes the sensitivity of credit
  reform modeling to slight changes in some model assumptions and therefore continually reviews its
  model factors and statistical modeling techniques to reflect the most accurate credit program costs
  possible in its annual financial statements.

  ACCOUNTS RECEIVABLE
  Accounts receivable are amounts due to the Agency from other federal agencies (intragovernmental)
  and the public (other than intragovernmental). Other than intragovernmental receivables result from
  overpayments to recipients of grants and other financial assistance programs. Intragovernmental
  receivables result from reimbursable agreements entered into by the Agency with other agencies to
  provide various goods and services. Accounts receivable are reduced to net realizable value by an al-
  lowance for uncollectible amounts.

  ADVANCES AND PREPAYMENTS
  Advances are cash outlays made by a Federal entity to its employees, contractors, grantees, or oth-
  ers to cover part or all the recipients’ anticipated expenses or as advance payments for the costs of
  goods and services the entity receives. Prepayments are payments made by a Federal entity to cover
  certain periodic expenses before those expenses are incurred. The SBA has both intragovernmental
  advances and advances to the public. Advances to the public represent prepaid grants to counseling
  and training partners.

  CASH AND OTHER MONETARY ASSETS
  The SBA field offices deposit collections from borrowers in the SBA’s account at the Treasury using an
  electronic deposit system. At the end of the fiscal year, collections temporarily held by the SBA field
  offices pending deposit are recorded as Undeposited Collections - Cash in Transit.

  PROPERTY, PLANT AND EQUIPMENT
  The SBA records PP&E at cost less accumulated depreciation. Capitalization and depreciation poli-
  cies are as follows:

  Equipment

  The SBA capitalizes equipment with a cost of $100,000 or more per unit, and a useful life of 2 years or
  more. Equipment meeting these criteria is capitalized at full cost and depreciated using the straight-
  line method over the useful life. The SBA expenses equipment not meeting the capitalization criteria.



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  Leasehold Improvements

  Leasehold improvements with modifications of $200,000 or more and a useful life of 2 years or more
  are capitalized and amortized using the straight-line method over the useful life of the improvement
  or the lease term, whichever is shorter. The SBA expenses leasehold improvements not meeting the
  capitalization criteria.

  Internal Use Software

  Software intended for internal use, whether internally developed, contractor developed, or pur-
  chased, is capitalized at cost if the unit acquisition cost is $500,000 or more and service life is at least
  2 years. Capitalized software costs include all direct and indirect costs incurred, including overhead
  to develop the software. Software for internal use is amortized using the straight-line method over
  its useful life, not to exceed 5 years. Amortization begins when the software is put into production.
  The costs of enhancements are capitalized when it is more likely than not that the enhancements
  will result in significant additional capabilities. Costs that do not meet the capitalization criteria are
  expensed when incurred.

  LEASES
  Effective October 1, 2023, SFFAS No. 54. Leases, revised the financial reporting standards for Fed-
  eral lease accounting, which provides a comprehensive set of standards to recognize Federal lease
  activities in a reporting entity’s financial reports and note disclosures. The statement requires Fed-
  eral lessees to recognize a lease liability and asset at the commencement of the lease term for all
  material non-intragovernmental, non-short-term contracts when the reporting entity has the right to
  control access to or obtain benefits from the use of real property, equipment, or other assets. Imple-
  mentation of this standard had an immaterial impact on the SBA’s financial reporting as its leases for
  real property are intragovernmental leases, which do not require the recognition of a lease liability
  or asset, and the SBA does not explicitly lease equipment or other assets in the normal course of
  business. The SBA will continue to evaluate its contract activity to identify any potential embedded
  leases. However, the SBA will not report any embedded leases in accordance with the three-year
  transitional accommodation period provided to entities implementing SFFAS No. 54 Leases in SFFAS
  No. 62, Transitional Amendment to SFFAS No. 54.

  ACCOUNTS PAYABLE
  Accounts Payable are amounts that will be liquidated during the next operating cycle. Included in the
  liability are payables to SBA lenders for their share of loan collections and to vendors for goods and
  services.

  ADVANCES FROM OTHERS
  Advances received from other federal entities are recorded when received and liquidated when the
  SBA records a expense funded by the advance.




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  BENEFIT PROGRAM CONTRIBUTION PAYABLE
  A liability is recorded for accrued benefits payable that will be liquidated when the related payments
  are recorded.

  ACCRUED GRANT LIABILITY
  Disbursements of grant funds are recognized as expenses at the time of disbursement. However,
  some grant recipients incur expenditures prior to initiating a request for disbursement based on the
  nature of the expenditures. The SBA accrues a liability for expenditures incurred by grantees prior to
  receiving grant funds for the expenditures. The accrual is determined through an analysis of historic
  grant expenditures. The Small Business Development Center program and several other grant pro-
  grams are subject to this treatment.

  COMMITMENTS AND CONTINGENCIES
  The SBA is a party in various administrative proceedings, legal actions, environmental lawsuits, and
  claims brought against the Agency. In the opinion of the SBA’s management and legal counsel, there
  are certain matters regarding legal claims for which a clear evaluation of the likelihood of an unfavor-
  able outcome cannot be determined as of the date of this financial report. See, Commitments and
  Contingencies note for further details. The resolution of all other legal proceedings, actions, suits,
  and claims will not materially affect the financial position or results of the SBA’s operations.

  CUMULATIVE RESULTS OF OPERATIONS
  The Cumulative Results of Operations, presented on the Consolidated Balance Sheet, is the accu-
  mulated difference between expenses and financing sources since the inception of the Agency. The
  amounts reported reflect timing differences between the recording of expenses and the recognition
  of resources. Most of this timing difference results from subsidy reestimates which are funded in the
  following year. The SBA does not have funds from dedicated collections.

  UNEXPENDED APPROPRIATIONS
  Unexpended Appropriations is the portion of the SBA’s appropriations received which are either
  undelivered or unobligated. Delivered orders result in expended appropriations and reduce the total
  reported as Unexpended Appropriations. Undelivered orders are the amount of orders of goods or
  services which have not been actually or constructively received. The SBA does not have funds from
  dedicated collections.

  CLASSIFIED ACTIVITIES
  Accounting standards require all reporting entities to disclose that accounting standards allow cer-
  tain presentations and disclosures to be modified, if needed, to prevent the disclosure of classified
  information.




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  EMPLOYEE BENEFITS
  Leave

  A liability for employee annual leave is accrued as it is earned and reduced as leave is taken. Each
  year the balance of accrued annual leave is adjusted to reflect current pay rates as well as forfeited
  “use or lose” leave. Annual leave earned but not taken, within established limits, is funded from fu-
  ture financing sources. Sick leave and other types of non-vested leave are expensed as taken.

  Federal Employees’ Compensation Act

  The Federal Employees’ Compensation Act (FECA) provides income and medical cost protection to cover
  federal civilian employees injured on the job and to beneficiaries of employees whose deaths are attrib-
  utable to job-related injury or disease. The FECA program is administered by the Department of Labor.

  The DOL pays valid claims as they occur, which are billed to the SBA annually and funded and paid
  approximately 15 months later. The DOL also calculates an estimated actuarial liability for future
  benefits based upon historical experience and other economic variables. Projected annual benefit
  payments are then discounted to present value using the forecasted interest rates for 10-year Trea-
  sury notes and bonds published by the OMB in its economic assumptions for the federal budget.
  The SBA recognizes a current unfunded cost for the actual claims paid and the change in the FECA
  actuarial liability each year.




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  Note 2. Fund Balance with Treasury
  The U.S. Department of the Treasury processes cash receipts and disbursements on the SBA’s behalf
  to pay liabilities and finance loan program costs. Cash receipts are deposited into the SBA’s account
  at the Treasury. The SBA’s fund balances with the Treasury are available to make expenditures to liq-
  uidate allowable obligations, except for the Budget Clearing Accounts which are not available to the
  SBA to obligate or expend until applied.

  Records are maintained for the SBA’s program, financing, liquidating, suspense/budget clearing ac-
  counts (awaiting disposition or reclassification), and other accounts at the fund level. Fund balances
  with the Treasury include expired year amounts, which are unavailable for obligation, as well as
  amounts currently available for new obligations.

  Fund Balance with Treasury (FBWT) is an asset to the SBA and a liability of the General Fund. The
  amounts represent commitments by the Government to provide resources for particular programs,
  but they do not represent net assets to the Government as a whole. When disbursements are made,
  the Treasury will finance the disbursements in the same way it finances all other disbursements,
  using a combination of receipts, other inflows, and borrowing from the public (if there is a budget
  deficit).

  (Dollars in Thousands)

    As of September 30,                                                                       2025

      Appropriated Funds                                                          $                 5,856,283

      Financing Funds                                                                               7,648,624

      Liquidating Funds                                                                                      519

      Revolving Funds                                                                                  115,308

      Trust Fund                                                                                             485

      Budget Clearing Accounts Balance                                                                  91,641

    Total Fund Balance with Treasury                                             $              13,712,860




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  Note 3. Non-Entity Assets
  Non-Entity Assets consist of assets that belong to other entities but are included in the SBA con-
  solidated financial statements and are offset by various liabilities to accurately reflect the SBA’s net
  position. The SBA’s non-entity accounts receivable principally consist of disaster loan downward
  re-estimates from FY 2025 of $2.3 billion and business guaranteed loans of $0.6 billion. The SBA
  performs eliminations between the credit agency payable and the non-entity receivable for compil-
  ing the balance sheet. The downward reestimate amounts are reflected in the consolidated balance
  sheet in the liabilities section as downward reestimate payable to treasury.

  (Dollars in Thousands)

    As of September 30,                                                                         2025

    Intragovernmental Assets:

       Accounts Receivable, Net                                                     $                 2,869,138

    Total Intragovernmental Assets                                                                   2,869,138


    Other Than Intragovernmental Assets:
       Accounts Receivable, Net                                                                          101,167

    Total Other Than Intragovernmental Assets                                                           101,167


    Total Non-Entity Assets                                                                           2,970,305

    Eliminations                                                                                    (2,869,138)

    Total Entity Assets                                                                            248,308,974

    Total Assets                                                                    $           248,410,141




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  Note 4. Accounts Receivable, Net
  Accounts receivable are amounts due to the SBA from other federal agencies (intragovernmental)
  and the public (other than intragovernmental).

  Other than Intragovernmental includes amounts owed by the public to the SBA for grants and direct
  payments whose recipients have not provided sufficient documentation for the SBA to determine
  that the payments have been earned as well as guaranty fees in the SBA’s loan and surety bond pro-
  grams and miscellaneous receivables (Other).

  An Allowance for Loss on uncollectible Restaurant Revitalization Fund Receivables and Shuttered
  Venue Operators Grant Receivables is based upon historical recovery rates in the Paycheck Protec-
  tion Program which is similar in nature, originating during the COVID era with no personal guarantee
  or collateral.

  The Allowance for Loss for Other receivables is the allowance for uncollectible Surety Bond Guaranty
  fees based on an aging of delinquent balances. Amounts over 180 days past due on guarantied loans
  purchased by the SBA are written off for financial reporting purposes.

  (Dollars in Thousands)

                                                         Shuttered
                                       Restaurant                         Guaranty
                                                           Venue
        As of September 30, 2025      Revitalization                        Fees                  Total
                                                         Operators
                                          Fund                           Receivable
                                                           Grant

    Intragovernmental

     Administrative Receivables       $              - $             - $            377 $                  377
    Total Intragovernmental           $              - $             - $           377 $                  377


    Other than Intragovernmental
      Accounts Receivable Gross       $     2,363,589 $       706,689 $       146,735 $           3,217,013
      Allowance For Loss                   (2,262,428)       (675,107)          (2,752)          (2,940,287)
    Total Other than
                                      $      101,161 $        31,582 $       143,983 $             276,726
    Intragovernmental, Net




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  Note 5. Credit Program Receivables and
  Liability for Loan Guaranties
  A. LOAN PROGRAM DESCRIPTIONS AND ACCOUNTING
  Loan Program Descriptions

  The SBA provides guaranties that help eligible small businesses obtain loans from participating
  lenders and licensed small business investment companies to make investments in qualifying small
  businesses. The SBA also makes loans to microloan intermediaries and provides direct loans that
  assist homeowners, renters, businesses of all sizes, and private nonprofit organizations recover from
  disasters.

  Major Direct Loan and Loan Guaranty Programs

    Program Group                    Program Type   Program

    Disaster                         Direct         Disaster Assistance Loans

    Business                         Guarantied     7(a) Loan Guaranty

    Business                         Guarantied     504 Certified Development Company

    Business                         Guarantied     Small Business Investment Company Debentures

    Business                         Direct         7(m) Microloan

  SBA’s Disaster Assistance Loan program makes direct loans to disaster survivors under four cat-
  egories: (1) physical disaster loans to repair or replace damaged homes and personal property; (2)
  physical disaster loans to businesses of any size; (3) economic injury disaster loans to eligible small
  businesses and nonprofit organizations without credit available elsewhere; and (4) economic injury
  loans to eligible small businesses affected by essential employees called up to active duty in the
  military reserves. The maximum interest rate is 4 percent for loan applicants without credit available
  elsewhere and 8 percent for applicants with credit available elsewhere. The SBA offered low-interest
  Economic Injury Disaster Loans for working capital to small businesses suffering substantial eco-
  nomic injury as a result of the COVID-19 pandemic. Although the SBA stopped accepting new loan
  applications on January 1, 2022, the program continues to require servicing support.

  SBA’s business loan programs include its flagship 7(a) Loan Guaranty program in which the SBA
  guaranties up to 90 percent of the amount of loans made by participating banks and other lending
  institutions to eligible small businesses not able to obtain credit elsewhere. The CARES Act added the
  Paycheck Protection Program in the 7(a) loan program which is designed to provide a direct incentive
  for small businesses to keep their workers on the payroll. Although the Paycheck Protection Program
  ended on May 31, 2021, there continues to be recovery activity.




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  The 504 Certified Development Company program guarantees 100 percent of the principal and inter-
  est payments on debentures issued by development companies for loans to eligible small business-
  es secured by real estate or equipment.

  The Small Business Investment Company program guarantees principal and interest payments on
  debentures issued by small business investment companies, which in turn make investments in
  qualifying small businesses.

  The 7(m) Microloan program provides direct loans to nonprofit intermediaries, which use these funds
  to make loans up to $50,000 to eligible small businesses.
  Credit Subsidy Modeling

  The SBA estimates future cash flows for direct and guarantied loans using economic and financial
  credit subsidy models. These estimated cash flows are used to develop the subsidy funding required
  under the Federal Credit Reform Act of 1990. The SBA has developed a customized credit subsidy
  model for each of its major loan programs.

  SBA’s models vary in the specific methodologies employed to forecast future program cash flows. In
  general, however, models for all major credit programs use historical data as the basis for assumptions
  about future program performance and then translate these assumptions into nominal cash flow esti-
  mates by applying rules about program structure. Nominal cash flow forecasts are discounted using the
  OMB’s Credit Subsidy Calculator that has both forecasted and actual Treasury interest rates.

  Historical data is used as the basis for program performance assumptions. The historical data under-
  goes quality review and analysis prior to its use in developing model assumptions.

  Key input to the subsidy models varies by program. Input includes items such as:

  •     Contractual terms of the loan or guaranty such as loan amount, interest rate, maturity, and grace
        periods

  •     Borrower characteristics

  •     Loan origination methods

  •     Economic indicators such as gross domestic product growth and unemployment rate

  •     Loan performance assumptions, for example: conditional purchase and prepayment rates and
        recovery rates

  •     Loan fee rates

  Subsidy Funding under the Federal Credit Reform Act

  The Federal Credit Reform Act (FCRA) requires that the credit subsidy costs of direct loans and loan
  guaranties be expensed in the year loans are disbursed. The credit subsidy cost is the net present val-
  ue of expected cash inflows and outflows over the life of a guarantied loan, or the difference between
  the net present value of expected cash flows and the face value of a direct loan. The cost expressed
  as a percentage of loans disbursed is termed the subsidy rate. The SBA receives appropriations to



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  fund its credit programs based on the subsidy rate that applies to the credit program level approved
  by Congress. The SBA records subsidy expenses when loans are disbursed. In accordance with FCRA,
  subsidy costs are reestimated annually.

  Credit Program Receivables and Related Foreclosed Property, Net

  FCRA governs direct loans made after FY 1991. FCRA direct loans are valued at the present value of
  expected future cash flows discounted at the interest rate of marketable Treasury securities. The
  subsidy allowance represents the difference between the outstanding loans receivable balance and
  the net present value of the estimated cash flows of the loans over their remaining term. The subsidy
  allowance is subtracted from the outstanding loans receivable balance to obtain the net loans receiv-
  able balance.

  Guarantied loans purchased by the SBA upon borrower default are established as loans receivable
  and are valued in a similar manner as direct loans under FCRA.

  Direct loans and defaulted guaranties made prior to FCRA are valued at the current receivable bal-
  ance net of an allowance for uncollectible amounts calculated using historical loss experience.

  The SBA advances payments semiannually to honor the SBA’s timely payment requirement of prin-
  cipal and interest due for debentures in the SBA’s 504 Certified Development Company and Small
  Business Investment Company programs. The advances are liquidated by receipt of the payments
  due from borrowers in these programs. Advance balances are reported as Other Loans Receivable.

  Interest receivable is comprised of accrued interest on loans receivable and purchased interest re-
  lated to defaulted guarantied loans. Interest income is accrued at the contractual rate on the out-
  standing principal amount and is reduced by the amount of interest income accrued on nonperform-
  ing loans in excess of 90 days delinquent. SBA’s purchase of accrued interest is limited to 120 days on
  the defaulted guaranty unless the loan has been sold in the secondary market. Purchased interest is
  carried at cost, and an allowance is established for amounts in excess of 90 days delinquent.

  Foreclosed property is comprised of real and personal property acquired through foreclosure on di-
  rect loans and defaulted loan guaranties. Properties acquired as a result of defaulted loans commit-
  ted after FY 1991 are shown at recoverable value, which is adjusted to the present value of expected
  future cash flows for financial statement presentation through the allowance for subsidy. Other fore-
  closed property is shown at the appraised value. At September 30, 2025 the SBA’s foreclosed prop-
  erty was $20.8 million related to 74 loans. The properties had been held for an average of 1,806 days.

  Valuation Methodology for the Liability for Loan Guaranties under FCRA

  FCRA also governs loan guaranties made after FY 1991. A liability for outstanding guaranties is includ-
  ed on the SBA’s Balance Sheet. The liability for guarantied loans committed after FY 1991 is based on
  the net present value of their expected future cash flows, including guaranty fee inflows and the net
  cash outflows of defaulted guarantied loans purchased by the SBA.




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  Valuation Methodology for Pre-FCRA Liability for Loan Guaranties

  The SBA values pre-credit reform direct and defaulted guarantied loans by estimating an allowance
  for loan losses. This allowance is offset against gross loan receivables to obtain the SBA’s expected
  net collections from these assets. The SBA establishes a 100 percent allowance for pre-credit reform
  direct and guarantied loans that are past due more than 180 days.

  Reestimates

  Reestimates mean revisions of the subsidy cost estimate of a cohort (or risk category) based on infor-
  mation about the actual performance and/or estimated changes in future cash flows of the cohort.
  Reestimates must be made immediately after the end of each fiscal year, as long as any loans in the
  cohort are outstanding, unless a different plan is approved by OMB (see section 185.6). An upward
  reestimate indicates that insufficient funds had been paid to the financing account, so the increase
  (plus interest on reestimates) is paid from the program account to the financing account to make it
  whole. Permanent indefinite budget authority is available for this purpose pursuant to section 504(f)
  of the FCRA. A downward reestimate indicates that too much subsidy had been paid to the financing
  account. The excess (plus interest) is disbursed to a downward reestimate receipt account.

  Significant Transactions During FY 2025

  As a result of an updated accounting policy to more accurately value the gross receivable, the SBA
  returned 697,793 COVID EIDLs totaling $48.9 billion and 448,816 purchased defaulted PPP loans total-
  ing $10.2 billion from charge off to a new loan status “SBA Uncollectible”. These loans are either at
  Treasury for collection efforts or are eligible for Treasury referral. Due to the subsidy allowance, there
  is no impact to the net credit program receivables line. In FY 2026, the SBA will review its other loan
  programs to ensure consistency with this new accounting treatment.




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  B. CREDIT PROGRAM RECEIVABLES AND RELATED FORECLOSED PROPERTY, NET
  (Dollars in Thousands)

                                                        Pre-1992       Post-1991
                   As of September 30, 2025                                                      Total
                                                         Loans           Loans
    Direct Business Loans
      Business Loans Receivable                     $        6,021 $        226,053 $                232,074
      Interest Receivable                                          -           2,142                    2,142
      Foreclosed Property                                    2,631                    -                 2,631
      Allowance                                             (8,652)         (18,170)                (26,822)

    Total Direct Business Loans                                    -       210,025                 210,025


    Direct Disaster Loans
      Disaster Loans Receivable                                 32      324,938,778            324,938,810
      Interest Receivable                                          1     11,024,930             11,024,931
      Foreclosed Property                                          -           4,939                    4,939
      Allowance                                                    -   (103,975,451)         (103,975,451)

    Total Direct Disaster Loans                                 33 231,993,196              231,993,229


    Defaulted Guarantied Business Loans & Other Loans Receivable
      Defaulted Guarantied Business Loans                    2,579       15,117,991             15,120,570
      Other Loans Receivable (see note below)                      -          36,551                  36,551
      Interest Receivable                                          -        291,477                 291,477
      Foreclosed Property                                    1,263            11,979                  13,242
      Allowance                                             (3,842)     (13,323,935)          (13,327,777)

    Total Defaulted Guarantied Business Loans &
                                                                   -     2,134,063              2,134,063
    Other Loans Receivable

    Total Credit Program Receivables & Related
                                                                                          $234,337,317
    Foreclosed Property, Net


  Note: Other Loans Receivable includes payments advanced by the SBA against future reimburse-
  ments in the SBIC and 504 loan programs.




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  C. 2025 SUBSIDY RATES BY PROGRAM AND COMPONENT
  The subsidy rates in Table D pertain only to loans obligated in the current year. These rates cannot
  be applied to the loans disbursed during the current year to yield the subsidy expense because loans
  disbursed during the current year include loans obligated in prior years.

    Loan                         Total
                                          Financing        Default           Other                    Fee
    Program                     Subsidy

    Guaranty

    7(a)                         0.00%     0.00%            3.23%            0.00%                 -3.23%

    504 CDC                      0.00%     0.00%            3.77%            0.36%                 -4.13%

    504 Refi                     0.00%     0.00%            3.92%            0.36%                 -4.28%
    SBIC
                                 0.00%     0.00%            5.05%            0.02%                 -5.07%
    Debentures

    Direct
    Disaster                    22.22%     15.67%           9.70%            -3.15%                 0.00%

    Microloan                   10.53%     8.85%            1.93%            -0.25%                 0.00%



  D. LOAN GUARANTEE LIABILITIES
  For guaranteed loans outstanding, the present value of estimated net cash outflows of the loan guar-
  antees is recognized as a liability. Credit programs re-estimate the liability for outstanding loan guar-
  antees as required in Statement of Federal Financial Accounting Standards (SFFAS) 2. An increase or
  decrease in loan guarantee liability resulting from the re-estimates is recognized as an increase or
  decrease in subsidy expense for the current reporting period. The SBA currently has outstanding loan
  guarantee liabilities of $3.0 billion.




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  E. LOANS PRINCIPAL OUTSTANDING
  (Dollars in Thousands)

    Loans Outstanding as of September 30,                                                   2025

      Total Principal Outstanding at Face Value                                 $             175,043,268

      Total Principal Outstanding Guarantied by the SBA                                       145,606,225


  Note: SBA’s guarantied loan servicing agent provides data to the SBA on the unpaid principal balance
  of guarantied loans with a one-month lag.




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  Note 6. Property, Plant, and Equipment, Net
  (Dollars in Thousands)

                                                                    Accumulated
                                     Useful Life                                             Net Book
    As of September 30, 2025                           Cost       Depreciation and
                                      (Years)                                                 Value
                                                                   Amortization

      Equipment                         2-25       $      2,675 $            (2,675) $                         -

      Leasehold Improvements             2-5              1,811              (1,811)                           -

      Software in Development                             5,643                      -                  5,643

      Software in Use                     5             181,984           (131,576)                   50,408

    Total General Property
                                                   $   192,113 $         (136,062) $                 56,051
    and Equipment, Net


  RECONCILIATION PROPERTY, PLANT AND EQUIPMENT, NET

    As of September 30,                                                                     2025

    Balance Beginning of Year                                                   $                    79,875

      Capitalized Acquisitions                                                                          5,758

      Depreciation Expense                                                                           (29,582)

    Balance at End of Year                                                      $                    56,051

  See Note 1 for a description of accounting policy.




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  Note 7. Liabilities Not Covered by Budgetary
  Resources
  Liabilities not covered by budgetary resources require future congressional action whereas liabilities
  covered by budgetary resources reflect prior congressional action. Regardless of when the congres-
  sional action occurs, when the liabilities are liquidated, Treasury will finance the liquidation in the
  same way that it finances all other disbursements, using some combination of receipts, other inflows,
  and borrowing from the public (if there is a budget deficit).

  These liabilities consisted of the following categories, as shown in the table.

  The liability for Surety Bond Guaranties is an estimate of future claims in the SBG Program for guar-
  anties outstanding at year-end.

  (Dollars in Thousands)

    As of September 30,                                                                              2025

    Intragovernmental Liabilities - Benefit Program Contributions Payable

      Unfunded Employment Taxes Payable                                                        $             4,879

      Unfunded Federal Employees' Compensation Act Payable                                                   6,560

    Total Intragovernmental Liabilities - Benefit Program Contributions Payable                           11,439


    Other than Intragovernmental Liabilities - Federal Employee Benefits Payable
      Accrued Unfunded Annual Leave                                                            $           50,167

      Federal Employees' Compensation Act Payable                                                          27,747
    Total Other than Intragovernmental Liabilities - Federal Employee Benefits
                                                                                                          77,914
    Payable


    Surety Bond Guarantee Program Future Claims                                                $          89,590


      Total Liabilities Not Covered by Budgetary Resources                                     $        178,943

      Total Liabilities Covered by Budgetary Resources                                             255,608,840

      Total Liabilities Not Requiring Budgetary Resources                                                  91,641

    Total Liabilities                                                                          $ 255,879,424




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  Note 8. Debt
  The FCRA permits agencies to borrow from Treasury to support credit programs. Borrowings payable
  to the Treasury funded disbursements of new loans, payment of downward subsidy reestimates, and
  the payment of other credit program outlays and related costs. The SBA makes periodic principal re-
  payments to the Treasury based on the analysis of its cash balances and future disbursement needs.

  All debt is intragovernmental and covered by budgetary resources. Approximately 99% of SBA debt is
  attributable to direct loan programs.

  INTRAGOVERNMENTAL DEBT
  (Dollars in Thousands)

    As of September 30,                                                                    2025

    Principal Payable to the Bureau of the Fiscal Service

      Beginning Balance                                                        $              264,662,710

      New Borrowings                                                                            14,778,023

      Repayments                                                                              (30,104,831)

    Total Principal Payable to the Bureau of the Fiscal Service                $            249,335,902




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  Note 9. Net Assets of Liquidating Funds Due to
  Treasury
  Unobligated balances of liquidating funds are transferred to the Treasury general fund at the end of
  the fiscal year. Net Assets of Liquidating Funds Due to Treasury is the residual of the book value of
  assets less liabilities in the Liquidating Funds for loans made prior to FY 1992 that is not yet available
  for transfer.

  (Dollars in Thousands)

    As of September 30,                                                                          2025

      Disaster Loan Fund                                                             $                           33

      Business Loan and Investment Fund                                                                          42

    Total Due to Treasury                                                            $                           75




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                                                                                         Financial Reporting (Unaudited)



  Note 10. Other Liabilities
  Intragovernmental Other Liabilities - Payable to Treasury represent the amount of non-entity as-
  sets held in a General Fund Receipt Account due to Treasury for the estimated recovery of payments
  made by the Restaurant Revitalization Fund.

  Other than Intragovernmental Other Liabilities primarily represent fund balance with treasury not yet
  reclassified as of the balance sheet date.

  Other liabilities are shown in the following table.

  All liabilities reflected are current liabilities.

  (Dollars in Thousands)

    As of September 30,                                                                     2025

    Intragovernmental Other Liabilities

      Employment Taxes Payable                                                  $                       1,136

      Payable to Treasury                                                                            101,167

    Total Intragovernmental Other Liabilities                                                      102,303


    Other than Intragovernmental Other Liabilities
      Budget Clearing Accounts                                                                        91,641

    Total Other than Intragovernmental Other Liabilities                                             91,641

    Total Other Liabilities                                                     $                  193,944




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                                                                                       Financial Reporting (Unaudited)



  Note 11. Federal Employment Benefits Payable
  Federal Employment Benefits Payable are shown in the following table.

  (Dollars in Thousands)

    As of September 30,                                                                   2025

    Federal Employee Salary, Leave, and Benefits Payable

     Accrued Funded Payroll and Leave                                          $                     36,911

     Employer Contributions and Taxes Payable                                                            655

     Unfunded Leave                                                                                  50,167

    Total Federal Employee Salary, Leave, and Benefits Payable                 $                   87,733


    Post-Employment Benefits Payable
     Actuarial FECA Liability                                                  $                     27,747

    Total Post-Employment Benefits Payable                                     $                   27,747




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                                                                                            Financial Reporting (Unaudited)



  Note 12. Commitments and Contingencies
  A loss contingency is an existing condition, situation, or set of circumstances involving uncertainty
  as to possible loss to an entity. The uncertainty will ultimately be resolved when one or more future
  events occur or fail to occur. A loss contingency is a liability when a past event or exchange transac-
  tion has occurred, a future outflow or other sacrifice of resources is probable, and the future outflow
  or sacrifice of resources is measurable.

  PROBABLE LIKELIHOOD OF AN ADVERSE OUTCOME
  The SBA does not have any material probable contingencies. Any probable losses would be classified
  as immaterial and would have inconsequential effects on the financial performance or position of
  the SBA.

  REASONABLY POSSIBLE LIKELIHOOD OF AN ADVERSE OUTCOME
  The SBA is subject to other potential losses where it is reasonably possible that an adverse outcome
  will result. Since some of the potential liabilities represent claims with no stated amount, the exact
  amount of total potential loss is unknown, but it is believed these claims could result in potential
  estimable losses as of September 30, 2025, of up to $253 million if the outcomes were adverse to the
  SBA. For most claims, any amounts ultimately due will be paid out of Treasury’s Judgment Fund.
  For certain claims to be paid by Treasury’s Judgment Fund, once the claims are settled or court
  judgments are assessed relative to the SBA, the liability will be removed, and an Imputed Financing
  Source will be recognized.




U.S. Small Business Administration                                             Agency Financial Report Fiscal Year 2025   90
 SECTION 3




      Other
Information
             (UNAUDITED)
                                                                                             Other Information (Unaudited)



  Other Information
  The information contained in the section is unaudited.

  This section consists of financial statements, notes, and other information other than that related to
  the Consolidated Balance Sheet.

  The Consolidated Statement of Net Cost shows, by major program category, the net cost of opera-
  tions for the reporting period. Net cost of operations consists of full program costs incurred by the
  SBA less the exchange revenues earned by those programs.

  The Consolidated Statement of Changes in Net Position presents the SBA’s beginning and end-
  ing net position by two components - Cumulative Results of Operations and Unexpended Appropria-
  tions. It summarizes the change in net position by major transaction category. The ending balances
  of both components of net position are also reported on the Balance Sheet.

  The Combined Statement of Budgetary Resources provides information about funding and avail-
  ability of budgetary resources, and the status of those resources at the end of the reporting period.
  Data on the Combined Statement of Budgetary Resources is consistent with information reflected on
  the Report on Budget Execution and Budgetary Resources (SF 133), with the one exception of offset-
  ting receipts. Offsetting receipts offset budget authority and outlays at the agency level in the Budget
  of the United States Government but are not reflected in the SF 133. The SBA includes offsetting
  receipts in this statement for the purpose of reconciling outlay information presented in the Budget
  of the United States Government.

  The Notes to the Financial Statements provide information to explain the basis of the account-
  ing and presentation used to prepare the statements and to explain specific items in the statements.
  They also provide information to support how particular accounts have been valued and computed.

  The Required Supplementary Information presents a Combining Statement of Budgetary Re-
  sources report by principal functional area.




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                                                                                             Other Information (Unaudited)


  (Dollars in Thousands)

                                           U. S. Small Business Administration
                              CO N S O L I D AT E D S TAT E M E N T O F N E T CO S T
                                 For The Year Ended September 30, 2025 (Unaudited)

                                                                                              2025

    Access to Capital, Investment & Innovation, Contracting & Business
    Development
       Gross Cost                                                                 $                 1,077,610
       Less: Earned Revenue                                                                            545,092
    Net Program Costs                                                                                 532,518


    Disaster Assistance and Recovery
       Gross Cost                                                                                 15,920,959
       Less: Earned Revenue                                                                         4,550,934
    Net Program Costs                                                                            11,370,025


    Mission Support and Advocacy
       Gross Cost                                                                                      165,062
    Net Program Costs                                                                                 165,062


    Inspector General and Congressional Initiatives
       Gross Cost                                                                                       56,809
    Net Program Costs                                                                                  56,809

    Net Cost of Operations                                                        $              12,124,414


  Note 16: The accompanying notes are an integral part of these statements.




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                                                                                        Other Information (Unaudited)


  (Dollars in Thousands)

                                    U. S. Small Business Administration
           CO N S O L I D AT E D S TAT E M E N T O F C H A N G E S I N N E T P O S I T I O N
                           For The Year Ended September 30, 2025 (Unaudited)

                                                                                         2025
    Funds from other than Dedicated Collections

    Unexpended Appropriations:
     Beginning Balance                                                       $                3,092,566
     Appropriations Received                                                                 12,043,886
     Other Adjustments:
       Rescissions                                                                            (149,212)
       Adjustment - Cancelled Authority                                                        (16,430)
       Return of Unrequired Liquidating Fund Appropriation                                        (412)
       Other Adjustments                                                                          (138)
     Appropriations Used                                                                   (10,818,802)

    Total Unexpended Appropriations                                          $               4,151,458


    Cumulative Results of Operations:
     Beginning Balance                                                       $               (7,346,654)
     Appropriations Used                                                                     10,818,802
     Donations of Cash and Cash Equivalents                                                            2
     Imputed Financing                                                                            55,953
     Other:
       Current Year Liquidating Equity Activity                                                    7,947
       Non-entity Activity                                                                   (3,032,377)
    Net Cost of Operations                                                                  12,124,414
    Net Change in Cumulative Results of Operations                                          (4,274,087)

    Total Cumulative Results of Operations                                   $            (11,620,741)


    Ending Net Position                                                      $             (7,469,283)


  The accompanying notes are an integral part of these statements.




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                                                                                             Other Information (Unaudited)


  (Dollars in Thousands)

                                      U. S. Small Business Administration
                   CO M B I N E D S TAT E M E N T O F B U D G E TA R Y R E S O U R C E S
                             For The Year Ended September 30, 2025 (Unaudited)
                                                                       Nonbudgetary
                                                       Budgetary                                  Total
                                                                        Financing
    BUDGETARY RESOURCES
    Unobligated Balance from Prior Year Budget
                                                   $      4,156,418 $       7,777,561 $           11,933,979
    Authority, Net (discretionary and mandatory)

    Appropriations (discretionary and mandatory)         11,894,262                    -          11,894,262

    Borrowing Authority (discretionary and
                                                                   -       14,522,564             14,522,564
    mandatory)
    Spending Authority from Offsetting
                                                          1,237,937         9,226,764             10,464,701
    Collections
    Total Budgetary Resources                      $    17,288,617 $      31,526,889 $           48,815,506


    STATUS OF BUDGETARY RESOURCES
    New Obligations and Upward Adjustments
                                                   $     12,534,817 $      25,997,479 $           38,532,296
    (total)
    Unobligated Balance, end of year:
      Apportioned, unexpired accounts                     1,748,202         2,637,794               4,385,996
      Unapportioned, unexpired accounts                     596,034         2,891,616               3,487,650
      Unexpired Unobligated Balance, end of year          2,344,236         5,529,410               7,873,646
      Expired Unobligated Balance, end of year            2,409,564                    -            2,409,564
    Unobligated Balance, end of year (total)              4,753,800         5,529,410             10,283,210
    Total Status of Budgetary Resources            $    17,288,617 $      31,526,889 $           48,815,506


    OUTLAYS, NET and DISBURSEMENTS, NET
    Net Outlays (discretionary and mandatory)      $     10,866,439                        $      10,866,439
    Distributed Offsetting Receipts                     (10,030,589)                            (10,030,589)
    Agency Outlays, Net (discretionary and
                                                   $       835,850                         $          835,850
    mandatory)
    Disbursements, Net (total) (mandatory)                             $ (10,219,149)

    Note 17: The accompanying notes are an integral part of these statements.


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                                                                                             Other Information (Unaudited)



  Note 13. Reporting Entity and Summary
  of Significant Accounting Policies (Other
  Information)
  BASIS OF ACCOUNTING AND PRESENTATION
  The SBA prepares financial statements to report its financial position, and the results of its opera-
  tions, as required by the Chief Financial Officers Act of 1990 and the Government Management
  Reform Act of 1994. The financial statements are prepared from the Agency’s records in accordance
  with Generally Accepted Accounting Principles (GAAP), issued by the Federal Accounting Standards
  Advisory Board (FASAB), and the Office of Management and Budget (OMB) Circular A-136, Financial
  Reporting Requirements, as revised.

  The accounting structure of federal agencies is designed to reflect both the accrual and budgetary ac-
  counting transactions. Under the accrual method of accounting, revenues are recognized when earned
  and expenses are recognized when a liability is incurred, without regard to receipt or payment of cash.
  Budgetary accounting facilitates compliance with legal constraints and controls over federal funds.

  BUDGETS AND BUDGETARY ACCOUNTING FOR LOAN PROGRAMS
  The SBA’s loan disbursements are financed by appropriations for long-term loan subsidy cost and
  borrowings from the Treasury’s Bureau of the Fiscal Service for the remaining nonsubsidized portion
  of the loans. The Congress may provide one-year, multi-year, or no-year appropriations to cover the
  estimated long-term costs of the loan programs. The non-subsidized portion of each loan disburse-
  ment, financed initially under permanent indefinite authority to borrow funds from the Treasury, is
  repaid from collections of loan fees, repayments, and default recoveries. The Congress authorizes the
  dollar amount of obligations that can be made for the cost of direct loans and loan guaranties and
  establishes the maximum amount of loans the SBA can guarantee in its annual Appropriation Act.

  A permanent indefinite authority is available to fund any reestimated increase of subsidy costs that
  occurs after the year in which a loan is disbursed. Reestimated reductions of subsidy costs are re-
  turned to the Treasury and are unavailable to the SBA. As required by the FCRA, the SBA uses bud-
  getary “program accounts” to account for appropriations in its credit programs and nonbudgetary
  “financing accounts” to account for credit program cash flow. Estimates and reestimates of credit
  program subsidy expenses are recorded in the SBA’s program accounts. Financing accounts are used
  to account for Treasury borrowings, the collection of loan fees, repayments and default recoveries,
  and the disbursement of loans and loan expenses.

  As a component of the Government-wide reporting entity, the SBA is subject to the Federal budget
  process, which involves appropriations that are provided annually and appropriations that are pro-
  vided on a permanent basis. The financial transactions that are supported by budgetary resources,
  which include appropriations, are generally the same transactions reflected in agency and the
  Government-wide financial reports.




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                                                                                               Other Information (Unaudited)


  The SBA’s budgetary resources reflect past congressional action and enable the entity to incur budget-
  ary obligations, but they do not reflect assets to the Government as a whole. Budgetary obligations are
  legal obligations for goods, services, or amounts to be paid based on statutory provisions. After budget-
  ary obligations are incurred, the Treasury will make disbursements certified by the SBA to liquidate the
  budgetary obligations and finance those disbursements in the same way it finances all disbursements,
  which is to borrow from the public if there is a budget deficit.

  FIDUCIARY ACTIVITIES
  Fiduciary activities are the receipt, management, protection, accounting, investment, and disposi-
  tion by the Federal Government of cash or other assets in which non-federal entities have an own-
  ership interest that the Federal Government must uphold. Fiduciary cash and other assets are not
  assets of the government, and are not recognized on the SBA’s proprietary statements, but they are
  required to be disclosed in the notes to the SBA’s financial statements. SBA’s fiduciary balances are
  on deposit in commercial banks.

  EMPLOYEE BENEFITS
  Employee Health and Life Insurance Benefits

  SBA employees may choose to participate in the contributory Federal Employees Health Benefits
  and the Federal Employees Group Life Insurance programs. The SBA matches a portion of the em-
  ployee contributions to each program. Such matching contributions are recognized as current oper-
  ating expenses.

  Employee Pension Benefits

  SBA employees participate in either the Civil Service Retirement System or the Federal Employees
  Retirement System and Social Security. These systems provide benefits upon retirement and in the
  event of death, disability, or other termination of employment and may also provide pre-retirement
  benefits. They may also include benefits to survivors and their dependents, and they may contain early
  retirement or other special features. The SBA’s contributions to both retirement plans, as well as to the
  government-wide Federal Insurance Contribution Act administered by the Social Security Administra-
  tion, are recognized on the Consolidated Statement of Net Cost as current operating expenses.

  Federal employee benefits also include the Thrift Savings Plan. For FERS employees, the SBA match-
  es employee contributions to the plan, subject to limitations. The matching contributions are recog-
  nized as current operating expenses.

  Imputed Financing Costs

  The SBA recognizes the full cost of providing all employee benefits and future retirement benefits,
  including life and health insurance, at the time employee services are rendered. Eligible retired SBA
  employees can continue to participate in health and life insurance plans. The cost of these benefits is
  funded through Agency contributions, employee compensation to the extent withheld from employ-
  ee and retiree pay, from matching of employee withholding for Thrift Savings Plan and FICA, and by
  the Office of Personnel Management, which administers the retirement programs for SBA employees.




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                                                                                          Other Information (Unaudited)


  The OPM calculates imputed costs as the actuarial present value of future benefits attributed to
  services rendered by covered employees and eligible retired SBA employees during the accounting
  period, net of the amounts contributed by employees, retirees, and the Agency. The SBA recognizes
  these imputed costs in the Statement of Net Cost and imputed financing in determining the SBA’s net
  position.




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                                                                                               Other Information (Unaudited)



  Note 14. Credit Program Disbursements, Expenses
  and Reconciliations of Receivables, Subsidy
  Allowance, and Liability for Loan Guaranties
  A. SUBSIDY COST ALLOWANCE BALANCES
  (Dollars in Thousands)

    For The Year Ended September 30,                                                             2025

    Post-1991 Business Direct and Purchased Guarantied Loans

    Beginning Balance of Allowance Account                                                 $             2,493,967

     Current Year's Subsidy (see 14.C for breakdown by component)                                             4,329

     Loans Written Off                                                                                   (3,347,899)

     Loans Written Off Reversals                                                                         10,235,792

     Subsidy Amortization                                                                                    (1,263)

     Allowance Related to Guarantied Loans Purchased This Year                                            3,642,796

     Miscellaneous Recoveries and Costs                                                                     316,941

     Balance of Subsidy Allowance Account before Reestimates                                             13,344,663

     Reestimates                                                                                             (2,558)

    Ending Balance of Allowance Account                                                    $            13,342,105

    Post-1991 Disaster Direct Loans

    Beginning Balance of Allowance Account                                                 $            40,913,937

     Current Year's Subsidy (see 14.C for breakdown by component)                                           761,214

     Loans Written Off                                                                                  (14,850,405)

     Loans Written Off Reversals                                                                         59,684,829

     Subsidy Amortization                                                                                 7,996,516

     Miscellaneous Recoveries and Costs                                                                   (251,781)

     Balance of Subsidy Allowance Account before Reestimates                                             94,254,310

     Reestimates                                                                                          9,721,141

    Ending Balance of Allowance Account                                                   $           103,975,451


  Note: The Loans Written Off Reversals line includes loans that were returned to regular servicing in
  FY 2025 and reestablished as gross loan receivables, as a result of the Hardship Accommodation
  Program (HAP), which ended in March 2025. The FY 2025 increase in loans to regular servicing was
  primarily due to an update the SBA made to its accounting policy to more accurately value the gross
  receivable for loans that were referred to Treasury for collection efforts or are eligible for Treasury
  referral. See Note 5A for additional information.



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                                                                                       Other Information (Unaudited)



  B. LIABILITY FOR LOAN GUARANTIES
  (Dollars in Thousands)

    For The Year Ended September 30,                                                    2025

    Post-1991 Business Loan Guaranties

    Beginning Balance of Liability for Loan Guaranties                       $               4,827,018

      Claim Payments to Lenders/Guarantee Payments                                           (5,156,075)

      Fees                                                                                    1,489,895

      Interest Supplements Paid                                                                  184,842

      Interest Revenue on Uninvested Funds                                                       136,549

      Interest Expense on Entity Borrowings                                                      (74,772)

      Current Year's Subsidy (see Note 14C for breakdown by component)                              7,061

      Upward Reestimates                                                                      1,177,567

      Downward Reestimates                                                                     (538,625)

      Loan Modifications                                                                       (178,334)

      Adjustment Due to Reestimate & Guarantied Loan Purchases                                1,513,279

      Miscellaneous Recoveries and Costs                                                       (369,100)

    Total Ending Balance of Liability for Loan Guaranties                    $               3,019,305




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                                                                                             Other Information (Unaudited)



  C. SUBSIDY EXPENSE BY COMPONENT
  (Dollars in Thousands)

    For The Year Ended September 30,                                                                2025
    Business Loan Guaranties
      Defaults                                                                        $                  12,807
      Fees                                                                                               (6,029)
      Other                                                                                                  283
      Subsidy Expense Before Reestimates and Loan Modifications                                            7,061
      Loan Modifications                                                                              (178,334)
    Components of Subsidy Reestimates
      Technical Assumptions/Default Reestimates                                                         645,782
      Interest Rate Reestimates                                                                          (6,840)
    Total of the above Components of Subsidy Reestimates                                                638,942
    Total Guarantied Business Loan Subsidy Expense                                    $                467,669
    Business Direct Loans
      Interest                                                                        $                    3,556
      Defaults                                                                                               898
      Other                                                                                                (125)
      Subsidy Expense Before Reestimates and Loan Modifications                                            4,329
    Components of Subsidy Reestimates
      Technical Assumptions/Default Reestimates                                                          (2,545)
      Interest Rate Reestimates                                                                              (13)
    Total of the above Components of Subsidy Reestimates                                                 (2,558)
    Total Business Direct Loan Subsidy Expense                                        $                   1,771
    Disaster Direct Loans
      Interest                                                                        $                 524,694
      Defaults                                                                                          341,729
      Other                                                                                           (105,209)
      Subsidy Expense Before Reestimates and Loan Modifications                                         761,214
    Components of Subsidy Reestimates
      Technical Assumptions/Default Reestimates                                                      9,625,085
      Interest Rate Reestimates                                                                         96,056
    Total of the above Components of Subsidy Reestimates                                             9,721,141
    Total Disaster Direct Loan Subsidy Expense                                        $           10,482,355

  Note: In FY 2025, loan modifications were required to increase fees for 7(a) loans effective March 27,
  2025, and to include the effects of temporary expansion of Community Advantage lending and the
  expected rollout of Manufacturers’ Access to Revolving Credit (MARC) program.



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                                                                                         Other Information (Unaudited)



  D. ADMINISTRATIVE EXPENSE
  The SBA received appropriations to administer its credit programs, including the making, servic-
  ing and liquidation of its loans and guaranties. Amounts expensed in the Statement of Net Cost are
  shown in the following table.

  (Dollars in Thousands)

    For The Year Ended September 30,                                                      2025

      Disaster Direct Loan Programs                                            $                1,009,000

      Business Loan Programs                                                                       162,420

    Total Administrative Expense                                               $              1,171,420




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                                                                                          Other Information (Unaudited)



  E. CREDIT PROGRAM SUBSIDY REESTIMATES
  Reestimates are performed annually, on a cohort-by-cohort basis. The purpose of reestimates is to
  update original program cost estimates to reflect actual cash flow experience as well as changes in
  forecasts of future cash flows. Forecasts of future cash flows are updated based on additional infor-
  mation about historical program performance, revised expectations of future economic conditions,
  and enhancements to cash flow projection methods. Financial statement reestimates were per-
  formed using a full year of performance data for FY 2025 for the SBA’s large loan programs, with nine
  months of actual and three months of projected performance data for the Secondary Market Guaran-
  tee, Microloan, and the small loan programs.

  Business Guarantied Loan Programs

  Net subsidy reestimates for the business guarantied loan programs are shown in the following table.
  (Dollars in Thousands)

    For The Year Ended September 30,                                                       2025

      7(a)                                                                      $                   563,694
      7(a) - Recovery Act                                                                            (3,499)
      7(a) - Jobs Act                                                                                (1,995)
      7(a) - COVID Support                                                                           46,299
      504 CDC                                                                                     (271,376)
      504 CDC - Recovery Act                                                                         (2,713)
      504 CDC - Jobs Act                                                                               (265)
      504 CDC - COVID Support                                                                      (15,534)
      504 CDC - Debt Refinancing                                                                   (29,012)
      504 CDC - Debt Refinancing - COVID Support                                                     (3,568)
      504 First Mortgage Loan Pooling - Recovery Act                                                 (1,121)
      SBIC Debentures                                                                              (78,472)
      SBIC Participating Securities                                                                    1,369
      Secondary Market Guaranty Program                                                                (659)
      Paycheck Protection Program                                                                   435,965
      ARC - Recovery Act                                                                               (171)
      All Other Guaranty Loan Programs                                                                     (1)

    Total Guarantied Loan Program Subsidy Reestimates                           $                 638,942



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                                                                                            Other Information (Unaudited)


  The 7(a) Loan Guaranty program, SBA’s flagship program, had a net upward reestimate of $563.7 mil-
  lion in FY 2025. The upward reestimate is concentrated in the 2018 to 2025 cohorts. These cohorts had
  higher-than-expected losses in FY 2025. The 2025 cohort has higher future loss projections than previ-
  ously estimated. These higher projected losses are in part due to loan compositional differences from
  the initial estimate, implying higher than anticipated credit risk for these loans.

  The 7(a) Recovery Act program had a net downward reestimate of $3.5 million. The reestimate is
  mostly due to lower-than-expected losses in FY 2025.

  The 7(a) Jobs Act cohort had a net downward reestimate of $2.0 million. The reestimate is mostly due
  to lower-than-expected losses in FY 2025.

  Authorized by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (Economic
  Aid Act), the 7(a) COVID Support program offered 90 percent guarantee and upfront and on-going fee
  waivers for eligible borrowers and additional debt relief support. The 7(a) COVID Support program
  had a net upward reestimate of $46.3 million. The reestimate is primarily driven by higher-than-ex-
  pected losses in FY 2025.

  The 504 Certified Development Company program had a net downward reestimate of $271.4 million.
  The reestimate is mostly due to better-than-expected loan performance in FY 2025 contributing to a
  downward reestimate in most cohorts. Aggregate purchases were lower than projected and recover-
  ies were higher than projected by the prior year model.

  The 504 Recovery Act program had a net downward reestimate of $2.7 million. The reestimate is
  mostly due to better-than-expected loan performance in FY 2025. Aggregate purchases were lower
  than projected and recoveries were higher than projected by the prior year model.

  The 504 Jobs Act program had a net downward reestimate of $0.3 million. The reestimate is mostly
  due to better-than-expected loan performance in FY 2025.

  Authorized by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (Economic
  Aid Act), the 504 COVID support program offered fee waivers of third-party lender fees and borrower
  CDC Processing fees, provided for CDC reimbursements of Processing fees, and extended additional
  debt relief support. The 504 COVID support program had a net downward reestimate of $15.5 million.
  The reestimate is mostly due to better-than-expected loan performance in FY 2025. Aggregate pur-
  chases were lower than projected and recoveries were higher than projected by the prior year model.

  The 504 Debt Refinancing program had a net downward reestimate of $29.0 million. The reestimate is
  mostly due to better-than-expected loan performance in FY 2025 contributing to a downward reesti-
  mate for most cohorts. Aggregate purchases were lower than projected by the prior year model.

  Authorized by the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (Eco-
  nomic Aid Act), the 504 Debt Refinancing COVID support program offered fee waivers of third-party
  lender fees and borrower Processing fees, provided for CDC reimbursements of Processing fees, and
  extended additional debt relief support. The 504 Debt Refinance COVID support program had a net
  downward reestimate of $3.6 million. The reestimate is in part due to better than projected loan per-
  formance in FY 2025. Aggregate purchases were lower than projected by the prior year model.




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                                                                                            Other Information (Unaudited)


  The Section 504 First Mortgage Loan Pooling program had a net downward reestimate of $1.1 million
  in FY 2025. The reestimate is mostly due to higher than projected recoveries and lower than project-
  ed purchases which were partially offset by higher than projected advances in FY 2025.

  The SBIC Debentures program had a net downward reestimate of $78.5 million. The reestimate is
  primarily driven by better-than-anticipated program performance in FY 2025. Actual purchases in FY
  2025 were lower than projected leading to lower lifetime expected purchase rates for cohorts 2019-
  2024. Recoveries on previously purchased debentures were lower in FY 2025 than projected, partially
  offsetting the reduction in lifetime expected purchases in the program.

  The SBIC Participating Securities program had a net upward reestimate of $1.4 million. The reesti-
  mate is primarily due to lower than projected recoveries and lower cash inflows in FY 2025. A reduc-
  tion in expected inflows in future years also contributed to the upward reestimate.

  The Secondary Market Guaranty program had a net downward reestimate of $0.7 million in FY 2025.
  The reestimate is a result of offsetting reestimates across cohorts, driven mainly by changes to pro-
  jected earnings on security investments.

  The Paycheck Protection Program (PPP) had a net upward reestimate of $436 million in FY 2025. The
  reestimate is primarily due to higher FY 2025 actual purchases relative to the prior year model projec-
  tions. The increased purchase volume is primarily driven by the processing of guarantee purchase
  transactions in Q4 of FY 2025.

  The America’s Recovery Capital program had a net downward reestimate of $0.17 million. The reesti-
  mate is primarily due to higher than projected recoveries in FY 2025.

  All Other Guaranty Loan programs had a net reestimate of less than $0.001 million.

  Business Direct Loan Programs

  Net subsidy reestimates for the business direct loan programs are shown in the following table.

  (Dollars in Thousands)

    For The Year Ended September 30,                                                         2025

       7(m) Microloan                                                             $                    (2,492)

       7(m) Microloan - Recovery Act                                                                       (14)

       Intermediary Lending Pilot Program                                                                  (52)

    Total Direct Loan Program Subsidy Reestimates                                 $                  (2,558)

  The 7(m) Direct Microloan program had a net downward reestimate of $2.5 million. The reestimate is
  primarily due to aggregate actual defaults being lower and prepayments being higher than projected
  in FY 2025.




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  The 7(m) Direct Microloan Recovery Act program had a downward reestimate of $0.01 million. The re-
  estimate is due to higher than projected aggregate actual recovery in FY 2025 and minor differences
  in actual FY 2025 inflows relative to prior year projections.

  The Intermediary Lending Pilot had a net downward reestimate of $0.05 million. The reestimate is
  mostly due to higher aggregate recoveries and prepayments relative to what was forecasted in the
  prior year model.

  Disaster Direct Loan Program

  Net subsidy reestimates for the disaster direct loan programs are shown in the following table.
  (Dollars in Thousands)

    For The Year Ended September 30,                                                          2025

       Disaster                                                                    $                9,721,141

    Total Disaster Direct Loan Program Subsidy Reestimates                         $               9,721,141

  The Disaster Assistance program had a net upward reestimate of $9,721.14 million. The upward rees-
  timate is primarily due to lower than projected cash collections on COVID EIDL loans in FY 2025, at-
  tributed to lower than projected prepayments on loans in regular service and recoveries on defaulted
  loans, particularly for larger COVID EIDL loans. Lower than projected collections also contributed to
  decrease in expected prepayments and recoveries in future years. and recoveries in future years. These
  factors contribute to an upward reestimate, particularly the FY 2021 and FY 2022 COVID EIDL cohorts
  which have a higher concentration of larger loans. Partially offsetting the upward reestimate, SBA re-
  turned many COVID EIDL loans to regular servicing in FY2025, separate from those placed into the newly
  introduced SBA-Uncollectible status, resulting in improved expectations for future loan collections. This
  activity was concentrated in the FY 2020 COVID EIDL cohort.




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  F. LOANS RECEIVABLE
  Business Direct

  (Dollars in Thousands)

                                                      Pre-1992       Post-1991
    As of September 30, 2025                                                                   Total
                                                       Loans           Loans

    Loans Receivable Direct, Net, beginning of year   $          - $     213,992 $              213,992

       Loans Disbursed                                           -          43,518                 43,518

       Principal & Interest Payments Received                    -        (36,092)               (36,092)

       Foreclosed Property                                       6                  -                     6

     Loans Written Off                                           -              (45)                   (45)

     Interest Revenue on Uninvested Funds                        -          (2,458)               (2,458)

     Interest Expense on Entity Borrowings                       -           6,399                  6,399

     Subsidy Expense                                             -          (4,329)               (4,329)

     Upward Reestimates                                          -            (203)                  (203)

     Downward Reestimates                                        -           2,761                  2,761

     Subsidy Allowance                                           -          (2,679)               (2,679)

     Other non-cash reconciling items                        (6)          (10,839)               (10,845)

    Loans Receivable Direct, Net, end of year         $          - $     210,025 $              210,025




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  Disaster Direct

  (Dollars in Thousands)

                                                        Pre-1992    Post-1991
    As of September 30, 2025                                                               Total
                                                         Loans        Loans

    Loans Receivable Disaster, Net, beginning of year   $       - $ 256,247,176 $ 256,247,176

      Loans Disbursed                                           -     3,484,233             3,484,233

      Principal & Interest Payments Received                (168)    (7,745,471)           (7,745,639)

      Foreclosed Property                                       -          (840)                   (840)

      Loans Written Off                                         -   (14,850,405)         (14,850,405)

      Interest Revenue on Uninvested Funds                      -      (550,662)             (550,662)

      Interest Expense on Entity Borrowings                     -     4,729,312             4,729,312

      Subsidy Expense                                           -      (761,214)             (761,214)

      Upward Reestimates                                        -   (12,029,628)         (12,029,628)

      Downward Reestimates                                      -     2,308,487             2,308,487

      Subsidy Allowance                                         -   (12,187,284)         (12,187,284)

      Other non-cash reconciling items                       201     13,349,492            13,349,693

    Loans Receivable Disaster, Net, end of year         $     33 $231,993,196 $ 231,993,229




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  Business Guarantied

  (Dollars in Thousands)

                                                       Pre-1992       Post-1991
   As of September 30, 2025                                                                  Total
                                                        Loans           Loans
   Defaulted Guaranteed Loans Receivable, Net,
                                                   $              - $ 1,646,649 $ 1,646,649
   beginning of year

     Claim Payment to Lenders/Guarantee Payments                  -     5,156,075             5,156,075

     Principal & Interest Payments Received                 (394)       (665,840)             (666,234)

     Fees                                                         -    (1,489,895)          (1,489,895)

     Foreclosed Property                                      (1)           (9,009)               (9,010)

     Loans Written Off                                            -    (3,347,855)          (3,347,855)

     Subsidy Allowance                                            -     1,057,355             1,057,355

     Other non-cash reconciling items                        395        (213,417)             (213,022)

   Defaulted Guaranteed Loans Receivable, Net,
                                                   $              - $ 2,134,063 $ 2,134,063
   end of year




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   G. LOANS DISBURSED
   (Dollars in Thousands)

    New Loans Disbursed During the Year Ended September 30,                  2025

    Direct Loans

      Business Direct Loan Program                                $                    43,518

      Disaster Loan Program
                                                                                   3,484,233

    Total Direct Loans Disbursed                                  $              3,527,751


    Guarantied Loans

      Total Principal Disbursed at Face Value                     $               39,930,460

      Total Principal Disbursed Guarantied by the SBA                             31,812,913




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  Note 15. Leases
  The SBA leases its facilities from the General Services Administration (GSA). The SBA enters into an
  Occupancy Agreement with the GSA for each facility. The GSA bills the SBA monthly for leased space.
  Agreements specify that space in federal buildings can be vacated with 120 to 180 days’ notice. The
  SBA anticipates continuing the same or similar facilities leases in the future.

  For official government travel, the SBA leases its vehicles from the GSA.

  These federal leases with the GSA are intragovernmental leases and are expensed in the Statement of
  Net Cost when incurred. Lease expenses for FY 2025 are $44.0 million.

  (Dollars in Thousands)

    For The Year Ended September 30,                                                         2025

    Major Underlying Asset Category

      Buildings                                                                   $                    42,930

      Vehicles                                                                                           1,111

    Total Intragovernmental Lease Expenses as Lessee                              $                   44,041

  The SBA’s non-federal leases include office equipment and parking. The SBA has determined that
  there is no material impact to the SBA financial statements as the total value does not round up to
  $1.0 million.




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  Note 16. Consolidated Statement of Net Cost
  Federal cost accounting standards require the SBA to report operating costs by major program. Full
  costs include all direct and indirect costs for a program. Full costs are reduced by exchange (earned)
  revenues to arrive at net operating cost.

  Gross Cost
  The full and net operating costs of SBA’s major programs are presented in the Consolidated State-
  ment of Net Cost. Full costs are comprised of all direct costs for the program and those indirect costs
  which can be reasonably assigned or allocated to the program, including employee pension and
  other retirement benefit costs paid by the OPM and charged to the SBA.

  Earned Revenue
  Earned revenue arises from exchange transactions and is deducted from the full cost of SBA’s major
  programs to arrive at net cost of operations. The SBA recognizes earned revenue when reimburse-
  ments are payable from other federal agencies and the public as a result of costs incurred or services
  performed. Two major sources of earned revenue include interest earned on SBA’s outstanding
  business and disaster loan portfolios, and interest earned on uninvested funds in the credit reform
  financing accounts.

  Reporting by Major Program Category
  The SBA reports net costs by major program category. Access to Capital, Investment and Innovation,
  Contracting and Business Development programs strengthen the domestic economy by promoting
  the “Made in America” initiative to grow U.S. manufacturing, expanding access to capital, and fostering
  American innovation. Disaster Assistance and Recovery programs prepare communities to address risks
  and help disaster survivors recover and rebuild their communities. Mission Support and Advocacy sup-
  ports the agency addressing fraud risks, program evaluation, and advocacy for small business. Agency
  administrative overhead costs are fully allocated to the programs. Inspector General and Congressional
  Initiatives are program costs associated with the Office of the Inspector General and Congressional
  Initiatives. The OIG’s mission and funding are a separate and independent part of the SBA.

  Intragovernmental Gross Cost is incurred by the SBA in exchange transactions with other federal
  agencies. Other than Intragovernmental Gross Cost is incurred in exchange transactions with the
  public. Intragovernmental Earned Revenue is earned by the SBA in exchange transactions with other
  federal agencies. Other than Intragovernmental Earned Revenue is earned in exchange transactions
  with the public. The General Services Administration and the Treasury are SBA’s primary intragovern-
  mental trading partners.

  The classification as Intragovernmental Cost or Other than Intragovernmental Gross Cost relate to
  the source of goods and services received by the SBA and not to the classification of related revenue.
  Revenue or cost being defined as “Intragovernmental” or “Other than Intragovernmental ” is defined
  on a transaction-by-transaction basis. The purpose of this classification is to enable the federal gov-
  ernment to provide consolidated financial statements, and not to match the public and intragovern-
  mental revenue with costs that are incurred to produce public and intragovernmental revenue.




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  GROSS COST AND EXCHANGE REVENUE
  (Dollars in Thousands)

    For The Year Ended September 30,                                               2025

    Access to Capital, Investment & Innovation, Contracting & Business Development
      Intragovernmental Gross Cost                                       $                  197,976
      Other than Intragovernmental Gross Cost                                               879,634
      Gross Program Costs                                                               1,077,610

      Intragovernmental Earned Revenue                                                      140,855
      Other than Intragovernmental Earned Revenue                                           404,237
      Program Earned Revenue                                                               545,092

    Disaster Assistance and Recovery
      Intragovernmental Gross Cost                                       $               4,942,723
      Other than Intragovernmental Gross Cost                                           10,978,236
      Gross Program Costs                                                             15,920,959

      Intragovernmental Earned Revenue                                                      550,662
      Other than Intragovernmental Earned Revenue                                        4,000,272
      Program Earned Revenue                                                            4,550,934

    Mission Support and Advocacy
      Intragovernmental Gross Cost                                       $                   37,464
      Other than Intragovernmental Gross Cost                                               127,598
      Gross Program Costs                                                                  165,062

    Inspector General and Congressional Initiatives
      Intragovernmental Gross Cost                                       $                   12,894
      Other than Intragovernmental Gross Cost                                                43,915
      Gross Program Costs                                                                    56,809

    Net Cost of Operations                                               $            12,124,414




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  Note 17. Statement of Budgetary Resources
  The Statement of Budgetary Resources presents information about total budgetary resources avail-
  able to the SBA and the status of those resources as of September 30, 2025. SBA’s budgetary re-
  sources were $17.3 billion for the fiscal year ended September 30, 2025. Additionally, $31.5 billion of
  nonbudgetary resources (including borrowing authority and collections of loan principal, interest,
  and fees in financing funds) were reported for the fiscal year ended September 30, 2025.

  NET ADJUSTMENTS TO UNOBLIGATED BALANCE, BROUGHT FORWARD, OCTOBER 1
  The beginning balance brought forward for FY 2025 decreased by $3.8 billion in total. This amount
  reflects an increase of $1.1 billion in recoveries and a decrease of $4.9 billion in Other Changes in
  Unobligated Balance. This other change represents the prior year repayment of debt.

  PERMANENT INDEFINITE APPROPRIATIONS
  The SBA receives permanent indefinite appropriations annually to fund increases in the projected
  subsidy costs of loan programs, as determined by the reestimation process required by the FCRA. The
  appropriations are received initially in the SBA Program Funds, and then transferred to the Financ-
  ing Funds, where they are used to fund obligations. SBA’s Liquidating Funds also receive permanent
  indefinite appropriations to fund obligations. The Financing Funds are used to account for credit
  program obligations made after FY 1991. Liquidating Funds are used to account for credit program
  obligations made prior to FY 1992.

  Decreases in projected subsidy costs in the Financing Funds are returned to the Treasury through
  SBA’s annual reestimation process. The prior year’s ending unobligated balances in SBA’s Liquidating
  Funds are also transferred to the Treasury annually.

  BORROWING AUTHORITY AND TERMS OF BORROWING
  The SBA is authorized to borrow from the Treasury’s Bureau of Fiscal Service when funds needed
  to disburse direct loans and purchase guarantied loans exceed subsidy costs and collections in the
  nonbudgetary loan financing funds. In FY 2025, the SBA received $14.5 billion of borrowing authority
  from the OMB. The SBA pays interest to the Treasury based on Treasury’s cost of funds. The rate at
  which interest is paid to the Treasury on the amounts borrowed (or received from the Treasury on un-
  invested cash balances) in a loan financing fund for a particular cohort is a disbursement-weighted
  average discount rate for cohorts prior to FY 2001 and a single effective rate for cohorts beginning
  with FY 2001. The SBA calculates and repays borrowings not needed for working capital at mid-year
  and at year-end for prior year cohorts. The SBA uses the loan principal, interest, and fees collected
  from the borrowers in its loan financing funds to repay its Treasury borrowings. The repayment
  maturity dates for borrowings from the Treasury are based on the loan maturities used in the sub-
  sidy calculation. The maturities range from 16 years for direct business loans, 25 years for guarantied
  business loans, and 30 years for disaster loans.




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  UNOBLIGATED BALANCES
  Unobligated balances at September 30, 2025 is $10.3 billion which include $5.9 billion of unavailable
  unobligated balances. These balances are unavailable primarily because the balances are expired
  or unapportioned by the OMB. The SBA accumulates the majority of the unobligated balances in its
  nonbudgetary financing accounts during the fiscal year ($5.5 billion in FY 2025) from fees and subsidy
  to fund default claims in future years. In addition, unobligated balances are accumulated in budget-
  ary accounts from appropriations ($4.8 billion in FY 2025) that are used to finance SBA’s ongoing
  program operations. The SBA requests OMB apportionments as needed, and after OMB approval,
  apportioned amounts are available for obligation.

  UNDELIVERED ORDERS
  Undelivered orders consist of goods or services ordered and obligated which the SBA has not re-
  ceived. This includes any orders that have been paid in advance, but for which delivery or perfor-
  mance has not yet occurred.
  (Dollars in Millions)

    For The Year Ended September 30,                                                        2025

    Intragovernmental
      Unpaid                                                                  $                         758.2
      Paid                                                                                                 9.1

    Total Intragovernmental                                                                             767.3
    Other than Intragovernmental
      Unpaid                                                                  $                       2,865.4
      Paid                                                                                                10.8
    Total Other than Intragovernmental                                                                2,876.2

    Total Undelivered Orders                                                  $                     3,643.5




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  DIFFERENCES BETWEEN THE STATEMENT OF BUDGETARY RESOURCES AND THE BUD-
  GET OF THE U.S. GOVERNMENT
  There was no material difference between the FY 2024 Statement of Budgetary Resources and the
  President’s FY 2026 budget submission. The President’s FY 2027 Budget with actual numbers for FY
  2025 has not yet been published and will be available at a later date on the OMB website. The SBA
  expects no material differences between the President’s Budget “actual” column and the FY 2025
  reported results when the budget becomes available in early 2026.

  DISTRIBUTED OFFSETTING RECEIPTS
  Distributed offsetting receipts are amounts that an agency collects from the public or from other Gov-
  ernment agencies that are used to offset or reduce an agency’s budget outlays. Agency outlays are
  measured on both a gross and net basis, with net outlays being reduced by offsetting receipts (and
  other amounts).




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  Note 18. Fiduciary Activities: Master Reserve
  Fund and Master Reserve Account
  Fiduciary activities are the receipt, management, protection, accounting, investment, and
  disposition by the federal government of cash or other assets in which non-federal entities have an
  ownership interest that the federal government must uphold. Fiduciary cash and other assets are not
  assets of the government and are not recognized on the SBA’s proprietary statements, but they are
  required to be disclosed in the notes to the SBA’s financial statements. The SBA’s fiduciary balances
  are on deposit in commercial banks.

  The Master Reserve Fund (MRF) is a fiduciary activity administered by the SBA’s 7(a) Fiscal Transfer
  Agent. The balance in the MRF is invested, according to the SBA policy, entirely in Treasury securities.
  The MRF is an integral part of the SBA’s 7(a) secondary market program. The MRF was authorized
  by the Small Business Secondary Market Improvement Act of 1984 to facilitate the pooling of 7(a)
  guarantied loans that are purchased by secondary market investors. The MRF receives monthly
  payments from SBA guarantied borrowers and disburses monthly to 7(a) secondary market pool
  investors based on a schedule of amounts due. The 7(a) secondary market program includes the
  SBA’s guaranty of timely payment, as well as a default guaranty, to 7(a) secondary market investors.
  The MRF supports $39.2 billion and $38.1billion of outstanding SBA guarantied 7(a) secondary
  market pool principal as of September 30, 2025 and 2024.

  The Master Reserve Account (MRA) is a fiduciary activity administered by the SBA’s 504 Central
  Servicing Agent. The balance in the MRA is invested entirely in Treasury securities. The MRA facilitates
  the operation of the 504 Certified Development Company secondary market program. The MRA was
  authorized by Section 505 of the Small Business Investment Act of 1958 as amended, as a vehicle
  to receive, temporarily hold, and distribute 504 program cash flows. The MRA receives monthly
  payments from 504 borrowers and retains the payments until a semi-annual debenture payment
  is due to secondary market investors. The 504 secondary market program includes the SBA’s
  guaranty of timely payment, as well as a default guaranty, to 504 secondary market investors. The
  MRA supports $37.3 billion and $34.8 billion of SBA guarantied 504 debentures outstanding in the
  secondary market as of September 30, 2025 and 2024.

  The composition of the MRF and MRA and a reconciliation of the changes in the assets are included
  in the following tables.




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  (Dollars in Thousands)

                                                             Fiduciary Assets

   For The Year Ended September 30,                           2025                                           2024

                                              MRF             MRA               Total         MRF            MRA                   Total

   Cash                                   $            - $            - $               - $            - $            17 $                   17

   Short Term Securities

     Money Market Funds                         551,928         637,502         1,189,430       404,727        632,313             1,037,040

     Treasury Bills                              43,910               -            43,910       128,114                 -             128,114

   Total Cash and Short Term Securities         595,838         637,502         1,233,340       532,841       632,330             1,165,171


   Long Term Securities
     Treasury Notes/Bonds Including
                                               1,089,303              -         1,089,303      1,082,771                -          1,082,771
     Interest

   Total Long Term Securities                 1,089,303               -         1,089,303     1,082,771                 -         1,082,771

   Net Assets                             $   1,685,141 $      637,502 $    2,322,643 $       1,615,612 $    632,330 $            2,247,942




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  (Dollars in Thousands)

                                                                   Fiduciary Assets

   For The Year Ended September 30,                                  2025                                                  2024

                                                    MRF               MRA              Total             MRF               MRA                  Total

   Beginning Net Assets                        $ 1,615,612 $           632,330 $ 2,247,942 $ 1,893,951 $                    584,118 $ 2,478,069

   Receipts
     Earned
                                                       87,493            39,656           127,149            99,129           43,165                142,294
     Income
     Contributions                                 12,213,013        14,577,822       26,790,835        12,086,813        12,937,091            25,023,904

     Net Realized Gain (Loss)                               28                 -               28               127                   -                  127

   Total Receipts                                 12,300,535        14,617,478       26,918,012        12,186,069        12,980,256           25,166,325

   Less Disbursements
     Payments to Investors                         12,231,005        14,612,306       26,843,311        12,464,408        12,932,044            25,396,452

     Expenses                                                 -                -                 -                 -                  -                      -

   Total Disbursements                            12,231,005        14,612,306       26,843,311        12,464,408        12,932,044           25,396,452

   Ending Net Assets                           $ 1,685,141 $           637,502 $ 2,322,643 $ 1,615,612 $                    632,330 $ 2,247,942


  The SBA has four accounts that belong to the 7(a) loan program and are non-MRF in nature. Two of the four non-MRF accounts are fiduciary in nature (7a
  Escrow & 7a Disbursement). The balances of the two fiduciary accounts are $82.5 million and $100.2 million at September 30, 2025 and September 30,
  2024. The other two non-MRF accounts are non-fiduciary in nature and are maintained for administrative actions and fees.




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  Note 19. Reconciliation of Net Operating Cost
  and Net Budgetary Outlays
  SFFAS 53 amends requirements for a reconciliation between budgetary and financial accounting in-
  formation established by SFFAS 7. SFFAS 53 provides for the budget and accrual reconciliation (BAR)
  to replace the statement of financing. The BAR explains the relationship between the entity’s net
  outlays on a budgetary basis and the net cost of operations during the reporting period.

  Budgetary accounting is used for planning and control purposes and relates to both the receipt and use
  of cash. Financial accounting is intended to provide a picture of the government’s financial operations
  and financial position and presents information on an accrual basis. The accrual basis includes infor-
  mation about costs arising from the consumption of assets and the incurrence of liabilities. The recon-
  ciliation of net outlays presented on a budgetary basis, and the net cost, presented on an accrual basis,
  provides an explanation of the relations between budgetary and financial accounting information.
  The reconciliation serves not only to identify costs paid for in the past and those that will be paid in the
  future, but also to assure integrity between budgetary and financial accounting. The analysis illustrates
  this reconciliation by listing the key differences between net cost and net outlays.

  Reestimate expense is recorded at the end of the fiscal year and funded in the following fiscal year.
  SBA’s annual reestimate process updates program costs based upon actual cash flow experience and
  forecasts of future cash flow. As a part of the reestimate process there is an adjustment for the Presi-
  dent’s Budget where expenses for downward adjustments are recorded in the budgetary program
  funds and the outlays are from financing funds creating a difference between budgetary outlays and
  net cost.

  Changes in assets recognize the timing differences between the recognition of income and the re-
  ceipt of funds. These are primarily non-federal advances.

  Changes in liabilities recognize the timing difference between the recording and payment of expenses.

  Other financing sources include SBA’s imputed cost for retirement benefits. This is an expense for the
  Agency that is funded by the OPM.

  Components of budget outlays that are not part of net operating cost include disbursements and
  receipts that are not a revenue or an expense.




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   BUDGET AND ACCRUAL RECONCILIATION
   (Dollars in Thousands)

                                                              Federal         Non-federal         Total 2025
    Net Operating Cost (SNC)                              $    4,499,540 $      7,624,874 $ 12,124,414

    Components of Net Operating Cost not Part of the Budgetary Outlays

      Property, plant and equipment depreciation
                                                                          -       (29,583)               (29,583)
      expense
      Year-end credit reform subsidy reestimates              (10,386,964)                  -      (10,386,964)
      President's Budget adjustment to downward
                                                                  (19,265)                  -            (19,265)
      reestimates
      Downward Modification                                       182,504                   -            182,504
      President's Budget adjustment to upward
                                                                   48,703                   -              48,703
      reestimates

      Increase/(decrease) in assets not affecting Budget Outlays:
      Accounts Receivable, Net                                           53        132,636               132,689
      Advances                                                     (1,386)          (1,322)                (2,708)
      Loans Receivable, Net                                               -               38                     38
      Other assets                                                        -         (8,618)                (8,618)

      (Increase)/decrease in liabilities not affecting Budget Outlays:
      Accounts Payable                                             (7,193)         427,418               420,225
      Accrued Grant Liability                                             -         85,698                 85,698
      Federal Employee Salary, Leave, and Benefits
                                                                          -         (5,753)                (5,753)
      Payable
      Post-Employment Benefits Payable                                    -           1,526                  1,526
      Surety Bond Guarantee Program Future Claims                         -       (12,322)               (12,322)
      Other Liabilities                                         (108,826)               (45)           (108,871)

      Other Financing Sources:
      Imputed Cost                                                (55,953)                  -            (55,953)
    Total Components of Net Operating Cost Not
                                                          $( 10,348,327) $        589,673 $ (9,758,654)
    Part of the Budget Outlays

   Continued...


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  ...Continued

                                                       Federal       Non-federal          Total 2025

    Components of the Budget Outlays That Are Not Part of Net Operating Cost
      Acquisition of Capital Assets                              -            5,759                 5,759

      Other Financing Sources:
      Donation of Cash and Cash Equivalents                      -               (2)                    (2)
      Effect of prior year credit reform subsidy
                                                        8,494,922                   -          8,494,922
      reestimates
    Total Components of the Budget Outlays That    $   8,494,922 $           5,757 $          8,500,679
    Are Not Part of Net Operating Cost

    Other Reconciling Items
      Distributed Offsetting Receipts                            -    (10,030,589)          (10,030,589)

                                                   $             - $(10,030,589) $(10,030,589)
    Total Other Reconciling Items
    Total Net Outlays                                                                   $       835,850

    Budgetary Agency Outlays, Net (SBR)
      Budgetary Agency Outlays, Net                                                     $       835,850




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                                                                                           Other Information (Unaudited)



  Note 20: Reclassification of Financial
  Statement Line Items for Financial Report
  Compilation Process
  To prepare the Financial Report of the U.S. Government (Financial Report), the Department of the
  Treasury requires agencies to submit an adjusted trial balance, which is a listing of amounts by U.S.
  Standard General Ledger account that appear in the financial statements. Treasury uses the trial
  balance information reported in the Government-wide Treasury Account Symbol Adjusted Trial Bal-
  ance System (GTAS) to develop a Reclassified Statement of Net Cost and a Reclassified Statement
  of Changes in Net Position for each agency, which are accessed using GTAS. Treasury eliminates all
  intragovernmental balances from the reclassified statements and aggregates lines with the same title
  to develop the Financial Report statements. This note shows the SBA’s financial statements and the
  SBA’s reclassified statements prior to elimination of intragovernmental balances and prior to aggre-
  gation of repeated Financial Report line items. A copy of the 2024 Financial Report can be found here:
  Bureau of the Fiscal Service - Reports, Statements & Publications (treasury.gov) and a copy of the
  2025 Financial Report will be posted to this site as soon as it is released.

  The term “intragovernmental” is used in this note to refer to amounts that result from other compo-
  nents of the Federal Government.

  The term “non-Federal” is used in this note to refer to Federal Government amounts that result from
  transactions with non-Federal entities. These include transactions with individuals, businesses, non-
  profit entities, and State, local, and foreign governments.

  The SBA does not have funds from dedicated collections.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 123
                                                                                                                                          Other Information (Unaudited)
  (Dollars in Thousands)
                                                                                         Line Items Used to Prepare FY 2025 Government-Wide
                              FY 2025 SBA Statement of Net Cost
                                                                                                        Statement of Net Cost
                                                                                                      Non-Federal Cost
   STRATEGIC GOAL 1:
   Access to Capital, Investment & Innovation, Contracting & Business Development   $    12,029,384    Non-Federal Gross Cost

     Gross Cost                                                   $     1,077,610       12,029,384    Total Non-Federal Cost

     Less: Earned Revenue                                                 545,092                     Intragovernmental Costs

   Net Cost of Strategic Goal 1                                          532,518           169,300     Benefit Program Costs

                                                                                            55,953     Imputed Costs
   STRATEGIC GOAL 2:
   Disaster Assistance and Recovery                                                        105,486     Buy /Sell Costs

     Gross Cost                                                        15,920,959         4,810,715    Borrowing and Other Interest Expense

     Less: Earned Revenue                                               4,550,934           49,602     Other Expenses (w/o Reciprocals)

   Net Cost of Strategic Goal 2                                       11,370,025         5,191,056    Total Intragovernmental Costs

   STRATEGIC GOAL 3:                                                                    17,220,440    Total Reclassified Gross Cost
   Mission Support and Advocacy
     Gross Cost                                                           165,062        4,404,509    Non-federal Earned Revenue

   Net Cost of Strategic Goal 3                                          165,062                      Intragovernmental Earned Revenue

                                                                                             1,848     Buy/Sell Revenue
   COST NOT ASSIGNED TO STRATEGIC GOALS
                                                                                           689,669     Borrowing and Other Interest Revenue
     Gross Cost                                                            56,809
                                                                                           691,517    Total Intragovernmental Earned Revenue
   Net Cost Not Assigned to Strategic Goals                                56,809
                                                                                         5,096,026    Total Reclassified Earned Revenue

   Net Cost of Operations                                         $   12,124,414    $   12,124,414    Net Cost




U.S. Small Business Administration                                                                                          Agency Financial Report Fiscal Year 2025 124
                                                                                                                                                                  Other Information (Unaudited)
  (Dollars in Thousands)

           FY 2025 SBA Statement of Changes in Net Position                                    Line Items Used to Prepare FY 2025 Government-Wide
                                                                                                       Statement of Changes in Net Position
   Funds from other than Dedicated Collections                                   $     3,092,566 Unexpended Appropriations, Beginning Balance
   Unexpended Appropriations:                                                         11,877,694    Appropriations Received
     Beginning balance                                       $      3,092,566
     Appropriations Received                                       12,043,886
     Other Adjustments:
       Rescissions                                                   (149,212)
        Adjustment - Cancelled Authority                              (16,430)
       Return of Unrequired Liquidating Fund Appropriation               (412)
       Other Adjustments                                                 (138)
   Appropriations Used                                            (10,818,802)       (10,818,802) Appropriations Used
   Total Unexpended Appropriations                           $      4,151,458    $     4,151,458 Total Unexpended Appropriations
   Cumulative Results of Operations:
     Beginning Balance                                       $     (7,346,654)   $   (7,346,654) Cumulative Results, Beginning Balance
       Other Adjustments:
          Current Year Liquidating Equity Activity                      7,947         10,818,802    Appropriations Expended
     Appropriations Used                                           10,818,802              7,947    Non-expenditure Transfers-Out of Unexpended Appropriations and Financing Sources
       Donations of Cash and Cash Equivalents                               2         10,826,749 Total Appropriations Used
                                                                                         (47,483)   Other Taxes and Receipts
                                                                                        (47,483) Total Non-Federal Non-Exchange Revenue
                                                                                         149,642    Collections Transferred into a TAS Other than the General Fund of the US Government
                                                                                        149,642 Total Federal Non-Exchange Revenue
     Imputed Financing                                                 55,953             55,953    Imputed Financing
     Other:                                                                          (10,066,433)   Non-Entity Collections Transferred to the General Fund of the U.S. Government
                                                                                                    Accrual for Non-Entity Amounts to be Collected and Transferred to the General
          Non-entity Activity                                      (3,032,377)         6,931,899
                                                                                                    Fund of the U.S. Government

                                                                                     (3,078,581) Total Transfers and Imputed Financing

   Net Cost of Operations                                         12,124,414         12,124,414 Net Cost of Operations

   Total Cumulative Results of Operations                    $   (11,620,741)    $ (11,620,741) Total Cumulative Results of Operations

   Ending Net Position                                       $    (7,469,283)    $   (7,469,283) Net Position




U.S. Small Business Administration                                                                                                                  Agency Financial Report Fiscal Year 2025 125
                                                                                                                                                                                     Other Information (Unaudited)
  (Dollars in Thousands)
                                                                           Required Supplementary Information
                                                        CO M B I N I N G S TAT E M E N T O F B U D G E TA R Y R E S O U R C E S
                                                                   For The Year Ended September 30, 2025 (Unaudited)
                                                                     BLIF                                        DLF                              SBGRF                    SE                   OIG

                                                                              Nonbudgetary                                Nonbudgetary
   BUDGETARY RESOURCES                                   Budgetary                                   Budgetary                                   Budgetary             Budgetary              Budgetary
                                                                               Financing                                   Financing

   Unobligated Balance from Prior Year Budget       $         2,002,204   $         6,064,802    $         163,936    $         1,712,759    $         114,312    $          1,193,460    $           25,217
   Authority, Net (discretionary and mandatory)

   Appropriations (discretionary and mandatory)                904,395                       -           10,326,947                      -                    -                 358,798               88,620
   Borrowing Authority (discretionary and
                                                                      -              978,887                      -            13,543,677                     -                       -                     -
   mandatory)
   Spending Authority from Offsetting Collections                     -             3,543,861                     -             5,682,903               29,798               1,208,122                     15

   Total Budgetary Resources                        $        2,906,599    $       10,587,550     $      10,490,883    $       20,939,339     $        144,110     $         2,760,380     $        113,852


   STATUS OF BUDGETARY RESOURCES
   New Obligations and Upward Adjustments (total)   $          935,786    $         7,254,443    $        9,920,056   $        18,743,036    $          28,912    $          1,323,981    $           48,750

   Unobligated Balance, end of year:

    Apportioned, unexpired accounts                              3,836              1,492,735              456,418              1,145,059               11,098                  973,351               62,848

    Unapportioned, unexpired accounts                           64,652              1,840,372              114,409              1,051,244              104,100                   24,223                   216
    Unexpired Unobligated Balance,
                                                                68,488              3,333,107              570,827              2,196,303              115,198                  997,574               63,064
    end of year
    Expired Unobligated Balance, end of year                  1,902,325                      -                    -                      -                    -                 438,825                2,038

   Unobligated Balance, end of year (total)                   1,970,813             3,333,107              570,827              2,196,303              115,198               1,436,399                65,102

   Total Status of Budgetary Resources              $        2,906,599    $       10,587,550     $      10,490,883    $       20,939,339     $        144,110     $         2,760,380     $        113,852


   OUTLAYS, NET and DISBURSEMENTS, NET
   Net Outlays (discretionary and mandatory)        $          940,911                           $        9,501,527                          $          (3,850)   $             111,094   $           47,193

   Distributed Offsetting Receipts                                    -                                           -                                           -           (10,030,589)                      -
   Agency Outlays, Net (discretionary and
                                                    $          940,911                           $       9,501,527                           $         (3,850)    $       (9,919,495)     $           47,193
   mandatory)
   Disbursements, Net (total) (mandatory)                                 $        3,389,318                          $      (13,608,467)




U.S. Small Business Administration                                                                                                                                    Agency Financial Report Fiscal Year 2025 126
                                                                                                                                                                                           Other Information (Unaudited)
  (Dollars in Thousands)
                                                                         Required Supplementary Information
                                                      CO M B I N I N G S TAT E M E N T O F B U D G E TA R Y R E S O U R C E S
                                                                 For The Year Ended September 30, 2025 (Unaudited)
                                                  ADVOCACY            EDP             EIDL            SVOG            RRF             WCF             BATF           TOTAL            TOTAL
                                                                                                                                                                                   Nonbudgetary
   BUDGETARY RESOURCES                            Budgetary       Budgetary       Budgetary       Budgetary       Budgetary       Budgetary       Budgetary        Budgetary                             Total
                                                                                                                                                                                    Financing
   Unobligated Balance from Prior Year Budget
   Authority, Net (discretionary and mandatory)   $    7,892 $        101,703 $        467,579 $        45,164 $       15,079 $        19,355 $              517 $ 4,156,418 $          7,777,561 $ 11,933,979


   Appropriations (discretionary and
   mandatory)                                         10,109          316,800         (107,165)               -       (15,079)         10,837                  -     11,894,262                 -        11,894,262
   Borrowing Authority (discretionary and
                                                              -               -               -               -               -               -                -               -       14,522,564        14,522,564
   mandatory)
   Spending Authority from Offsetting
                                                              -               -               -               -               -               -                2      1,237,937         9,226,764        10,464,701
   Collections

   Total Budgetary Resources                      $   18,001 $        418,503 $       360,414 $        45,164 $               - $      30,192 $              519 $ 17,288,617 $        31,526,889 $ 48,815,506

   STATUS OF BUDGETARY RESOURCES

   New Obligations and Upward Adjustments
   (total)                                        $    9,634 $        252,188 $              91 $            20 $             - $      15,363 $               36 $ 12,534,817 $        25,997,479 $ 38,532,296

   Unobligated Balance, end of year:

    Apportioned, unexpired accounts                    8,367          126,490           45,419          45,144                -        14,750                481      1,748,202         2,637,794         4,385,996

    Unapportioned, unexpired accounts                         -               -        288,432                -               -               -                2        596,034         2,891,616         3,487,650
    Unexpired Unobligated Balance,
                                                       8,367          126,490          333,851          45,144                -        14,750                483      2,344,236         5,529,410         7,873,646
    end of year
    Expired Unobligated Balance, end of year                  -        39,825           26,472                -               -             79                 -      2,409,564                 -         2,409,564

   Unobligated Balance, end of year (total)            8,367          166,315          360,323          45,144                -        14,829                483      4,753,800         5,529,410        10,283,210

   Total Status of Budgetary Resources            $   18,001 $        418,503 $       360,414 $        45,164 $               - $      30,192 $              519 $ 17,288,617 $        31,526,889 $ 48,815,506


   OUTLAYS, NET and DISBURSEMENTS, NET
   Net Outlays (discretionary and mandatory)      $    9,386      $   270,840     $    (21,254)   $     (4,090)   $    (2,084)    $    16,731     $           35   $ 10,866,439                     $    10,866,439

   Distributed Offsetting Receipts                            -               -               -               -               -               -                -    (10,030,589)                        (10,030,589)

   Agency Outlays, net (discretionary and
                                                  $    9,386 $        270,840 $       (21,254) $       (4,090) $       (2,084) $       16,731 $               35 $     835,850                      $      835,850
   mandatory)

   Disbursements, Net (total) (mandatory)                                                                                                                                          $ (10,219,149)




U.S. Small Business Administration                                                                                                                                          Agency Financial Report Fiscal Year 2025 127
                                                                              Other Information (Unaudited)


  U.S. Small Business Administration
  Office of Inspector General



                                        Top Management and
                                     Performance Challenges
                                        Facing the Small Business Administration
                                                              in Fiscal Year 2026

                                              Report 26-01 | December 18, 2025




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                                                                                              Other Information (Unaudited)



  Contents
  MESSAGE FROM THE DEPUTY INSPECTOR GENERAL                                                                   131
  INTRODUCTION                                                                                                132
  Table 1: Top Management and Performance Challenges Facing SBA in Fiscal Year 2026                            132
  CHALLENGE 1: PROTECTING THE INTEGRITY OF SBA PROGRAMS                                                       133
  Managing Fraud Risk                                                                                          133
  Improving Verification of Eligibility                                                                        135
  Mitigating Improper Payments                                                                                 137
  Seizure and Return of Funds                                                                                  138
  CHALLENGE 2: MANAGING SBA’S LOAN PORTFOLIO AND PARTICIPATING LENDERS 141
  Servicing Disaster Loans                                                                                     141
             Figure 1: The Increased Burden of COVID-19 EIDL Servicing on SBA                                  142
  Planning and Modeling for Future Disaster Responses                                                          142
             Figure 2: Total Dollar Amount of Approved Disaster Loans                                          143
  Overseeing Lenders                                                                                           143
             Ensuring Retention of Loan and Award Records                                                      145
  CHALLENGE 3: MEASURING PERFORMANCE AND MONITORING SBA PROGRAMS                                              147
  Measuring Program Performance                                                                                147
  Monitoring Program Performance Results                                                                       147
  Ensuring Funds Are Used as Intended                                                                          148
  CHALLENGE 4: FINANCIAL REPORTING AND MANAGING DATA                                                          150
  Improving Internal Controls Through Financial Statements Audit Remediation                                   150
             Figure 3: SBA Audit Deficiencies From Pre-Pandemic Through Pandemic Recovery                      151
  Authorized Data Sharing                                                                                      152
  CHALLENGE 5: MANAGING RISKS IN INFORMATION TECHNOLOGY SYSTEMS                                               154
             Figure 4: Risk Management Best Practices Strategy                                                 154
  Improving Information Technology Systems Management                                                          154
  Preparing for Artificial Intelligence Challenges                                                             155
  Deploying and Monitoring New Third-Party Systems                                                             156
  Cybersecurity and Modernization                                                                              157
  MAKE A DIFFERENCE                                                                                           159



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                                               NOTICE:

  Pursuant to the James M. Inhofe National Defense Authorization Act for Fiscal Year 2023, Public Law
  117-263, Section 5274, any nongovernmental organizations and business entities identified in this
  report have the opportunity to submit a written response for the purpose of clarifying or providing
  additional context as it relates to any specific reference contained herein. Comments must be sub-
  mitted to AIGA@sba.gov within 30 days of the final report issuance date. We request that any com-
  ments be no longer than two pages, Section 508 compliant, and free from any proprietary or other-
  wise sensitive information. The comments may be appended to this report and posted on our public
  website.




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                                     Message From the
                                     Deputy Inspector General
                                     Each year, in accordance with the Reports Consolidation Act of 2000, the
                                     U.S. Small Business Administration (SBA) Office of Inspector General (OIG)
                                     provides a vital assessment of the agency’s top management and perfor-
                                     mance challenges. It is our statutory responsibility to detect and deter fraud,
                                     waste, abuse, and mismanagement in agency programs and services.

                             While the immediate economic crisis of the Coronavirus 2019 pandemic
                             is behind us, the vulnerabilities it exposed are not. These persistent chal-
                             lenges — including improper payments, ensuring program eligibility, and
                             strengthening internal controls — are not relics of the past. They are sys-
                             temic issues that continue to challenge SBA’s flagship capital, contracting,
                             counseling, and disaster assistance programs. Our work remains focused
                             on how these risks persist and how we can best support the agency in
  mitigating them for the future.

  OIG has conducted a significant body of work to inform this assessment. Our audits have explored
  critical areas, such as the effective use of technology and the alignment of technology with the com-
  prehensive review of eligibility criteria, which are essential safeguards against fraud and abuse. We
  are actively engaged with our strategic partners to further use the U.S. Department of the Treasury’s
  Do Not Pay system and other measures to identify and eliminate improper payments. As SBA pursues
  new priorities, such as an increased focus on manufacturing loans, we are committed to providing
  independent and objective oversight of these and other critical SBA programs to promote effective
  and efficient implementation.

  We recognize that SBA has undergone significant changes in its operations, including organizational
  restructuring and workforce reductions. Our continuing oversight will consider the effects of these
  changes on program operations within our prioritized work. Our partnership with SBA is vital to our
  shared goal of protecting the integrity of the agency’s programs. We acknowledge SBA’s continued
  commitment to being responsive to our recommended corrective actions.

  The nation can depend on OIG to continue to leverage our strategic partnerships and risk-based
  approaches to identify and address the most serious challenges facing SBA. Our ultimate goal is to
  improve the integrity, accountability, and performance of the agency’s programs, ensuring they oper-
  ate as effectively as possible for the American people and are free from fraud, waste, and abuse.




  Sheldon Shoemaker
  Deputy Inspector General




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                                                                                              Other Information (Unaudited)



  Introduction
  The Top Management and Performance Challenges Facing the Small Business Administration (SBA)
  in Fiscal Year (FY) 2026 is an important tool to help the agency prioritize its work to improve program
  performance and enhance operations. OIG remains committed to protecting the interests of Ameri-
  can taxpayers by promoting positive change within SBA and across government, ensuring taxpayer
  dollars are spent efficiently according to intent.

  Identification of an issue as a top challenge does not necessarily denote significant deficiencies or
  lack of attention on SBA’s part. Many of the challenges are longstanding, inherently difficult, and will
  likely continue to be challenges in the coming years. Addressing the challenges will require consis-
  tent attention from agency management and ongoing engagement with Congress, the public, and
  other stakeholders. We continue to collaborate with SBA program officials in identifying and mitigat-
  ing the top challenges and associated issues facing the agency.

  TABLE 1: TOP MANAGEMENT AND PERFORMANCE CHALLENGES FACING SBA IN
  FISCAL YEAR 2026
     Challenge                              Issues

                                            Managing Fraud Risk
     Challenge 1
                                            Improving Verification of Eligibility
     Protecting the Integrity of SBA
                                            Mitigating Improper Payments
     Programs
                                            Seizure and Return of Funds

     Challenge 2                            Servicing Disaster Loans
     Managing SBA’s Loan Portfolio          Planning and Modeling for Future Disaster Responses
     and Participating Lenders              Overseeing Lenders


     Challenge 3                            Measuring Program Performance
     Measuring Performance and              Monitoring Program Performance Results
     Monitoring SBA Programs                Ensuring Funds Are Used as Intended


     Challenge 4                            Improving Internal Controls Through Financial Statements
     Financial Reporting and                  Audit Remediation
     Managing Data                          Authorized Data Sharing

                                            Improving Information Technology Systems Management
     Challenge 5
                                            Preparing for Artificial Intelligence Challenges
     Managing Risks in Information
                                            Deploying and Monitoring New Third-Party Systems
     Technology Systems
                                            Cybersecurity and Modernization




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                                                                                              Other Information (Unaudited)



                                     Challenge 1: Protecting the
                                     Integrity of SBA Programs

  The SBA provides loan guaranties, direct disaster assistance loans, government contracting certifica-
  tions, and business development programs to qualifying small business owners, entrepreneurs, and
  those recovering from a declared disaster. SBA’s challenge is to fulfill its mission of quickly deliver-
  ing services and capital while also protecting the integrity of its programs. A strong internal control
  environment will help mitigate this challenge. Agency leaders have implemented new verification
  measures to ensure only eligible Americans benefit from SBA programs.A We will continue to provide
  oversight as the agency moves forward with fraud protection efforts.

  MANAGING FRAUD RISK
  SBA’s four pandemic relief programs delivered 22.1 million loans and grants to help eligible small
  business owners and entrepreneurs. SBA used limited front-end fraud detection internal controls
  when it initially distributed the $1.2 trillion.1 The agency was following legislative requirements in-
  tended to expedite aid to small business owners adversely affected by the pandemic.

  The challenge of managing fraud risk continues as SBA conducts post-payment automated and
  manual reviews of Paycheck Protection Program (PPP) loans. Post-payment reviews are when loans
  are examined for eligibility after the funds have already been paid to the borrower and forgiven.
  PPP borrowers can continue to apply for forgiveness for up to 5 years from the issuance of the loan,
  so through 2026. The statutes of limitations for fraud in the PPP and Coronavirus 2019 (COVID-19)
  Economic Injury Disaster Loan (EIDL) program were extended from 5 years to 10. In most cases, the
  U.S. government will have until 2032 to prosecute wrongdoers and return misused and fraudulently
  obtained funds to taxpayers.

  In a recent management advisory, we reported how SBA presumed that post-payment reviews of
  PPP loans would offset the risks of eliminating key up-front internal controls.2 SBA started flagging
  these loans for review in July 2021; however, as of May 2024, SBA had not completed reviewing
  37,938 loans totaling about $4.6 billion. According to the agency, these reviews are ongoing and will
  continue as resources allow. SBA is drafting a recovery plan for any loans deemed ineligible. For
  loans suspected of fraud, SBA did provide information to lenders on how to refer PPP loans, but the
  agency did not always keep record and review the referrals.

  The federal government does have a front-end fraud detection system in place. The U.S. Department
  of the Treasury’s Do Not Pay system is available to help verify applicant eligibility for loans or grants
  before they are issued. The Do Not Pay system is a series of databases designed to prevent and
  detect improper payments to those not eligible for government funds because of past fraudulent ac-
  tivity or other high-risk factors. SBA eventually started using the Do Not Pay system for its pandemic
  assistance programs. The agency is in the process of adding additional front-end verification checks

  A SBA, News Release 25-42, “SBA Highlights Range of New Measures to Stop Fraud” (April 10, 2025).




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                                                                                          Other Information (Unaudited)


                                                 that include Do Not Pay for disaster assistance, 7(a),
                                                 and 504 program loans.

                                                 We also found SBA performed limited oversight of
                                                 non-bank lenders and lender service providers even
                                                 though the agency had processes in place. After the
                                                 non-bank lenders and service providers were ap-
                                                 proved to become PPP lenders, SBA could have bet-
                                                 ter assessed the risk of allowing them to continue
                                                 to operate in the program. We found that non-bank
                                                 lenders made $14.2 billion in suspected fraudulent
                                                 loans at a rate more than five times higher than
          Example of a Massive Scheme to
                                                 loans made by traditional bank lenders. We also
           Defraud SBA Preferred Lenders
                                                 found the rate of suspected fraudulent loans made
         Fourteen defendants were arrested       by lenders using service providers was more than
        in a global criminal network charged     three times the rate of loans processed by lenders
            with conspiracy to defraud the       that did not use a service provider. For more on this
          government in obtaining over $25       topic see our Overseeing Lenders section.
         million in taxpayer-funded federally
                                                 In 2023, SBA adopted several new changes to its
       guaranteed small business loans and
                                                 flagship 7(a) loan program that dramatically re-
       pandemic relief funds over a period of
                                                 duced underwriting standards. Ultimately, these
                        7 years.
                                                 changes increased potential risk. Many of these
       One ringleader allegedly defrauded        changes were reversed in 2025; In 2023, SBA ad-
          numerous banks and the SBA             opted several new changes to its flagship 7(a) loan
      Preferred Lender Program, a program        program that dramatically reduced underwriting
      designed to help small businesses that     standards. Ultimately, these changes increased
      otherwise might not obtain financing.      potential risk. Many of these changes were reversed
                                                 in 2025; however, the loans made during that time
              He allegedly directed sham         remain susceptible to increased risk and financial
              corporations to open bank          loss.B
           accounts, make false statements,
         and concoct documents to support        Our investigative work has revealed a pattern of
         loan applications. He also allegedly    fraud by loan packagers and other fee-based agents
          purchased phony tax returns that       in the 7(a) loan guaranty program. We found SBA’s
         falsely reported millions in revenue.   loan programs are susceptible to borrower fraud
                                                 from false statements and documentation, mis-
                U.S. Attorney’s Office           representation of equity injections, and misuse of
             Central District of California      proceeds. These patterns of fraud continue to pose
                                                 a risk to taxpayer resources due, in part, to SBA
                                                 allowing applicants to attest to their own eligibility
                                                 (see Improving Verification of Eligibility).


  B SBA, News Release 25-41,“SBA Initiates Actions to Reverse Biden-Era Mismanagement of Core 7(a)

     Lending Program” (March 27, 2025).


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  This past year, the agency has expanded the chief financial officer’s role to include ensuring agency-
  wide risk factors are monitored and mitigated. An effective risk management program is sustained by
  implementing corrective actions and strengthening internal controls, ultimately reducing fraud and
  enhancing program integrity for current and future programs.

  IMPROVING VERIFICATION OF ELIGIBILITY
  SBA should obtain evidence to verify an applicant’s compliance with program requirements before
  issuing loans, grants, or conferring certifications. The agency should be able to ensure only eligible
  applicants receive program benefits. One of the biggest challenges in this area is self-certification.
  Self-certification is when a person is allowed to make an official declaration that their business com-
  plies with standards set for that program without independent evidence. Requiring participants to
  provide supporting documentation could mitigate the risks associated with self-certification.

  We found that SBA allowed self-certification in the Small Business Innovation Research and Small
  Business Technology Transfer programs. Business owners were asked to submit and verify reports,
  sales, and investments documentation, but SBA then did not always review the material.3

  SBA also allowed applicants to the Restaurant Revitalization Fund (RRF) and Shuttered Venue Opera-
  tors Grant (SVOG) pandemic relief grant programs to self-certify their eligibility.4 Applicants attested
  that they qualified by both industry and operational status during the eligibility period. We found this
  self-certification made the programs vulnerable to fraud or misuse. SBA has not made progress in
  resolving multiple audit recommendations for SBA to review billions in grant awards. Progress had
  been delayed as the agency contemplated recovery strategies. SBA plans to recover funds for any im-
  proper payments made to RRF recipients starting in FY 2026. However, it remains that agency manag-
  ers will only review 10,050 awards, despite OIG identifying over 61,000 awards that lacked sufficient
  support to determine whether the payment was made to an eligible entity. This means the agency
  could miss the opportunity to recoup over $9.5 billion in potentially improper RRF payments.

  Another area of concern is the verification of eligibility for SBA contracting certifications. The U.S.
  government is the largest single purchaser of goods and services in the world, awarding over $760
  billion in prime contracts annually. Congress established SBA contracting certification programs to
  ensure that a fair proportion of federal awards and subcontracts are awarded to small businesses.
  Congress intended for these programs to assist small businesses with overcoming the complexities
  of the federal contracting system. The programs were intended to help build stronger businesses,
  expanding competition in the marketplace and strengthening the overall U.S. economy.

  SBA works to maximize opportunities for small businesses in government contracting, but because
  it relies on self-certification for a key eligibility requirement, fraudsters can take advantage of the
  programs.

  SBA has seen unscrupulous business owners misrepresent themselves to compete for a contract set
  aside for a disadvantaged small business, capitalizing on the smaller pool of applicants and taking
  away the opportunity from an eligible and deserving small business. Fraud in these contracting certi-
  fication programs contradicts the intent of the congressional mandate to support small business.




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  OIG investigators currently have 27 cases involv-
  ing allegations of firms not meeting contracting
  program requirements, including in the 8(a)
  Business Development, Women-Owned Small
  Business, Service-Disabled Veteran-Owned
  Small Business, and Historically Underutilized
  Business Zone (HUBZone) programs.

  In our reviews of the HUBZone and Women-
  Owned Small Business programs, we recom-
  mended SBA check each business seeking these
  certifications to ensure they can be categorized                Example of Contracting
  as “small.”5 SBA decided instead to continue                      Certification Fraud
  to rely on small business owners attesting that
                                                          A Wisconsin woman who was the owner
  they meet these requirements. The agency has
                                                             of a Milwaukee HUBZone-certified
  maintained its position that self-certification is
                                                          construction company pled guilty to one
  the most efficient method, but agreed to imple-
                                                            count of false statements. She falsely
  ment procedures to monitor contract volume
                                                          certified her construction company met
  and provide additional training to mitigate the
                                                            HUBZone eligibility requirements and
  risk of HUBZone firms outgrowing their size.
                                                         complied with rules and procedures. She
  Relying on self-certification without any verifica-   also falsely certified that she had no affiliate
  tion perpetuates a system in which ineligible           business. She solicited 15 HUBZone set-
  business owners can obtain benefits meant              aside contracts on behalf of her company
  for disadvantaged businesses, depriving these            and was awarded 7 HUBZone set-aside
  business owners of the opportunities that                            contracts worth
  should rightfully be theirs under the statute. Un-
                                                           $4.7 million. She did not comply with
  scrupulous business owners can make unsup-
                                                           the subcontracting rules requiring her
  ported claims to attest they are eligible for these
                                                         construction company to perform at least
  certification programs in SAM.gov or SBA’s Small
                                                        15 percent of the cost of HUBZone contract
  Business Search Database. Federal contracting
                                                         performance. She did not disclose to SBA
  officers check these databases when awarding a
                                                          that employees of another construction
  set-aside contract; however, the veracity of the
                                                            company exercised control over the
  information is not verified by any federal entity.
                                                        management and decision-making process
  Given these vulnerabilities across SBA’s loan,                      of her business.
  grant, and certification programs, it is vital the
                                                             We investigated this case with the
  agency implement robust review procedures
                                                            assistance of the U.S. Department of
  when conducting eligibility reviews. For certifi-
                                                         Transportation OIG, FBI, General Services
  cation programs, these reviews could include
                                                             Administration OIG, Army Criminal
  checking for indicators that a business still
                                                         Investigation Division, and Department of
  qualifies according to size standards. Such miti-
                                                                        Defense OIG.
  gating steps can protect program integrity and
  support SBA’s recent focus to comprehensively                   DOT OIG Investigations
  review 8(a) Business Development program



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  participants and federal contracting officers who awarded contracts to these businesses over the last
  15 years.C

  MITIGATING IMPROPER PAYMENTS
  An improper payment is one that should not have been made or was made in an incorrect amount,
  including overpayment or underpayment, under a statutory, contractual, administrative, or other
  legally applicable requirement.D

  Agencies are required to review and assess programs to identify those susceptible to significant
  improper payments and report estimates, corrective action plans, and reduction targets to Congress.
  However, SBA did not always have acceptable practices and processes to calculate accurate esti-
  mates of improper payment rates for some of its programs during the last fiscal year, raising concerns
  about whether there were problems and the extent of them.6

  Prior and ongoing OIG audit work
  has identified 7(a) and PPP loans
  given to borrowers who were ineligi-
  ble, resulting in improper payments.
  OIG’s independent public account-
  ing firm found SBA did not publish
  improper and unknown payment
  estimates for the SVOG program or
  for multiple programs under the
  debt relief program, according to
  our report on SBA’s FY 2024 com-
  pliance with the Payment Integrity
  Information Act.

  In FY 2024, SBA largely employed
  adequate and appropriate sampling
  and estimation methodology plans
  for each of its seven programs that
  reported an improper payment
  rate, a notable improvement from
  FY 2023. However, the independent
  public accountant noted SBA placed
  undue reliance on its statisticians ex-
  ecuting the plans without the appro-
  priate level of oversight and quality
  control. Further, SBA had data

  C SBA, News Release 25-56, “Administrator Loeffler Orders Full-Scale Audit of 8(a) Contracting

     Program” (June 27, 2025).
  D Office of Management and Budget, M-21-19, “Transmittal of Appendix C to OMB Circular A-123,

     Requirements for Payment Integrity Improvement” (March 5, 2021).


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  quality issues that affected the improper payment rates for multiple programs due to an inadequate
  review process.

  The independent public accountant also noted SBA published ineffective corrective action plans for
  the PPP loan forgiveness and the PPP loan guaranty purchase programs. In addition, they found SBA
  did not accurately disclose the improper payment reduction targets in the annual financial report for
  six programs.

  Payment integrity actions, such as accurately measuring and reporting an agency’s improper pay-
  ment rate, will help to reduce fraud, waste, and abuse in government programs. These actions en-
  hance program missions, efforts to advance equity, efficiency, and customer experience.

  Over the past several years, SBA has initiated several corrective actions to enhance and develop addi-
  tional controls to address loan reviews, loan forgiveness, and fraud, including establishing guidelines
  for loan and forgiveness reviews. Although many of SBA’s efforts to mitigate improper payments are
  for pandemic assistance programs, learning from past mistakes will help the agency mitigate improp-
  er payments in its traditional programs moving forward.


  SBA’s implementation of a robust framework and ensuring its effectiveness will help mitigate this
  challenge. SBA has also adopted several new verification measures within its loan application pro-
  cess that will strengthen protections against fraud to ensure its programs only benefit eligible Ameri-
  cans, including citizenship verification, date of birth verification, and automatic fraud alerts.E

  SEIZURE AND RETURN OF FUNDS
  SBA, SBA OIG, and our external law enforcement partners are continuing to work together to seize or
  return pandemic-related program funds that remain frozen at financial institutions. SBA is also work-
  ing to claw back funds the agency has determined to be improper payments including loans flagged
  as potentially fraudulent. Recovery can be time consuming because it can involve coordination with
  other government entities and law enforcement agencies. This is a challenge given the volume of
  loans in SBA’s portfolio and the applicable statutory timeframes. SBA is working collaboratively with
  the Department of Justice, Treasury, and OIG officials to mitigate this challenge.

  In the FY 2024 financial statements audit, OIG’s independent public accountant identified significant
  issues in the agency’s accounting for the PPP, COVID-19 EIDL, RRF, and SVOG programs.7 Because
  these programs are either in the servicing or post-payment review phases, SBA needs to improve
  the process to recover funds or identify funds that need to be recovered. Further, the independent
  accountant found SBA managers did not adequately design and implement controls or develop ac-
  counting policies to account for the recovery of funds related to these programs (see Challenge 4 for
  more discussion on this issue).

  Our audits of SBA’s oversight of RRF and SVOG recipients also found management did not establish
  a process to recover funds from these programs.8 Subsequently, SVOG program officials sent letters
  requesting a return of funds to recipients who were found to be ineligible for the award or who im-
  properly used award funds.9 During FY 2025, SBA drafted a policy for recovering RRF funds and plans
  to implement a process in FY 2026.



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  SBA’s challenge is to enforce its current guidance for returning loan funds and standardize proce-
  dures on clawing back funds. Recently, SBA established a process to recover SVOG awards that were
  either sent to an ineligible recipient or used for improper expenses. SBA has also recently drafted a
  plan to account for the recovery of improperly paid PPP and COVID-19 EIDLs. For RRF awards, SBA
  needs to finalize a process to recover funds. The agency is still working through finalizing policies
  for clawing back PPP loans that were found to be ineligible after forgiveness. We will monitor SBA’s
  progress and actions to close this recommendation. Regarding seized and frozen pandemic-related
  program funds, SBA developed a procedural notice to provide guidance to borrowers, lenders, and
  other financial intermediaries on how to return the PPP loan funds to SBA. OIG will continue to evalu-
  ate the effectiveness of the processes.




  E SBA, News Release 25-42, “SBA Highlights Range of New Measures to Stop Fraud” (April 10, 2025).




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  OIG HIGHLIGHTED WORK

  1 COVID-19 Pandemic EIDL and PPP Loan Fraud Landscape (Report 23-09)
  2 SBA’s Actions to Address Forgiven PPP Loans Subsequently Flagged as Potentially Ineligible

    (Report 25-12)
  3 SBA’s Implementation of the SBIR and STTR Extension Act of 2022 (Report 24-14)
  4 SBA’s Restaurant Revitalization Fund Program Award Practices (Report 24-09); SBA’s Oversight of

    Shuttered Venue Operators Grant Recipients (Report 25-21)
  5 SBA’s Implementation of the Women-Owned Small Business Certification Program (Report 22-20);

    SBA’s Oversight of HUBZone Program Participants’ Continuing Eligibility (Report 24-23)
  6 Independent Auditors’ Report on SBA’s FY 2024 Compliance with the Payment Integrity Information

    Act of 2019 (Report 25-15)
  7 Independent Auditors’ Report on SBA’s FY 2024 Financial Statements (Report 25-05)
  8 SBA’s Restaurant Revitalization Fund Program Award Practices (Report 24-09); SBA’s Oversight of

    Shuttered Venue Operators Grant Recipients (Report 25-21)
  9 Improvements Needed in SBA’s Shuttered Venue Operators Grant Post-Award Review Process

    (Report 24-21)




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                                     Challenge 2: Managing SBA’s Loan
                                     Portfolio and Participating Lenders

  SBA provides entrepreneurs looking to start, grow, or expand
  their small businesses access to financial assistance through
  several business loan programs. The 7(a) loan program is
  SBA’s principal vehicle for providing small business owners
  and entrepreneurs with access to credit they cannot obtain
  elsewhere. This program relies on numerous outside parties
  (such as loan agents and lenders) to originate loans. By
  statute, the 7(a) loan guaranty offered through private lending
  institutions is required to operate at “zero-subsidy,” or zero
  cost to taxpayers, and is funded through the collection
  of lender fees. SBA has recently restored lender fees and
  increased underwriting standards for loan guaranties, which were eliminated or lowered in 2023.A
  To protect taxpayer dollars, SBA must maintain adequate oversight of financial institutions
  participating in its guaranteed loan programs.

  SBA also provides long-term, low-interest direct disaster assistance loans to businesses of all sizes,
  private nonprofits, homeowners, and renters following a declared disaster. The agency is tasked
  with handling the long-term loan servicing of the COVID-19 EIDL program, which is a loan portfolio of
  about 3.8 million loans — over 14 times what the agency was managing before the pandemic. SBA’s
  challenge is to effectively service this large volume of disaster loans and recover delinquent funds.

  SERVICING DISASTER LOANS
  Prior to the pandemic, SBA typically serviced about 263,000 disaster loans totaling approximately
  $9.4 billion. Five years after the pandemic, SBA has the challenge of servicing approximately 3.8
  million outstanding disaster loans totaling approximately $336.4 billion — a fourteenfold increase in
  the amount of loans the agency was managing previously (see Figure 1). Note that the stated size of
  the portfolio includes about 1.1 million charged-off loans that normally would have been transferred
  to Treasury for cross servicing. SBA has been temporarily exempted from that requirement until
  March 31, 2026. Upon transfer, the servicing portfolio will significantly decrease.

  SBA typically services a disaster loan until it is paid in full or, upon default, to 120 days delinquent.
  Treasury and the agency have agreed that SBA will service even defaulted loans and attempt
  recovery on these loans for up to 2 years, or until the agency’s recovery efforts are exhausted.
  COVID-19 EIDL servicing is significantly different than traditional loan servicing because it includes a
  variety of complex action requests that are not common to private sector business loans. This further
  stresses SBA’s ability to fully and completely service current loans and perform full-spectrum

  A SBA, News Release 25-41, “SBA Initiates Actions to Reverse Biden-Era Mismanagement of Core 7(a)

     Lending Program” (March 27, 2025).


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  Figure 1: The Increased Burden of COVID-19 EIDL Servicing on SBA




  Source: OIG generated based on SBA data

  collection efforts on past-due and defaulted loans.1 SBA’s challenge is to be responsive to recipients
  of these loans and perform its due diligence to mitigate loss to the taxpayer.

  In our May 2025 inspection report, we concluded that SBA would be able to service its COVID-19
  loan portfolio with a staff of 1,492 at its Fort Worth, Texas, processing center.2 As of June 2025, SBA
  reduced its staff at the center to about 819 employees. Since these staff reductions occurred after
  our review, OIG has not assessed any potential impact on the agency’s servicing of the $336.4 billion
  COVID-19 EIDL disaster loan portfolio.

  PLANNING AND MODELING FOR FUTURE DISASTER RESPONSES
  To avoid funding lapses, SBA must improve its processes to forecast and request annual
  appropriations for future disaster responses. On October 15, 2024, the agency announced
  funds in its disaster assistance loans program account had been exhausted. This caused a delay
  in disbursements of loans between October 15 and December 21, 2024, when SBA received
  supplemental funding. This lapse in funding occurred, in part, because the agency had not adjusted
  its forecasted lending level or annual budget request for disaster assistance since 2009, even though
  the number and cost of billion-dollar disasters has generally increased over time (see red trendline
  on Figure 2).3 Our report 25-24 shows the correlation between a large number of costly disasters and
  a larger number of disbursed loans and SBA loan amounts. SBA’s challenge is to ensure historical



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  factors, such as changes in the subsidy rate, frequency of major disasters, and total dollar amount of
  loan approvals from prior years, are taken into account when developing the annual budget request
  for the disaster loan program.

  Figure 2: Total Dollar Amount of Approved Disaster Loans




  Source: National Centers for Environmental Information billion-dollar disaster database

  When requesting future funding, we found that SBA’s monthly reports to Congress did not include
  all the required components of 15 U.S. Code § 636k(a) and that the informal messages the agency
  initiated with Congress were insufficient to communicate the pending funding lapse.3 SBA’s
  challenge is to 1) ensure its monthly reports comply with the statute and can be clearly interpreted
  and 2) provide formal notification to Congress and the Office of Management and Budget (OMB) that
  clearly states whether sufficient funds are available or if there is a need for supplemental funds as
  soon as the agency anticipates a funding shortfall.

  OVERSEEING LENDERS
  SBA’s Office of Credit Risk Management manages program credit risk on financial assistance
  portfolios of guaranteed loans that totaled about $163 billion as of June 2025. The office monitors
  lender performance and enforces lending program requirements.

  In 2023 and 2024, SBA made significant policy changes to its flagship 7(a) loan program to help
  expand access to capital for disadvantaged entrepreneurs. The agency lowered underwriting
  standards and granted mission-driven financial institutions access to the 7(a) loan program as
  Community Advantage Small Business Lending Companies. In 2025, SBA reversed many of these




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  changes.B The agency has recently issued
  a moratorium on the expansion of the
  program and will require existing lenders to
  meet prudent financial stability standards
  as a condition of further participation. SBA’s
  challenge is to serve entrepreneurs while
  also mitigating increased risk to its 7(a) loan
  program. Many non-bank lenders are not
  regulated by other federal entities, which
  means they are primarily regulated and                      Example of Lender Service
  examined by SBA. The agency considered these                    Provider Fraud
  lenders to be higher risk than those with federal
                                                         We helped prosecute a national criminal
  regulators, so they required more oversight by
                                                           ring involving 1,300 PPP applications
  SBA’s Office of Credit Risk Management.4
                                                          associated with $600 million in fraud,
  OIG has conducted prior audit work related            leading to the convictions of the founders
  to third-party service providers in the 7(a)               of a lender service provider, which
  loan program. In FY 2025, we assessed the risk      facilitated over $6 billion in PPP loans, itself
  associated with non-bank lenders in the PPP,        benefitting from over $300 million in lender
  including financial technology companies and         fees. To date, this is our largest prosecuted
  service providers.5 We found opportunities                pandemic assistance fraud scheme.
  for SBA to enhance its oversight of non-bank
                                                          The investigation revealed two of the
  lenders to promote program integrity and
                                                        ringleaders co-founded a fintech in April
  reduce financial loss. Specifically, non-bank
                                                         2020 purportedly to assist applicants in
  PPP lenders made $14.2 billion in suspected
                                                          obtaining PPP loans. To obtain larger
  fraudulent loans at a rate more than five times
                                                      loans for certain applicants, they and other
  higher than loans made by traditional bank
                                                         co-conspirators fabricated documents,
  lenders. Over $6.1 billion of the $14.2 billion
                                                            including tax documentation. They
  in suspected fraudulent non-bank PPP loans,
                                                         charged borrowers kickbacks based on
  or nearly 43 percent, were made by lenders
                                                          a percentage of the funds received. To
  categorized as fintechs and other state-
                                                       obtain a greater volume of kickbacks from
  regulated finance companies. Additionally,
                                                          borrowers and a percentage of lender
  loans involving service providers had a
                                                        fees from SBA, they submitted PPP loan
  suspected fraud rate more than three times
                                                         applications they knew contained false
  higher than loans made without a service
                                                                        information.
  provider. In addition, we have investigative
  cases that reflect some of the effects non-bank               U.S. Attorney’s Office
  lenders have had on the PPP.                                Northern District of Texas,
                                                                   June 23, 2025
  SBA has taken steps to mitigate this challenge
  and significantly improved its tracking and                       August 11, 2025
  monitoring of third-party providers in the
  traditional loan programs. We will continue

  B SBA, News Release 25-51, “SBA Overhauls Reckless Biden-Era Lending Program” (May 19, 2025).




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  to monitor compliance with SBA policies and procedures as well as corrective actions to address
  noncompliance. It is vital that the agency continues to:
  •     Enhance its oversight of program lenders;

  •     Enhance the oversight of third-party service providers, including loan agents who lenders place
        significant reliance on; and

  •     Address emerging issues in a timely manner to reduce risks.

  Ensuring Retention of Loan and Award Records

  SBA guarantees 50 percent or more of a business loan made by a participating lender to the small
  business borrower. Lenders maintain the loan files and service the loan until either the loan is paid in
  full or SBA purchases the guaranty and charges off any uncollectible balance.6 This means that most
  loan documents and data reside only with the participating lender, which could be problematic if
  that lender dissolves or ceases to service the loan.

  If future programs were designed to capture and maintain applicant data, and if the data was shared
  with SBA, it would not be as difficult for the agency to conduct oversight of loans from lenders who
  ceased operating. In addition, if SBA were to acquire and maintain lender data, investigators would
  have access to the documentation needed to validate evidence of fraud. Retaining documentation
  and sufficient evidence to support loan decisions is consistent with federal standards for internal
  controls. These controls require managers to support their decisions and determinations with
  supporting documentation, which includes the rationale of how loan decisions were made. For this
  reason, it is important that all loan records are properly managed, maintained, and available.7

  This was most evident in the PPP because of the massive number of loans, the extent of the fraud,
  and the forgiveness process on the back end. In the PPP, SBA only required that lenders enter general
  applicant information, such as name, address, email, and telephone number, into the agency’s PPP
  systems. Applicants were not asked to provide their date of birth on the PPP application, which
  we found to be a critical element for Social Security number verification. In addition, SBA did not
  require lenders to submit borrower bank account details associated with the disbursement, Internet
  Protocol addresses, or web log data associated with the electronic signature on the applications.
  If a lender were to go out of business, SBA could not capitalize on the information it obtained in its
  PPP systems by using data analytics technology, such as artificial intelligence and machine learning,
  which help identify noncompliance with program requirements and likely fraud.

  Congress and the Administration took swift action to extend the statutes of limitations for
  prosecution of PPP and COVID-19 EIDLs from 5 to 10 years, but it will be difficult to prosecute bad
  actors if loan documents and data are not available. To correspond to the 10-year PPP fraud statute
  of limitations, SBA extended the records retention requirement for all PPP lenders to 10 years from
  the date of final disposition of each PPP loan.C SBA’s challenge is to continuously monitor and
  communicate with participating lenders to safeguard loan information and to share documents

  C 89 F.R. 68090 Business Loan Program Temporary Changes; PPP-Extension of Lender Records

      Retention Requirements (August 2024).


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  related to lending decisions, which is imperative in cases in which the lender dissolves or ceases to
  service the loan.

  The statute of limitations for the Restaurant Revitalization Fund and Shuttered Venue Operators Grant
  program is 5 years from application or the reporting date. SBA only requires Restaurant Revitalization
  Fund recipients to retain their award records for 3 years. If program officials do not conduct reviews
  in a timely manner, or extend the record retention period, SBA could miss the opportunity to
  prosecute wrongdoers and recover funds that were incorrectly or fraudulently obtained.


  OIG HIGHLIGHTED WORK

  1 Ending Active Collections on Delinquent COVID-19 Economic Injury Disaster Loans (Report 23-16)
  2 COVID-19 Economic Injury Disaster Loan Servicing Capability (Report 25-16)
  3 SBA’s Processes to Forecast and Request Appropriation Dollars for its Disaster Loans Program

    Account (Report 25-24)
  4 Audit of SBA’s Oversight of High-Risk Lenders (Report 20-03)
  5 SBA’s Oversight of Non-Bank Lenders and Third-Party Service Providers Associated With PPP Loans

    (Report 25-04)
  6 SBA’s Guaranty Purchases for Paycheck Protection Program Loans (Report 22-25)
  7 SBA’s Eligibility and Forgiveness Review of PPP Loans Made to Borrowers with Treasury’s Do Not

    Pay Data Matches (Report 24-06)




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                                     Challenge 3: Measuring
                                     Performance and Monitoring SBA
                                     Programs
  SBA manages programs to help support American entrepreneurs access grant funds and business
  counseling. It aids existing and prospective small businesses through a variety of counseling
  and training services offered by partner organizations. Among these partners are Small Business
  Development Centers (SBDC), the SCORE mentoring network, Women’s Business Centers, and
  Veterans Business Outreach Centers. SBA’s challenge is to improve the measures it uses to assess
  the effects of its programs and improve grantee oversight, better serving entrepreneurs and ensuring
  that every dollar spent delivers results.

  MEASURING PROGRAM PERFORMANCE
  Federal guidance requires SBA managers establish meaningful performance goals and measure
  progress, which provides proof of success and helps improve future programs. With over 33 million
  small businesses supporting the economy, having clearly defined program goals and targets are
  essential to achieving program objectives.

  Our reviews of SBA’s counseling and contracting certification programs have consistently found
  opportunities for SBA to improve its measures used to assess program goal accomplishments. In a
  recent review of an SBDC, we found SBA established performance goals and measures to monitor
  progress toward the goals.1 However, improvements were needed to better align performance goals
  with the related funding and to track progress toward achieving those goals.

  MONITORING PROGRAM PERFORMANCE RESULTS
  Federal standards for internal controls require managers to use quality information to achieve their
  objectives. This requires that program officials ensure information is complete, accurate, accessible,
  and provided in a timely manner so that leaders can make informed decisions and evaluate
  performance. Without accurate and complete performance reporting and comprehensive reviews of
  performance reports, SBA grant programs may not achieve their intended results.

  The agency can improve tracking and monitoring performance goals by coordinating with resource
  partners. We found this lack of coordination in our recent inspection of one SBDC. We highlighted the
  need to demonstrate performance goals were met by associating the center’s financial data with the
  program activities conducted. If not properly associated, the SBDC spends additional money toward
  meeting goals already funded, thereby increasing the operational cost of fulfilling program goals and
  activities. We plan to take a broader look at these issues in an upcoming audit of SBA’s oversight of
  the SBDC program.

  We also found in SBA’s oversight of the Small Business Innovation Research (SBIR) and Small
  Business Technology Transfer (STTR) programs that there was limited assurance that small
  businesses met minimum performance standards.2 These programs help entrepreneurs explore their



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  technological potential and provide an incentive to profit from commercialization. Small businesses
  must meet minimum performance standards to compete for SBIR and STTR awards. Changes to the
  Small Business Act are needed to improve SBA’s ability to monitor small businesses’ compliance
  with performance standards, reducing risks because they may not have the ability to achieve
  program goals for commercialization as intended by the Act. SBA’s challenge is to monitor grantee
  performance in the estimated number of new businesses started, tax revenue generated, and entity
  operational status.

  ENSURING FUNDS ARE USED AS INTENDED
  We identified systemic issues with SBA’s oversight of grant recipients’ use of federal funds. These
  issues included not enforcing financial reporting requirements, not detecting grant recipient budget
  reallocations, using weak financial review procedures, and missing supporting documentation. SBA’s
  challenge is to improve its grant management processes and procedures to ensure funds are used
  for allocable, allowable, and reasonable expenditures.

  In our recent review of an SBDC, we found opportunities for the center to improve its financial
  compliance when accounting for federal expenses, matching funds, and program income. SBA
  program officials are making changes to how it monitors use of funds to hold SBDCs accountable
  and ensure objectives are met.

  Federal funds can greatly assist struggling small businesses during an economic crisis. For example,
  the Restaurant Revitalization Fund (RRF) and Shuttered Venue Operators Grant (SVOG) were intended
  to help businesses in the restaurant and venues industries struggling to stay in business during the
  pandemic.

  In an audit of SBA’s oversight of RRF recipients, we found program officials needed to obtain sufficient
  information to monitor the recipients to ensure funds were used as intended.3 RRF recipients were
  required to submit their final use of funds report to SBA by April 30, 2023. As of July 2025, 9.4 percent of
  all recipients, with awards totaling $1.5 billion, had not yet filed the required report.

  To oversee the RRF and SVOG programs, SBA selected samples of the award recipients to manually
  confirm eligibility, award calculation, and use of funds. We previously found the reviews for both
  programs were being conducted at a rate that would extend beyond the required timeframe for
  grantees to retain award records and the statute of limitations for prosecution of fraud or misuse.4
  SBA’s challenge is to prioritize the RRF and SVOG reviews to increase the opportunity to save taxpayer
  funds. Program managers stated they have increased the number of staff allocated to these reviews
  and are working to manage resources to complete the reviews within the timeframes.

  In addition, we found program officials did not review all awards made to potentially fraudulent
  or ineligible recipients, as the agency had originally planned to do.5 We also found SBA needed to
  implement procedures for recipients to return unused or improperly awarded funds to Treasury.
  SBA management recently implemented a process for the SVOG program and plans to implement a
  process to recover improper payments for the RRF program in FY 2026.

  SBA’s challenge is to effectively manage its resources to meet the demands of monitoring awardee
  compliance with award requirements. Improving awardee oversight will help the agency to



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  effectively measure and accurately report performance results and assess whether the federal
  assistance programs were effective and funds were used appropriately.

  In our recent audit of SBA’s oversight of SVOG recipients, we found SBA could improve its process to
  close out SVOG awards. The SVOG award close out process consisted of various activities to include
  determining if 1) recipients were eligible; 2) the award amount was correct, used in accordance with
  requirements, or recovered if applicable; and 3) the agency completed its review of submitted audit
  packages.

  As of August 2025, SVOG officials closed out 1,515 of the 2,590 awards, with 1,075 awards totaling
  more than $1.5 billion still open. SBA program officials paused the close-out process to focus on
  recovery efforts. While finalizing the process to recover funds is important, SBA should consider both
  the close out and record retention requirements. By not doing so, they could miss the opportunity to
  collect misused or unused taxpayer funds.


  OIG HIGHLIGHTED WORK

  1 New Jersey Small Business Development Center’s Compliance With Cooperative Agreement

     Requirements (Report 25-17)
  2 SBA’s Implementation of the SBIR and STTR Extension Act of 2022 (Report 24-14)
  3 SBA’s Oversight of Restaurant Revitalization Fund Recipients (Report 23-15)
  4 SBA’s Oversight of Shuttered Venue Operators Grant Recipients (Report 25-21); Improvements

     Needed in SBA’s Shuttered Venue Operators Grant Post-Award Review Process (Report 24-21)
  5 SBA’s Administrative Process to Address Potentially Fraudulent Restaurant Revitalization Fund Awards

     (Report 23-10)




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                                     Challenge 4: Financial Reporting
                                     and Managing Data

  SBA is tasked with managing the data of small business
  owners through multiple interfaces and platforms while
  meeting government mandates for privacy and security. The
  agency has made it a priority to improve SBA technology,
  cybersecurity, and response time to customers, affirming that
  efficient data systems are integral to customer service. A
  Agency leaders also plan to further integrate AI into agency
  data systems, which may generate new cybersecurity
  concerns requiring OIG oversight. By implementing best
  practices in data management, the agency will have
  a stronger foundation for identifying and preventing
  fraud schemes. Data reliability is also essential for SBA to manage taxpayer funds and accurately
  communicate its financial position to Congress, the President, and the American public. The agency
  has made satisfactorily completing a financial audit a priority, according to an SBA February 2025
  news release. By improving data sharing practices, SBA can leverage information from federal
  partners to make more informed decisions, ultimately benefiting all Americans.

  IMPROVING INTERNAL CONTROLS THROUGH FINANCIAL STATEMENTS AUDIT
  REMEDIATION
  Our 2024 financial statements audit found a continuing challenge related to SBA’s internal controls,
  which are integral for financial data reliability and accuracy.1 Over the last 5 years, SBA has struggled
  with addressing long-standing internal control deficiencies due to challenges the agency faced with
  administering its pandemic relief programs. Starting in FY 2020, the agency received its first of five
  disclaimers of opinion, which means the auditors were unable to obtain sufficient audit evidence to
  support balances, so SBA has not obtained a clean audit opinion in 5 years.

  Since its first disclaimer, SBA’s financial statements audits have been limited to the balance sheet,
  one of four principal financial statements. The remaining three statements — net cost, statement of
  changes in net position, and budgetary resources — have not been audited due to the unresolved
  issues affecting the balance sheet. This is important because the other statements contain
  information about agency spending and how much funding was used during the fiscal year.

  In each of these 5 years, the auditors have identified as many as seven material weaknesses, three
  significant deficiencies, and three issues of non-compliance with laws and regulations (see Figure 3).2
  A material weakness is a serious concern that an organization’s financial reporting controls are

  A SBA, News Release 25-32, “SBA Administrator Loeffler Issues Memo on Day One Priorities”

     (February 24, 2025).


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  not effective enough to detect major errors or fraud that could cause material misstatements in the
  financial statements. A significant deficiency is less severe but indicates control issues that could
  potentially lead to misstatements.

  Figure 3: SBA Audit Deficiencies From Pre-Pandemic Through Pandemic Recovery




  *Federal Managers’ Financial Integrity Act of 1982, Federal Financial Management Improvement Act of 1996, Debt
  Collection Improvement Act of 1996.

  Source: OIG analysis from SBA financial statements audit reports


  OMB guidance states that correcting internal control deficiencies is a fundamental part of
  management accountability and must be prioritized.B In this light, the agency developed a new and
  centralized Financial Statements Audit Remediation Strategy in January 2025 that set key targets to
  focus time and resources on, including:

  •     Enhancing governance for the audit process;

  •     Developing accounting policies for the pandemic programs, such as COVID-19 EIDLs, the PPP,
        Restaurant Revitalization Fund, Shuttered Venue Operators Grants; and

  •     Writing a position paper for the auditors, explaining that SBA has identified loans with potential
        eligibility concerns through its verification process.C



  B OMB, M-16-17, “OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk

      Management and Internal Control,” at 37 (July 15, 2016).
  C SBA, Office of Performance, Planning, and the Chief Financial Officer Financial Statement Audit

      Remediation Strategy (January 8, 2025).


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  Although these are positive steps, SBA has the challenge
  of remediating the seven material weaknesses and
  producing a clean audit opinion for all four financial
  statements. SBA should strive to improve program
  oversight provided to the taxpayer, Congress, and the
  President and accurately report how taxpayer money
  was used during the fiscal year.

  Beyond achieving a clean audit opinion, SBA must meet
  its statutory responsibility with the Federal Managers
  Financial Integrity Act of 1982, which requires annual
  assessments and certifications of internal controls to           Example of Multi-Agency Data
  the Congress and President.D Although the material                         Sharing
  weaknesses identified are largely related to pandemic
                                                                   Four Detroit residents pled guilty
  relief programs that have ended, SBA can learn lessons
                                                                      to conspiracy to commit wire
  from the crisis to better its internal control environment
                                                                  fraud for their roles in a $6 million
  moving forward.
                                                                     pandemic relief fraud scheme.
  From FY 2020 to FY 2024, SBA did not substantially               Between February 2020 and May
  comply with the Federal Managers Financial Integrity               2021, the co-conspirators stole
  Act of 1982. Building a more rigorous internal control           identity information and created
  environment will not only help SBA move toward                    fictitious businesses to then file
  compliance with the Act but will also help it to identify       fraudulent claims in various states
  potential errors or fraud. SBA’s challenge will be to          for PPP loans, EIDLs, and pandemic
  effectively design an internal controls assessment                unemployment assistance. The
  plan that meets requirements, while building a team            unemployment benefits were often
  with expertise and capacity to strengthen its internal            deposited onto debit cards that
  controls.                                                       were sent to addresses controlled
                                                                          by the co-conspirators.
  AUTHORIZED DATA SHARING
                                                                     This joint investigation was
  During the pandemic recovery, leaders in the offices of           successful thanks to SBA OIG,
  inspector general analytics community demonstrated              Department of Labor OIG, and FBI
  that government data sharing can lead to successful              data sharing and collaboration.
  criminal and administrative investigations into PPP,
  EIDL, and unemployment insurance program fraud. E                   Office of Inspector General
                                                                      U.S. Department of Labor
  A collaboration between SBA OIG and the U.S.
  Department of Labor OIG identified $1.3 billion in                 Eastern District of Michigan
  potentially fraudulent unemployment insurance and
  EIDL payments were paid to the same likely fraudsters in


  D Federal Managers Financial Integrity Act of 1982. Pub. L. No. 97-255 (August 1982).
  E Pandemic Response Accountability Committee, Blueprint for Enhanced Program Integrity, Chapter

     4: Whole-of-Government Approach, at 11-12 (April 2025).


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  both programs.3 We identified this issue through a data use agreement and a subsequent data sharing
  and matching project. Additionally, SBA OIG identified an additional $1.4 billion in EIDL disbursements
  from a larger dataset not previously identified by Labor OIG or SBA OIG as potentially fraudulent.

  Another example of effective data sharing between agencies would be if SBA pursues a legal
  framework to establish Social Security number verification data. The Pandemic Response
  Accountability Committee (PRAC) demonstrated how a memorandum of understanding with the
  Social Security Administration allowed its data scientists to verify Social Security numbers, names,
  and dates of birth from a random sampling of 662,000 identity records across the COVID-19 EIDL, PPP,
  and Labor’s pandemic unemployment insurance program.F Using those results, PRAC estimated that
  up to 1.4 million stolen or invalid Social Security numbers were used to obtain benefits from these
  programs. PRAC estimated that verifying Social Security information could have saved taxpayers up
  to $79 billion in potentially fraudulent pandemic relief payments.

  Given the volume of identity theft associated with SBA pandemic loan programs, Social Security
  number verification could have helped mitigate fraud. If statutory limitations prevent SBA from
  accessing this or other critical data assets, there are other opportunities for responsible data sharing
  that could strengthen fraud detection efforts.

  The agency could undertake collaborative efforts to uncover fraud, waste, and abuse by
  implementing Do Not Pay data in all its programs. The agency could put agreements and systems in
  place to mitigate fraud, rather than chasing fraudsters after the funds have been disbursed.

  PRAC continues to advocate for expanding agency access to information, such as tax data.G We agree
  that expanding access to data using collaborative information sharing agreements will help identify
  fraud indicators so that federal agencies can better manage resources and protect taxpayer funds. SBA
  management stated they are currently making progress to secure sufficient and complete data sharing
  agreements with other federal agencies and ensure expired agreements are reestablished. As with Do
  Not Pay data sharing agreements with Treasury, the agency is undertaking additional collaborative
  efforts to uncover fraud, waste, and abuse during the application process for disaster assistance. These
  agreements can better help federal agencies verify applicant information and detect fraud.


  OIG HIGHLIGHTED WORK

  1 Independent Auditors’ Report on SBA’s FY 2024 Financial Statements (Report 25-05)
  2 SBA’s Controls to Address Financial Statements Audit Disclaimers and Material Weaknesses

     (Report 25-25)
  3 COVID-19: Data Sharing Project Finds Billions Paid to Same Likely Fraudsters Under Both the

     Unemployment Insurance and Economic Injury Disaster Loan Programs (Report 25-06)

  F PRAC, Fraud Prevention Alert: Pre-Award Vetting Using Data Analytics Could Have Prevented Over $79

     Billion in Potentially Fraudulent Pandemic Relief Payments (June 2025).
  G PRAC, Blueprint for Enhanced Program Integrity, Chapter 4: Whole-of-Government Approach,

     at 11-12 (April 2025).


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                                     Challenge 5: Managing Risks in
                                     Information Technology Systems

  SBA continues to share our concerns                  Figure 4: Risk Management Best Practices
  about its information technology (IT) and            Strategy
  cybersecurity issues, citing these as top
  priorities in 2025.A A strong IT governance
  framework enables the agency to achieve
  mission goals and objectives while
  safeguarding taxpayer funds. A governance
  framework is an integrated strategy that
  identifies, measures, and controls risk in
  IT investments, fraud, and AI (see Figure
  4). These processes will help the agency
  better deliver SBA programs and services,
  particularly in times of crisis.
                                                       Source: OIG generated from National Institute
  IMPROVING INFORMATION                                of Standards and Technology data
  TECHNOLOGY SYSTEMS MANAGEMENT
  In March 2024, OIG determined SBA did not enforce IT management policies and procedures, and a
  new IT systems framework was not scheduled to be implemented until the second quarter of 2024.1
  The agency has had issues related to IT software investment governance, including:

  •     Lack of oversight from the governance board,

  •     Not identifying the intended purpose of software investments and their expected benefits,

  •     Lack of monitoring against performance measurement baselines.

  An IT system is essential to mission delivery and enhances organizational performance. IT system
  management is on the U.S. Government Accountability Office’s (GAO) high-risk list because IT
  purchases are often a large investment of taxpayer funds for mission critical functions.B The agency
  has made updates to its management processes, including updating its process for IT investment
  management to correspond with the requirements of the Clinger-Cohen Act, the Federal Acquisition
  Reform Act of 1995, OMB requirements, and OIG recommendations.




  A SBA, News Release 25-32, “SBA Administrator Loeffler Issues Memo on Day One Priorities”

      (February 24, 2025).
  B GAO, GAO-25-107743, High-Risk Series: Heightened Attention Could Save Billions More and

      Improve Government Efficiency and Effectiveness, at 153 (February 2025).


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  PREPARING FOR ARTIFICIAL INTELLIGENCE CHALLENGES
                                               A 2025 executive order on AI calls upon agencies to develop
                                               and submit to the President an action plan to achieve policy
                                               goals of sustaining and improving America’s AI use, promoting
                                               human advancement, economic competitiveness, and
                                               national security.C OMB also called upon agencies to develop
                                               and publicly release an AI strategy that includes all its current
                                               and possible future uses of machine-learning technology.
                                               OMB directed agencies to promote the use of AI while also
                                               considering security threats and risk, particularly taking care
                                               when the AI has a significant effect on decisions related to:

  •     Civil rights, liberties, or privacy;

  •     Critical government resources or services; and

  •     Access to education, housing, insurance, credit, employment, and other programs.D

  This is relevant for SBA because it could employ AI to decide on loan guaranties, award grants, or
  detect potentially fraudulent applications, while accessing private financial information and affecting
  applicants’ credit records.

  SBA faces several challenges in implementing AI according to the new OMB memo. First, IT leaders
  must consistently identify and classify any AI uses, particularly if they plan to leverage existing data
  and AI assets across the agency. SBA management stated they have formed a new AI working group
  and a board to guide and oversee agency integration of AI to improve business processes. As of
  November 2025, SBA had no AI use cases reported.

  OMB also mandated SBA to:

  •     Designate a Chief AI Officer to promote AI innovation and governance. (A new officer was
        assigned as of August 2025);
  •     Update internal policies on IT infrastructure, data, cybersecurity, and privacy. (SBA published a
        2-year Open Data Plan in June 2025 addressing open data security and privacy; however, more
        internal guidance is needed); and

  •     Develop a generative AI policy. (Its last posted policy expired early 2025).E




  C Executive Office of the President, Executive Order 14179, “Removing Barriers to American

      Leadership in Artificial Intelligence” (January 23, 2025).
  D OMB, M-25-21, “Accelerating Federal Use of AI Through Innovation, Governance, and Public Trust,”

      at 19 (April 3, 2025).
  E “Artificial Intelligence.” SBA Office of the Chief Information Officer. Internal SharePoint site.




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  The agency must consider the budgetary costs and constraints of keeping AI systems and tools
  updated and protected from bad actors. Major tech players report skyrocketing costs to generative AI,
  leading to the cancellation or postponement of AI initiatives because of cost concerns.F Cutting-edge
  tools can be costly to maintain, particularly with ever-evolving cyber threats. Some tech companies
  have recognized the need to address the cost and security concerns of AI use within government.G
  SBA’s risk management and need of transparency, in addition to the large amount of taxpayer
  resources at stake, is why this is a top management challenge for SBA in 2026.

  Both GAO and OIG have drawn attention to a past case of SBA not being fully transparent regarding
  its use of AI.H SBA had used a machine learning model, considered AI according to U.S. Code,I that
  it did not include in its AI inventory. An SBA loan reviewer contractor developed a random forest
  machine learning model, an ensemble algorithm using multiple decision trees, to determine if loans
  required further analysis before being approved. The model developed its internal rules for making
  loan assessments based on risk indicators created by a legal and business research platform, which
  are numerical measurements or scores to indicate risk level for businesses. The model used other
  factors deemed relevant by the contractor but not clearly explained to GAO or OIG. The model was
  trained on a dataset of 20,000 manually reviewed loans, of which 275 had been marked as requiring
  further analysis before approval. This model was then used by SBA to assess 129,000 loans.

  OIG plans to conduct audit oversight on the implementation of SBA’s AI plans and strategies in the
  future. We look forward to working with the agency to ensure AI objectives are met with minimum
  risk and optimum return on investment.

  DEPLOYING AND MONITORING NEW THIRD-PARTY SYSTEMS
  The agency relies on service providers for software and IT services. While these outside solutions
  are expedient, SBA’s challenge is to implement robust due diligence and continuous monitoring to
  ensure data integrity is maintained throughout the processing cycle. Shortfalls in these processes
  have contributed to SBA having material weaknesses and disclaimers of financial reporting reliability
  going back to FY 2020.

  Proper guidance on monitoring third-party systems can be found through System and Organization
  Controls 1 reviews. Our independent financial statements auditors identified material weaknesses
  related to insufficient technical support and inadequate system controls, possibly leading to
  operational inefficiencies and increased risk of errors. These reviews allow agencies to evaluate the
  effectiveness of their internal controls over financial reporting. In FY 2025, SBA revised its standard
  operating procedure to enhance oversight procedures of service providers.J

  F Brodsky, Sascha. “The Hidden Costs of AI: How Generative Models are Reshaping Corporate

      Budgets.” IBM Think. Accessed July 18, 2025. (October 14, 2024).
  G Wakeman, Nick. “OpenAI to Give Federal Agencies ChatGPT Access at $1 Per year.” NextGov/FCW.

      Accessed August 6, 2025. (August 6, 2025).
  H GAO, GAO-25-107267, COVID-19 Relief Improved Controls Needed for Referring Likely Fraud in SBA’s

      Pandemic Loan Programs (March 2025).
  I   15 U.S. Code §9401(3).


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  SBA’s development guidance requires that systems are designed with adequate controls to prevent
  unauthorized access and data breaches. As new systems are developed, the importance of robust
  technical support and continuous system monitoring is integral to data quality.

  CYBERSECURITY AND MODERNIZATION
  Our evaluations of SBA’s systems, policies, and procedures regarding the Federal Information
  Security Modernization Act (FISMA) show this area continues to be a challenge for the agency.2 The
  agency’s overall security program continues to be rated as “not effective” in accordance with federal
  guidance. Because of SBA’s mission and the personally identifiable information it is required to
  collect to carry out that mission, the agency is susceptible to privacy and data breaches.

  It is also critical that SBA plan for cybersecurity risks when modernizing its IT systems. This was an
  issue for SBA’s Unified Certification Platform, which was intended to help streamline the process for
  small business owners to apply for contracting certification programs. GAO reported that when SBA
  transitioned to this new “one-stop” certification system, meant to consolidate multiple systems into
  one, the agency did not implement leading practices for risk management, cybersecurity, and IT
  governance over the investment.K

  In addition to not developing a cybersecurity risk management plan, SBA also did not trace design
  elements of the new system to related cybersecurity requirements, which increases the risk of
  security vulnerabilities.

  This problem continued with personally owned electronic devices allowed to access sensitive SBA
  systems. In late 2024, we identified a significant security vulnerability.3 The agency unknowingly
  allowed personally owned devices, such as smartphones, laptops, or tablet computers, to access,
  store, and transmit agency data with only a username and password. Devices could also access
  the network from foreign locations, which is prohibited by SBA IT policy. Personally owned devices
  can expose the agency to IT security risks, such as unauthorized access and theft of personally
  identifiable information, which can be exploited by cyber criminals and other bad actors. Cyber
  threats include, but are not limited to, disclosure of sensitive data, unauthorized changes, or
  backdoor access to other network resources.

  SBA should have multifactor authentication enabled for users to access the agency’s secure network.
  Multifactor authentication is a high security control that requires a username, password, and an identity
  card, unique security code, or biometrics to access a system. Relying on usernames and passwords
  alone greatly increases the risk of SBA data being accessed and exploited by cyber criminals.

  SBA has taken corrective action by rolling out multifactor authentication for more than 6,000 users.
  The agency is also designing the Unified Certification Platform to improve processes for



  J SBA, SOP 20 33 1, Review and Assessment of System & Organization Controls Report(s) (July 10,

     2025).
  K GAO, GAO-25-106963, It Modernization: SBA Urgently Needs to Address Risks on Newly Deployed

     System (November 2024).


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  administering the contract certification programs. The challenge for SBA is to ensure cybersecurity
  risks are considered and mitigated as the agency continues to modernize and integrate AI
  technology, which will likely be a collaborative process with entities outside the agency.


  OIG HIGHLIGHTED WORK

  1 SBA’s IT Investment Governance Framework (Report 24-10)
  2 Fiscal Year 2024 Federal Information Security Modernization Act (Report 25-13)
  3 Undetected Vulnerabilities from Personally Owned Devices (Report 25-11)




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  Make a Difference
  To promote integrity, economy, and efficiency, we encourage you to report instances of fraud, waste,
  or mismanagement to the OIG Hotline.*

  Visit our OIG Hotline website.

  Write or visit:

  U.S. Small Business Administration
  Office of Inspector General
  Investigations Division
  409 Third Street SW (5th Floor)
  Washington, D.C. 20416

  *In accordance with the Inspector General Act of 1978, codified as amended at 5 USC 407 and 420(b)
  (2)(B), confidentiality of a complainant’s identity is mandatory absent their consent to release such
  information, or unless the Inspector General determines disclosure is unavoidable during the course
  of the investigation.




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  Agency’s Response to Top Management and
  Performance Challenges Facing the Small
  Business Administration in Fiscal Year 2026
  Under the leadership of President Donald J. Trump and Administrator Kelly Loeffler, the U.S. Small
  Business Administration (SBA or Agency) remains dedicated to advancing the mission of support-
  ing America’s small businesses while strengthening operational integrity, program oversight, and
  strategic management. Throughout Fiscal Year (FY) 2025, the Agency’s top priority was reversing
  Biden-era programs and policies that inflicted material damage – whether through personnel policy
  that doubled the agency and resulted in 90% of staff working from home, dozens of unneeded real
  estate leases, hundreds of millions of dollars in wasteful spending, weakened oversight that resulted
  in billions in defaults and delinquencies, partisan initiatives that discriminated against politically
  disfavored groups, or a pervasive indifference to addressing billions of dollars of known fraud on be-
  half of U.S. taxpayers and small businesses. In furtherance of this objective, the Agency immediately
  reversed this damaging agenda, called for an audit, implemented an aggressive plan to strengthen
  and modernize its technology infrastructure, reinforced its internal controls, and reasserted rigorous
  oversight mechanisms to safeguard taxpayer funds.

  Although the Office of the Inspector General (OIG) has appeared unwilling to acknowledge the wide-
  spread malfeasance and mismanagement of the SBA under the Biden Administration, or the enor-
  mous progress that this Administration has made towards restoring the fiscal prudence, program
  integrity and non-partisan accountability that resulted in years of needless risk and costs, the Agency
  nonetheless recognizes that this annual review by OIG is statutorily mandated. With a Trump-ap-
  pointed Inspector General recently confirmed, the Agency is optimistic that it will have a law enforce-
  ment team that is recommitted in their mission to eliminate fraud, stop abuse, and leverage the SBA
  as a powerful force multiplier for economic growth.

  Under the current Administration, SBA prioritized enterprise-wide initiatives that strengthen over-
  sight, reduce risk, improve program outcomes, improve agency workforce productivity and quality,
  enhance efficiency, and address fraud. The result was a historic year in the SBA’s 72-year history –
  delivering a record $45 billion in 7(a) and 504 loans to 85,000 small businesses – with a smaller staff,
  fewer contractors, less spending, and stricter underwriting standards. In total, the Agency reduced
  its headcount by 54% and cut annual spending by over $300 million. Meanwhile, the Agency made
  substantial progress toward prosecuting billions of dollars in pandemic-era fraud that went unad-
  dressed by the Biden Administration and ending abuse within the 8(a) Program for “socially and
  economically disadvantaged” small businesses. With prudent controls and management practices
  in place, the Agency successfully led nationwide efforts to eliminate regulations, promote American
  industry, and level the playing field for rural and veteran entrepreneurs by eliminating Biden-era DEI
  and Green New Deal programs.

  The Trump SBA is committed to transparency with stakeholders, including Congress, federal part-
  ners, and program participants, and continues to apply strategic management decisions to deliver
  results for taxpayers and small businesses owners with accountability, integrity, and efficiency.




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  PROTECTING THE INTEGRITY OF SBA PROGRAMS: Since Day One, cracking down on known fraud
  and implementing preventative measures to end abuse was a top priority for the Agency. The Agency
  bolstered program integrity through a comprehensive fraud risk framework spanning account reg-
  istration, application processing, and pre-distribution screening, as well as retroactive reviews of
  pandemic-era disbursals.

  After years of inaction, the Agency added guardrails back to its core loan programs, including imple-
  menting citizenship and birth date verifications for 7(a) and 504 loan applications, and heightened
  domestic ownership requirements to ensure only legal, eligible, Americans can access federally backed
  resources. Additionally, the Agency established a task force led by the Agency’s Chief Operating Officer
  (COO). The task force meets with senior leadership to review emerging trends, coordinate intra- and
  inter- agency actions, and provide strategic direction to protect the integrity of SBA programs.

  In an effort to identify and prevent ineligible borrowers from accessing SBA-backed financing, the
  Agency expanded data sharing efforts across numerous federal databases, including the U.S. Depart-
  ment of Homeland Security’s (DHS) Systematic Alien Verification for Entitlements (SAVE) Program,
  Social Security Administration’s (SSA) Enterprise Data Exchange Network (EDEN), and Department of
  the Treasury (Treasury)’s Do Not Pay (DNP) database to prevent fraud and improper payments.

  Moreover, the Agency halted non-bank lending programs that saw dramatic expansion—and unprec-
  edented levels of default and delinquency—under the Biden Administration, including the Commu-
  nity Advantage Small Business Lending Company (CASBLC) Program designed to grant 7(a) loans to
  “underserved communities” through “mission-based lenders.” Through a new standard operating
  procedure (SOP), the SBA now requires existing lenders to meet prudent financial stability standards
  as a condition of further participation. In a similar effort to protect taxpayers from avoidable losses,
  the Agency eliminated self-certified loan forgiveness for Paycheck Protection Program (PPP) and cre-
  ated additional internal reviews before forgiveness is adjudicated.

  The assertion that no front-end fraud detection system exists for SBA loan programs is
  false. The SBA offers lenders two types of 7(a) and 504 loan application submissions for compliance
  check screening: a pre-check on in-progress applications undergoing underwriting and checks on
  full applications following the underwriting process. A Do Not Pay verification check was implement-
  ed and is not “in the process” of being completed as asserted in OIG’s report. The Agency also imple-
  mented a fraud framework to screen and oversee the following stages: (1) Account Registration, (2)
  Application Post-Submission Routines, and (3) Pre-Distribution Screening, which provide oversight of
  non-bank lenders and lender service providers.

  The increased rates of suspected fraudulent loans by non-bank lenders referenced in OIG’s
  report occurred in 2021 as part of a Biden-era strategy to increase lending through non-
  bank lenders by reducing program-wide underwriting standards and eliminating lender
  fees. This policy change, and its role in driving increased defaults and delinquencies within the 7(a)
  loan program, represented the single-greatest threat to the zero-subsidy status of the program since
  inception. By the time the Trump Administration assumed office, program losses were approaching
  $600 million. The Agency now projects an estimated $2.2 billion in taxpayer losses associated with
  the four underwriting cohort years of the Biden Administration.




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  Although the Trump SBA took immediate action to restore strong underwriting standards
  and lender fees to preserve the solvency of the 7(a) program, the OIG fails to acknowledge
  this swift corrective action. Remarkably, the OIG conveniently declines to acknowledge the last-
  ing damage of Biden-era malfeasance at all, despite sounding the alarm about potential losses to
  taxpayers in 2024.

  Ludicrously, while the OIG attempts to blame the Trump SBA for failed COVID-19 program
  oversight, the office conspicuously omits the critical fact that the Agency stopped accepting
  and processing pandemic-era loan applications during the Biden Administration in 2021,
  well before President Donald J. Trump won in a historic landslide election for the second
  time. Likewise, OIG’s complaints about the Restaurant Revitalization Fund (RRF) and Shuttered Ven-
  ue Operators Grant (SVOG) pandemic relief programs should be directed toward the Biden Adminis-
  tration, since both programs started and stopped accepting and processing applications in 2021.

  Concerning RRF, the assertion that the Agency hasn’t established a process to recover funds
  from improper payments is simply false. While the Biden Administration swept it under the rug,
  the Trump SBA went back to the data and took action to begin the recovery of those funds. In the
  second half of FY25, management determined a reasonable legal basis to seek recoupment of im-
  proper RRF payments. Management is completing a review of RRF awards, issuing letters to debtors,
  reviewing those debtor responses, and plans to refer identified improper RRF awards as a debt to
  Treasury for collection efforts and may, in limited circumstances, require intervention by the Depart-
  ment of Justice (DOJ).

  The Agency also continues to recover pandemic-era funds identified as potentially fraudulent in col-
  laboration with OIG, Treasury, and DOJ. In 2025, the SBA announced the suspension of thousands of
  Paycheck Protection Program (PPP) and Covid Economic Injury Disaster Loans (EIDL) borrowers and
  issued over 600 demand letters to recoup an estimated $625 million in funding approved through the
  SVOG Program. So far, the Agency has received about $3.5 million and plans to refer the grantees to
  Treasury for collections.

  Regarding SBA’s oversight of federal contracting programs, OIG’s report is inaccurate and
  incomplete as it fails to identify the root cause of fraud. One key failure is to provide sufficient
  context concerning Biden-era changes to self-certification for certain eligibility requirements while
  stating it can lead to fraudsters taking advantage of government contracting programs – and that the
  Trump SBA is the first in the 8(a)’s 45-year history to audit this Carter-era program. As written in the
  report, the reader could assume that SBA contracting certification programs allow self-certification
  for multiple eligibility requirements, rather than just the size of a particular business applicant. Addi-
  tionally, the Agency complies with the federal statute regarding the least possible regulatory burden
  principle (15 USC 632(x)(2)(B)) when it comes to the efficiency of self-certification. Furthermore, the
  OIG’s report inaccurately states that “unscrupulous business owners can make unsupported claims
  to attest they are eligible for these certification programs in SAM.gov or SBA’s Dynamic Small Busi-
  ness Search Database,” but only the Agency can attest to a small businesses’ “disadvantaged” status
  on both of those databases.

  Additionally, last year, the Agency commenced a thorough review of the 8(a) program, including
  revoking the independent contracting authority of the U.S. Agency for International Aid (USAID),



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  launching a comprehensive audit, and issuing letters to all 4,300 8(a) contractors requiring submis-
  sion of three years’ worth of financial documents for review. The Agency also updated its sprints for
  the Unified Certification Platform (UCP) system to include additional functionalities and features to
  support reviews of 8(a) firms, planned for deployment in mid-March 2026. The technology update
  aims to help mitigate the risks of 8(a) firm owners exceeding income threshold levels.

  MANAGING SBA’S LOAN PORTFOLIO AND PARTICIPATING LENDERS: Although the PPP and COV-
  ID-19 EIDL programs no longer accept new applications, the experience gained from those programs
  informed improvements to risk management, loan servicing, technology systems, investigations,
  and collections across active loan portfolios. As described in the preceding narrative, oversight of
  SBA’s loan programs was expanded through the application of more rigorous controls for both bank
  and non-bank lenders, including fintech participants. Program monitoring was enhanced to assess
  underwriting, loan disbursement, and lender compliance with SBA standards, including through the
  reapplication of prudent lending standards. The Agency also expanded pre-distribution screening
  and incorporated additional cross-agency verification checks within loan origination infrastructure.

  Concerning the Agency’s portfolio of pandemic-era loans, the OIG’s report speculates that the Agency’s
  workforce reduction in 2025 could negatively impact its ability to service the portfolio. This conjecture
  is wildly divorced from the reality of the data and results presented here. Last year, the Agency reduced
  its headcount by over 50% while simultaneously not experiencing any break in service across SBA’s
  financial products – thanks to improved technology, fewer internal personnel issues due to reductions,
  and improved workflow enabling greater productivity and results for taxpayers and small businesses.
  Mandating in-office work for federal employees – instead of allowing the work-from-home culture that
  pervaded the Biden Administration – also contributed to stronger results for taxpayers. As impossible as
  it may seem to bureaucrats, the federal government can do more with less.

  Under Administrator Loeffler, the Agency made enhancements to its origination platform
  for lenders, and continues to do so, to ensure the integrity of its programs and reduce risk,
  which is unrelated to lender oversight as the OIG report suggests. During the COVID-19 pan-
  demic, PPP funds were deployed rapidly, which did not allow for oversight activities to occur in the
  same manner as it does for SBA’s continuous programs, such as the 7(a) and 504 Loan Programs. For
  emergency programs with time critical capital deployment, the oversight (risk mitigation framework)
  must be integrated into the origination platform. The Agency, OIG and others have documented their
  perceived deficiencies in the PPP origination platform with the Agency responding with enhance-
  ments between rounds of PPP funding as well as continuous improvement since then in support
  of ensuring the continued viability of the Agency’s business loan programs. These efforts provide
  greater confidence in lender performance, borrower eligibility, and program outcomes, while reduc-
  ing the occurrence of improper payments.

  Although the OIG urges stronger stewardship of disaster resources, the office fails to acknowledge
  the restructuring implemented by this Agency to ensure the availability of adequate disaster fund-
  ing after the Biden Administration ran out of money at the height of Hurricane Helene in 2024. The
  Trump SBA maintained adequate appropriations through prudent forecasting and robust reporting
  and consultation with Congressional partners. With this renewed governance, the Agency approved
  over $6 billion in disaster relief for more than 27,000 survivors in 2025.




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  The Agency disagrees with OIG’s revisionist history that a lapse in disaster loan disbursements between
  October and December of 2024 was because “the Agency had not adjusted its forecasted lending level
  or annual budget request for disaster assistance since 2009 even though the number and cost of billion-
  dollar disasters has generally increased over time.” The Executive Branch historically does not use the
  annual budget requests process to mitigate major disaster requirements. In fact, the Biden SBA as-
  sured Congress that funding levels were sufficient mere days before disaster struck. While the Agency is
  adjusting its annual budget request to provide an updated steady state disaster lending estimate based
  on historical factors, gaps in disaster funding may occur should major disasters strike.

  MEASURING PERFORMANCE AND MONITORING SBA PROGRAMS: SBA continues to reform pro-
  gram performance oversight through expanded analytics and modern reporting dashboards. Oversight
  of resource partners programs, including Small Business Development Companies (SBDCs), has been
  reinstated after years to support accurate, timely performance reporting that aligns with statutory and
  congressional requirements. These actions allow leadership to track key indicators, identify emerging
  risks, and implement corrective measures that advance program performance and participant success.

  In contrast to the OIG’s report calling for measures to assess goal accomplishments, the
  Agency identified performance and consistency gaps at the beginning of the Administra-
  tion’s term and is already developing new dashboards to measure, track, and monitor
  activity and results. The OIG suggested remediation that would establish performance goals and
  measuring progress, yet these actions are not supported by statute in the Small Business Act, by the
  Agency’s regulations, or by Office of Management and Budget’s (OMB) guidance. Furthermore, the
  OIG’s recommendations are not practicable nor are they funded. The Agency repeatedly attempted
  to explain that differences in loan programs and grant-making require unique approaches. The
  Agency would like to partner with the OIG in adopting an accountability framework that inverses the
  effectiveness of for the Agency’s statutory grant programs, but the Agency does not believe applying
  lending metrics to a grant program is useful.

  The Agency agrees with the OIG’s proposal to coordinate with resource partners to improve
  the tracking and monitoring of performance goals. In fact, this is exactly what the Agency
  does. As the Agency revised the goals beginning for the 2024 project year, extensive meetings took
  place with resource partners, as well as consultations with America’s SBDC as required by statute. On an
  annual basis, SBDCs submit goals for the established metrics through their annual proposal, and these
  are reviewed by the Agency. If the goals are not in alignment with past performance, the Agency will
  work collaboratively with the SBDCs to adjust the goals accordingly. The OIGs presumption of addition-
  al funding to meet goals are completely unfounded. Because of delays in the appropriation and ap-
  portionment process, SBDCs may often carry over funds from the previous year to fill existing resource
  gaps while awaiting additional funding. This in turn leads to carryover for the next fiscal year but does
  not amount to additional money used in any given performance period as the OIG falsely claims.

  The OIG itself considered its recommendation that “the agency establish formal procedures for
  obtaining and reviewing appropriate supporting documentation to ensure sales and investments
  are accurately reported” resolved, as indicated in its published SBA’s Implementation of the SBIR
  and STTR Extension Act of 2022 (Report 24-14). OIG closed the recommendation in August 2024. The
  formal procedures were followed in performing the FY24 and FY25 performance benchmark assess-
  ments, including requiring small businesses to submit documentation that the SBA used to verify



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  performance claims. The population of documents provided as evidence of covered sales included
  purchase orders, contracts, sales agreements, receipts, and invoices. Covered sales were assessed
  and verified as Government Designated Phase III contracts via official federal databases. SBA has
  tested and continues to actively pursue external independent data sources to enhance its ability to
  validate commercialization activity provided by small businesses in the SBIR/STTR programs.

  FINANCIAL REPORTING AND MANAGING DATA: The Agency made significant progress in modern-
  izing data management and financial reporting systems. SBA established standardized data-sharing
  agreements with multiple federal partners, including SSA, Treasury, and DHS, to eliminate barriers
  and improve data accuracy for program administration. The Agency also created the SBA’s first Open
  Data Plan (ODP) to improve transparency and broaden public access to SBA data. Efforts to resolve
  historical accounting issues associated with COVID-19 era programs continue, with accepted ac-
  counting principles applied to closed and charged-off loans. Enterprise reporting dashboards and
  continued audit remediation activities give leadership greater visibility into operational and financial
  performance, while supporting statutory and regulatory compliance.

  The OIG report provides an accurate depiction of the material weaknesses and significant
  deficiencies identified by the Agency’s external auditors for FY24. That said, the report
  conspicuously omits any reference to the substantial remediation progress achieved by
  management during FY25. The auditor’s report indicates that, to date, SBA has successfully re-
  mediated three of the seven material weaknesses, two previously identified significant deficiencies
  were fully remediated, and one material weakness was downgraded to a significant deficiency. This
  meaningful advancement reflects our disciplined, prioritized approach to strengthening the overall
  control environment. By failing to acknowledge this considerable year-over-year improvement, the
  report inadvertently presents readers of the Agency Financial Report (AFR) with an outdated and
  incomplete perspective, one that materially understates the current state of our internal controls. In
  reality, the control environment today is demonstrably stronger than in the several prior fiscal years,
  with further enhancements already in progress that position the SBA for even greater resilience and
  reliability moving forward.

  MANAGING RISKS IN INFORMATION TECHNOLOGY SYSTEMS: The SBA has reinforced IT gover-
  nance and cybersecurity through the appointment of a new Chief Information Officer (CIO) and Chief
  AI Officer (CAIO) and the consolidation of data centers – which have already been reduced from 11 to
  four – accompanied by updated oversight from the new AI Governance Council, AI Working Group,
  and Data Governance Board. These bodies provide structured reviews of emerging technologies to
  support operational efficiency and sound decision-making. Strengthened IT governance supports
  security, continuity of operations, and the availability of reliable and timely information across all
  SBA programs.

  The reinstated AI Governance Council, Data Governance Board, and the new AI Working Group will
  oversee the responsible use of artificial intelligence. Additionally, the Agency has upgraded its net-
  work infrastructure, is in process of a complete cloud migration, launched AI pilot programs, and
  strengthened oversight to ensure compliance, operational excellence, data stewardship, and data
  security. The Data Governance Board has also drafted a new Data Strategy and Data Sharing Agree-
  ment for all systems.




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  The Trump SBA has begun developing a comprehensive de-risking strategy centered on modernizing
  both our physical assets, our technology infrastructure, and our human capital. The construction of
  a new physical Security Operations Center (SOC) infrastructure now serves as the centralized com-
  mand center for our defense operations. Supporting this physical upgrade, we have reorganized our
  security division into specialized units, specifically our SOC Analyst, Cyber Threat Intelligence, and
  Forensics teams. This structural shift ensures that we have dedicated expertise focused on every
  stage of a threat, from proactive intelligence gathering and real-time monitoring to deep-dive foren-
  sic investigations.

  At the core of our technological defense is the introduction of an Extended Detection and Response
  (XDR) solution. This unified security incident platform is designed to enhance our detection and re-
  sponse capabilities by integrating data across various security layers, providing a more holistic view
  of the threat landscape. To complement this, the SBA has moved toward automated security inci-
  dent response, which adopts a collaborative approach by integrating security practices directly into
  IT operations. By streamlining and automating incidents and vulnerability management, we have
  fostered much closer collaboration between our security and IT teams to ensure a unified approach
  to security. This synergy significantly reduces the risk of cyber threats while simultaneously increas-
  ing operational efficiency across the entire Agency.

  In contrast to the Biden SBA, which operated out of a dozen disparately managed data centers, and
  recognizing the complexity of modern infrastructure, the Trump SBA has also implemented a Cloud
  Native Application Protection Platform (CNAPP) to secure every layer of our cloud environment, from
  the initial code to the final runtime. The SBA now employs agentless, API-based scanning to maintain
  comprehensive visibility across our multi-cloud environments. This capability allows the Agency to
  protect everything it builds and runs in the cloud, ensuring consistent and robust security standards
  across all various cloud platforms. Through these combined physical, organizational, and technolog-
  ical advancements, the Agency has established a resilient framework for long-term risk management.

  To further mature the Agency’s risk management posture, the SBA has proactively engaged with the
  Cybersecurity and Infrastructure Security Agency (CISA) to enhance our participation in the Continu-
  ous Diagnostics and Mitigation (CDM) Program. This program provides a dynamic approach to fortify-
  ing government networks by reducing exposure to known vulnerabilities and streamlining Federal
  Information Security Modernization Act (FISMA) reporting.

  By aligning the CDM Program with Zero Trust principles, the Agency is moving toward a model that
  requires continuous verification of user identities and device security. This evolution has led to an
  increased focus on improving incident response capabilities and deploying advanced endpoint
  detection and response tools across the Agency’s infrastructure. These combined efforts—integrating
  advanced cloud protections with federal-level visibility programs—ensure that the Agency maintains
  a proactive and resilient defense against an increasingly sophisticated threat landscape. OIG’s report
  inaccurately states that the Agency has 21 unassigned and two in-review cases in AI Inventory, which
  the SBA believes is erroneous data from an invalid source.

  With the revitalization of the AI Working Group and the AI Governance Council, the AI Use Case Inven-
  tory will be reevaluated. It also inaccurately states that no updated internal policies have been posed
  on the Agency’s website. However, the Agency published the statutorily required ODP on June 18,



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  2025. This 2-year action plan was approved by the Data Governance Board and establishes an enter-
  prise-wide strategy and framework to expand and improve access to Agency data. The ODP outlines
  the Agency’s intent to comply with the requirements set forth in the OPEN Government Data Act and
  incorporates guidance from OMB M-25-05. The remainder of the document discusses the SBA data
  governance framework.

  CONCLUSION: The Agency recognizes the OIG’s oversight and appreciates the opportunity to pro-
  vide additional context on the findings presented in the Top Management and Performance Chal-
  lenges in FY26 report. Several issues identified in the report relate to closed COVID-19 programs that
  concluded years ago and were never reinforced or investigated during the Biden Administration. The
  SBA continues to resolve remaining matters associated with these programs, including recovery of
  improperly disbursed funds. The Agency’s current initiatives focus on strengthening internal controls,
  improving operational efficiency, and advancing effectiveness and oversight across active programs.
  Actions implemented in 2025 reflect this Administration’s structured approach to risk management
  and program integrity, informed by lessons learned from prior programs and shaped by modern
  oversight needs. The SBA remains committed to maintaining open communication with the OIG
  and federal partners, and to supporting small businesses through programs that are well-managed,
  transparent, and grounded in sound stewardship of public resources.

  Sincerely,




  Kelly Loeffler
  28th Administrator




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  Payment Integrity
  The Payment Integrity Information Act of 2019 (PIIA) was established to improve efforts to
  identify and reduce Government-wide improper payments. PIIA requires agencies to estimate
  improper payments and report on actions to reduce improper payments. In accordance with
  Office of Management and Budget (OMB) Circular A-123, Appendix C, Requirements for Payment
  Integrity Improvement (M-21-19) (hereafter referred to as “Appendix C”), agencies are required to
  identify, assess, prioritize, and respond to payment integrity risks to prevent improper payments
  in the most appropriate manner. This report will discuss the SBA’s efforts and results related to
  improper payment assessment and reviews. More detailed information on improper payments and
  information previously reported in the AFR that is not included in the FY 2025 AFR can be found on
  PaymentAccuracy.gov.
  The SBA’s improper payment reviews are a multi-layered process that starts with a risk assessment.
  If a risk assessment indicates that a program is susceptible to improper payments, then testing is
  performed using a statistically valid sampling technique. Based upon the testing results, a corrective
  action plan is developed to prevent and remediate the types of errors uncovered. If testing finds a
  significant amount of recoverable dollars, the SBA considers the appropriateness of performing a
  recapture audit.

  The detection and remediation of improper payments is a priority for the Agency. SBA staff monitor
  and review for improper payments and implement improvements that will reduce improper payment
  rates. The SBA also continually seeks opportunities to enhance and implement internal controls to
  reduce the risk for improper payments.

  In FY 2025, the SBA reviewed eight programs and activities that were deemed susceptible to
  significant improper payments. Of the eight programs reviewed, four programs are major credit
  programs mandated by OMB, and four programs are programs that were created as a result of the
  pandemic response. The eight programs are:
  •     7(a) Loan Guarantees Approvals;
  •     7(a) Loan Guarantees Purchases;

  •     504 Certified Development Loans Approvals;

  •     Disaster Assistance Loans;

  •     Paycheck Protection Program (PPP) Loan Guaranty Purchases;

  •     Paycheck Protection Program (PPP) Loan Forgiveness;

  •     Section 1112 Payments; and the

  •     Shuttered Venue Operators Grant Program (SVOG).

  The SBA conducts risk assessments on a three-year rotation cycle for programs not deemed
  susceptible to significant improper payments, or earlier if a program was subjected to significant
  change in legislation or funding level. Significant improper payments are defined as gross annual


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  improper payments exceeding (1) both 1.5 percent of program outlays and $10,000,000, or (2)
  $100,000,000. The qualitative risk assessment applies an individual risk weight to each risk factor to
  account for the variability in potential risk that each risk factor could impose on a program. This year,
  the SBA performed risk assessments on the Growth Accelerator Fund program and the payments
  made under Section 1112 of the CARES Act using the revised qualitative risk assessment. The SBA
  concluded that the Growth Accelerator Fund Competition Program was not susceptible to significant
  improper payments, and that the Section 1112 payments were susceptible to significant improper
  payments.

  The next sections discuss the SBA’s efforts and results related to improper payment assessments and
  reviews.




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  PAYMENT REPORTING
  Table 1: Improper Payment Reporting and Reduction Outlook (Dollars in Millions) 1
                                          FY 2024                                        FY 2025 Summary                                                                           FY 2025 Breakdown

                                                                                                                                              Over-                                                                                      FY 2025
                                                                                                                                                             Over-                  Techni- Overpayments Overpayments           Techni-
                                                                                                                                           payments                                                                                     Reduction
           Program            Outlays 2                             Outlays 2 Proper Improper Unknown Proper Improper Unknown                              payments      Under-      cally    (Outside      (Within    Under     cally
                                            IP           IP                                                                                 (Outside                                                                                      Target
                                 $                                     $      Payment Payment Payment Payment Payment Payment                            (Within Agency paments    Improper    Agency       Agency    payments Improper
                                            %             $                                                                                  Agency                                                                                        %7
                                                                                 %       %       %       $       $       $                                  Control)       %       Payments   Control)     Control)      $     Payment
                                                                                                                                            Control)
                                                                                                                                                               %                      %           $            $                   $
                                                                                                                                               %

   SBA Programs

  7(a) Loan Guaranty
                              20,294.40       5.44     1,103.35     26,614.89   93.87    6.13    0.00 24,982.37     1,632.51           -          0.00            0.00      0.00      100.00               -              -          -     1,632.51    5.79
  Approvals
  7(a) Loan Guaranty
                               1,394.74       5.34        74.52      2,115.50   98.49    1.07    0.44    2,083.63     22.55        9.31           0.00           75.97     24.03        0.00               -          17.13       5.42            -    1.07
  Purchases

  504 Certified
  Development Loan             6,329.16       3.74       236.73      7,392.04   95.42    4.58    0.00    7,053.63    338.42            -          0.00            0.00      0.00      100.00               -              -          -       338.42    4.56
  Approvals

  Disaster Assistance Loans    1,175.70       3.62        42.54      3,223.82   95.13    4.87    0.00    3,066.80    157.02            -          0.00           79.66     20.34        0.00               -         125.08     31.94             -    4.25

  COVID Programs
  Paycheck Protection
  Program (PPP) Loan           1,507.20      21.09       317.83       303.85    80.78   19.04    0.17      245.46     57.86        0.53           0.00           98.62      1.38        0.00               -          57.06       0.80            -   10.00
  Forgiveness
  Paycheck Protection
  Program (PPP) Loan           6,792.08      24.47     1,662.30      1,398.23   86.72    5.17    8.11    1,212.49     72.30      113.44           0.00          100.00      0.00        0.00               -          72.30          -            -    5.17
  Guaranty Purchases

  Section 1112
            3, 4                    N/A          N/A          N/A   10,585.15   99.66    0.34    0.00 10,548.67       36.48            -        100.00            0.00      0.00        0.00           36.48              -          -            -    N/A
  Payments
  Shuttered Venue
  Operators Grant                   N/A          N/A          N/A   14,604.95   31.06   39.89   29.05    4,535.97   5,826.29    4,242.69          0.00           76.97      0.35       22.67               -       4,484.64     20.62      1,321.03    N/A
          3, 5
  Program

  Restaurant Revitalization
                6             28,599.45       0.00         0.07          N/A     N/A     N/A      N/A        N/A        N/A         N/A           N/A             N/A       N/A         N/A             N/A            N/A        N/A          N/A     N/A
  Fund Program


  Total                       37,493.28                3,437.27 66,238.42                               53,729.02 8,143.43 4,365.97                                                                  36.48         4,756.21     58.78      3,291.96




  1 Amounts and percentages reported on this table may not reconcile due to rounding differences.
  2 Outlays in this report represent the base amount of the program activity related to SBA improper payments; and this amount will differ from the amount reported as outlays in SBA’s President’s Budget submissions because they include reesti-
  mates of subsidy cost, reimbursements to SBA administrative funds and other costs. Outlays for 7(a) loan guaranty purchases are the amount of disbursements for the purchase of defaulted guarantied loans. Outlays for 7(a) loan guaranty approvals
  are the amount of new guaranty approvals by banks and other SBA lending partners. Outlays for 504 CDC loans guarantied are approvals irrespective of disbursement, net of approval increases, decreases, reinstatements and cancellations for the
  current year. Outlays for disaster loans are loan disbursements on current year approvals.
  3 Prior year data for the program is not available as FY 2025 is the first year program is reporting improper payment data.
  4 Section 1112 Payments data pertain to outlays from April 1, 2020 through March 31, 2025. Data pertaining to this timeframe are reported in FY 2025.
  5 The Shuttered Venue Operators Grant program data pertain to outlays from April 1, 2021 through March 21, 2024. The last disbursement occurred on May 27, 2021. Data pertaining to this timeframe are reported in FY 2025.
  6 The Restaurant Revitalization Fund program data pertain to outlays in May 2021 to June 2021, which fell into FY 2022; and April 2022 to March 2023, which fell into FY 2023. Data pertain to these 2 years were reported in FY 2024.
  7 Tolerable rates have been established for 7(a) Loan Guaranty Approvals, 7(a) Loan Guaranty Purchases, 504 Certified Development Loan Approvals, and Disaster Assistance Loans. For these programs, the established reduction target will be the
  lesser of the established tolerable rate, or the current reported improper payment rate (i.e., if the FY 2025 improper payment rate is less than the established tolerable rate, the FY 2025 improper payment rate will be the reduction target).




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  The above table presents a summary of the SBA’s improper payment review results and reduction
  outlook.

  To provide more clarity for the reader, this section is organized by the seven programs and activities
  subjected to review for improper payments and provides statistical sampling information and review
  results coupled with the SBA’s planned corrective actions to address the improper payments.
  7(a) Loan Guaranty Program

  The 7(a) Loan Program is the SBA’s most common loan program. The 7(a) Loan Program provides
  small businesses with short- and long-term working capital, capital to refinance current business
  debt, and capital for specific business expenditures. Key eligibility factors include what the business
  does to receive its income, its credit history, and where the business operates.

  For the purpose of payment integrity reporting, the 7(a) Loan Program is split into 7(a) Loan Guaranty
  Approvals and 7(a) Loan Guaranty Purchases.
  7(a) Loan Guaranty Approvals

  7(a) Loan Guaranty Approvals describes the loan guaranty approval process. The SBA does not make
  loans directly to borrowers; instead, the SBA provides a guaranty to a lender which makes the loan to
  a borrower. The SBA delegates authority to certain lenders (13 CFR 120.440) to process, close, service,
  and liquidate certain 7(a) loans without prior SBA review. Approximately 80 percent of 7(a) loans are
  approved by lenders under their delegated authority. All loans identified as improper payments in FY
  2025 were processed by lenders under their delegated authority.

  During the loan guaranty approval review process, the SBA reviews the 7(a) loan for calculation
  accuracy to ensure that lenders issued the 7(a) loans to eligible borrowers and that loans are made
  within statutory, regulatory, and SBA-issued guidelines. At the time of loan approval, no monies
  are disbursed. Improper payments identified during loan review result in no monetary loss to the
  government.

  Statistical Sampling

  For 7(a) approval reviews, the sample cases were chosen using PPS Sampling with replacement
  from all loan guaranties approved during the 12-month period ended March 31, 2025. The approval
  population was divided into two strata based on whether the loan was SBA Express or not. The SBA
  determined the appropriate total sample size to be 232 loans from the population. The sample
  included net guaranteed approvals of $309,844,445 and improper payments of $23,034,655 within
  the sample. Using the Hansen-Hurwitz estimation method, the estimated improper payments rate
  for the annual period ending March 31, 2025, was calculated as 6.13%.

  The improper payment rate in FY 2024 was 5.44 percent. The increase in the improper payment rate
  can be attributed to unintentional lender underwriting errors and insufficient documentation.

  Tolerable Rates and Reduction Targets

  Guidance in Appendix C to OMB Circular A-123 states that “… agency leaders can set Risk Tolerance
  bands for IPs (Improper Payments) … for each program.”



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  Prior to the FY 2025 improper payment testing cycle, the SBA established a risk tolerance band for
  the 7(a) Loan Guaranty Approval Program improper payments. The risk tolerance band effective for
  the FY 2025 review cycle is 2.23 percent to 10.00 percent; while the improper payment rate increased
  in FY 2025, it is within SBA’s tolerable improper payment range. In compliance with SBA’s established
  processes, the Agency conducted the required annual assessment of the established 7(a) Approvals
  tolerable improper payment range. The assessment concluded the previous tolerable improper
  payment range was no longer adequate and established a new risk tolerance band of 5.23 percent to
  10.00 percent. In addition to the updated risk tolerance band, the SBA has also established a target
  reduction rate for this program of 5.79 percent.

  Improper Payment Reviews

  7(a) Loan Guaranty Approval reviews are conducted to determine whether lenders complied
  materially with the 7(a) Loan Program origination requirements, including statutory provisions,
  SBA regulations, any agreement the lender executed with the SBA, Standard Operating Procedures,
  Loan Authorizations/Terms and Conditions, and official SBA notices and forms applicable to the 7(a)
  Loan Program. The reviews are conducted in order to determine if lenders (1) originated the loan in
  a prudent and commercially reasonably manner, (2) misrepresented or failed to disclose a material
  fact to the SBA, and/or (3) placed the SBA’s financial interest at risk. Loans in the 7(a) Loan Guaranty
  Approval Program are reviewed at the time of approval; these loans are generally made to the right
  recipient for the right amount, but in the approval process, lenders failed to follow all statutes and
  regulations. In these cases, there is no amount that needs to be recovered. However, because the
  lender failed to adhere to all applicable statutes, the guaranty is considered technically improper.

  Actions to Improve Payment Integrity

  The SBA revised its 7(a) Lender and Developing Company Loans Standard Operating Procedure
  (SOP) in August of 2023 and issued a second revision in November of 2023. To improve payment
  integrity, the SBA provided training on the revised SOP – the SOP in effect during the FY 2025
  improper payment testing cycle - to lenders prior to issuance and continued providing quarterly
  training while this SOP remained in effect.

  The SBA updated its 7(a) Lender and Developing Company Loans SOP in 2025, largely re-implementing
  requirements that were in place before January 2021, including restoring 7(a) underwriting criteria,
  reinstituting the SBA Franchise Directory with streamlined procedures, re-affirming that SBA Lenders
  determine whether the Applicant is eligible for a loan guaranteed by SBA, and eliminating the “do what
  you do” philosophy from the SOP. This SOP became effective in June 2025 and will apply to 7(a) Loan
  Guaranty Approvals in the FY 2026 improper payment testing cycle. To improve payment integrity,
  the SBA provided training on the updated SOP prior to issuance and continues to provide quarterly
  training. The SBA also provides additional training on specific topics throughout the year.

  Root Causes and Corrective Action

  Approximately 80 percent of all 7(a) Loan Guaranty Approvals are performed by lenders with
  delegated authority to evaluate, process, close, and disburse 7(a) loans. Lenders with delegated
  authority were responsible for all identified improper payments for 7(a) Loan Guaranty Approvals in
  FY 2025.



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  Improper payments in the 7(a) Loan Guaranty Approval Program were caused by lenders’ failure to
  verify all components of loan eligibility (program integrity issues or project structure issues), lenders’
  failure to provide loan documentation, and data entry errors. Because the improper payments
  for these 7(a) approvals are technically improper, the OMB root cause is identified as Statutory
  Requirements of Program Were Not Met.

  To reduce and/or eliminate the occurrence of future improper payments, a Corrective Action Plan
  has been developed for the 7(a) Loan Guaranty Approval Program centers. Specific corrective actions
  are determined based upon the primary reason for the error, with the purpose of both remedying the
  error and preventing recurrence.

  1. Collaboration with the Office of Credit Risk Management (OCRM) through referrals;
  2. Collaboration with 7(a) Loan Guaranty Processing Center (LGPC) Management and the Office of
        Financial Assistance (OFA), informing management of identified deficiencies for incorporation
        into policy and training, along with feedback to lenders and LGPC; and/or

  3. Provide external training to lenders on regulatory and policy requirements governing eligibility,
        proper loan structure, and documentation.

  The Office of Financial Program Operations (OFPO) shares the loan level and lender deficiencies
  identified during the reviews with OCRM and OFA and will continue its efforts throughout the
  upcoming fiscal year to ensure that lender deficiencies are monitored and referred to OCRM
  recommending lender deficiencies raising concern to be incorporated into OCRM’s Risk Based
  Reviews and OFA’s policy revisions and updates.

  Corrective actions for specific loans are tracked at the loan level through a centralized database.
  The Quality Control Specialists for 7(a) Loan Guaranty Approvals monitors errors from identification
  through completion of the corrective actions. OFPO management provides oversight to ensure
  that milestones are met. Improper payments identified as a result of the FY 2025 PIIA reviews have
  been resolved through recommendations to reduce or cancel the loan guaranty, efforts to obtain
  additional documentation, and/or referral to other offices. Corrective actions are initiated within 120
  days and are generally taken within the fiscal year.
  7(a) Loan Guaranty Purchases

  7(a) Loan Guaranty Purchases describes the loan guaranty purchase process. A lender may demand
  that the SBA honor its guaranty on a loan if a borrower is in default or files for federal bankruptcy
  protection. During the loan guaranty purchase process, the SBA will purchase (also called “honor”)
  the guaranty on a defaulted SBA loan.

  During the loan guaranty purchase review process, the SBA reviews the 7(a) loan guaranty purchase
  to determine that the honoring of the guaranty was done appropriately: that the lender complied
  materially with Loan Program Requirements as defined in 13 CFR 120.110; that the lender made,
  closed, serviced, and liquidated the loan in a prudent manner; that the lender’s improper action or
  inaction did not place the SBA at risk; and that the lender did not misrepresent or fail to disclose a
  material fact regarding the loan.




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  Statistical Sampling

  For 7(a) purchase reviews, the sample cases were chosen using PPS Sampling with replacement from
  all purchases processed during the 12-month period ended March 31, 2025. The purchase population
  was divided into four strata based on the following factors: 1) which servicing office processed the
  purchase, and 2) whether the loan was considered an early default, regardless of servicing office. The
  SBA determined the appropriate total sample size to be 240 loans from the population. The sample
  included aggregate purchase outlays of $312,426,648 and an absolute value of improper payments of
  $4,093,797 within the sample. Using the Hansen-Hurwitz estimation method, the estimated improper
  payment rate for the 7(a) guaranty purchase population is 1.07 percent for the annual period ending
  March 31, 2025.

  The improper payment rate for 7(a) loan guaranty purchases in FY 2025 was 1.07 percent, a
  significant reduction from the FY 2024 rate of 5.34 percent. This reduction in the improper payment
  rate is part of a cycle of higher rates followed by lower rates. The SBA has been consistent throughout
  the past few years in providing training for staff involved in guaranty purchases.

  Tolerable Rates and Reduction Targets

  Guidance in Appendix C to OMB Circular A-123 states that “… agency leaders can set Risk Tolerance
  bands for IPs (Improper Payments) … for each program.”

  Prior to the FY 2025 improper payment testing cycle, SBA has established a risk tolerance band for
  FY 2025 for the 7(a) Loan Guaranty Purchases Program improper payments. The risk tolerance band
  for this program is 5.78 percent to 10.00 percent. In compliance with SBA’s established processes,
  the Agency conducted the required annual assessment of the established 7(a) Guaranty Purchases
  tolerable improper payment range, concluding no revisions were needed to the risk tolerance band
  for FY 2026. In addition to the risk tolerance band annual evaluation, the SBA also established a
  target reduction rate for this program of 1.07 percent.

  Improper Payment Reviews

  7(a) Loan Guaranty Purchase reviews are conducted to determine whether lenders complied
  materially with the 7(a) Loan Program origination requirements, including statutory provisions, SBA
  regulations, any agreement the lender executed with the SBA, standard operating procedures, loan
  authorizations, and official SBA notices and forms applicable to the 7(a) Loan Program. The reviewers
  determined whether the lender (1) originated, serviced, and liquidated the loan in a prudent and
  commercially reasonable manner, (2) misrepresented or failed to disclose a material fact to the SBA,
  and/or (3) put the SBA’s financial interest at risk. Loans in the 7(a) Loan Guaranty Purchase Program
  are reviewed at the time of guaranty purchase, after SBA has honored its guaranty.

  Actions to Improve Payment Integrity

  The SBA announced revisions to its 7(a) Loan Servicing and Liquidation SOP in September 2024,
  which became effective December 2024. Revisions to the SOP were largely the result of feedback
  received from the public, including participating lenders and representatives of various trade
  associations, addressing technical corrections to clarify the SOP. To improve payment integrity,



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  the SBA provided training on the revised SOP to lenders prior to issuance and continued providing
  quarterly training while this SOP remained in effect.

  The SBA updated its 7(a) Loan Servicing and Liquidation SOP in September 2025. This SOP became
  effective in November 2025 and will apply to 7(a) Guaranty Purchases in the FY 2026 improper payment
  testing cycle. At time of publication, the SBA is in the process of providing training on the updated SOP
  and will continue to provide quarterly training as part of its continuous efforts to improve payment
  integrity. The SBA also provides additional training on specific topics throughout the year.

  Root Causes and Corrective Action

  The root cause categories established by OMB are: (1) Statutory Requirements of Program Were Not
  Met; (2) Unable to Determine Whether Proper or Improper; (3) Data/Information Needed Does Not
  Exist; (4) Inability to Access Data/Information; and (5) Failure to Access Data/ Information. The root
  cause for 7(a) Loan Guaranty Purchases improper payments was identified as Failure to Access Data/
  Information. Improper payments occurred when purchase processors failed to identify lenders’
  deficiencies during the evaluating, processing, closing, disbursing, servicing, liquidating, or litigating
  of an SBA guaranteed loan. The root cause for 7(a) Loan Guaranty Purchases improper payments was
  identified as Statutory Requirements of Program Were Not Met when the source of equity injection
  funds was not provided.

  The primary reasons for 7(a) Loan Guaranty Purchase improper payments included improper payment
  of expenses related to the care and preservation of collateral, failing to properly identify eligibility for
  debt refinance, and failing to adequately reconcile the purchase from the Secondary Market.

  To reduce and/or eliminate the occurrence of future improper payments, a Corrective Action Plan
  has been developed for the 7(a) Loan Guaranty Purchase Centers. Specific corrective actions
  are determined based upon the primary reason for the error to prevent recurrence of improper
  payments. The Corrective Action Plan includes:

  •     Internal training for purchase processors, reviewers, and approvers to determine proper
        recommendation of guaranty purchase or denial: ensuring that borrower and loan eligibility
        requirements are met; ensuring that liquidation expenses are appropriate and/or approved,
        verifying the documentation and accuracy of calculations, ensuring that documentation for
        account reconciliation is complete, and verifying the proper use of proceeds and reviewing
        expenses for eligibility of reimbursement.

  •     Internal feedback provided to center staff regarding the specific loan-level deficiency upon
        detection.

  Corrective actions are tracked at the loan level through a centralized database. The Quality Control
  Specialists for the 7(a) Loan Guaranty Purchase centers monitor errors from identification through
  completion of the corrective action. Headquarters management provides oversight to ensure that
  milestones are met. Improper payments identified as a result of the FY 2025 PIIA reviews have been
  resolved through efforts to obtain additional documentation, referral for denial review, collection of
  funds from the lender, or reimbursement to the lender. Corrective actions were generally completed
  at the loan level within 60 days, and all actions were taken by the end of the fiscal year.



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  504 Certified Development Loan Approvals

  The 504 Certified Development Company Loan Program provides small businesses with long-term,
  fixed rate financing for major fixed assets that promote business growth and job creation. 504 loans
  are available through Certified Development Companies (CDCs). CDCs are the SBA’s community-
  based partners. They are nonprofit corporations certified and regulated by the SBA to package,
  process, close, and service 504 loans in order to promote economic development within their
  communities. CDCs are certified and regulated by SBA.

  During the loan approval review process, the SBA reviews the 504 loan to ensure that the CDC lender
  issued the 504 loan to an eligible borrower and that the loan was made within statutory, regulatory,
  and SBA-issued guidelines.

  Statistical Sampling

  For 504 CDC approval reviews, the sample cases were chosen using PPS sampling with replacement
  from all loan guaranties approved during the 12-month period ended March 31, 2025. The approval
  population was not stratified. The SBA determined the appropriate total sample size to be 219 loans
  from the population. The sample included net approval outlays of $501,711,000 and improper payments
  of $23,253,500 within the sample. Using the Hansen-Hurwitz estimation method, the estimated
  improper payments rate for the annual period ending March 31, 2025, was calculated as 4.58%.

  The improper payment rate for 504 loan approvals in FY 2024 was 3.74 percent, and the unknown
  payment rate was 0.39 percent. The estimated improper payment rate, including unknown payments
  for FY 2024, was 4.54 percent, consistent with the estimated improper payment rate for FY 2025, and
  within the established tolerance band for improper payments. While nominal, the increase in the
  improper payment rate can be attributed to ineligible project structures, borrower eligibility, and
  analysis of borrower’s repayment ability.

  Tolerable Rates and Reduction Targets

  Guidance in Appendix C to OMB Circular A-123 states that “… agency leaders can set Risk Tolerance
  bands for IPs (Improper Payments) … for each program.”

  Prior to the FY 2025 improper payment testing cycle, SBA established a risk tolerance band for 504
  Certified Development Loan Approval Program FY 2025 improper payments. The risk tolerance band
  for this program is 3.96 percent to 10.00 percent. In compliance with SBA’s established processes, the
  Agency conducted the required annual assessment of the established tolerable improper payment
  range, concluding the existing risk tolerance band to be adequate with no recommended revisions
  for FY 2026. In addition to the risk tolerance band re-evaluation, the SBA has also established a target
  reduction rate for this program of 4.56 percent.

  Improper Payment Reviews

  The 504 Certified Development Loan Approval reviews were conducted to determine whether CDCs
  complied materially with the program’s origination requirements, including statutory provisions, SBA
  regulations, any agreement the CDC executed with the SBA, standard operating procedures, loan
  authorizations, and official SBA notices and forms applicable to the 504 loan program. The reviews



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  were conducted to determine whether CDCs (1) originated the loans in a prudent and commercially
  reasonable manner, (2) misrepresented or failed to disclose a material fact to the SBA, and/or (3) put
  the SBA’s financial interest at risk.

  504 Loan Approval PIIA reviews are conducted after the time of loan approval but usually prior to
  disbursement. At the time of loan approval, no monies are disbursed. Improper payments identified
  during loan review result in no monetary loss to the government.

  Actions to Improve Payment Integrity

  The SBA revised its 7(a) Lender and Developing Company Loans Standard Operating Procedure
  (SOP) in August of 2023 and issued a second revision in November of 2023. To improve payment
  integrity, the SBA provided training on the revised SOP – the SOP in effect during the FY 2025
  improper payment testing cycle - to lenders prior to issuance and continued providing quarterly
  training while this SOP remained in effect.

  The SBA updated its 7(a) Lender and Developing Company Loans SOP in 2025, largely re-implementing
  requirements that were in place before January 2021, including restoring 7(a) underwriting criteria,
  reinstituting the SBA Franchise Directory with streamlined procedures, re-affirming that SBA Lenders
  determine whether the Applicant is eligible for a loan guaranteed by SBA, and eliminating the “do
  what you do” philosophy from the SOP. This SOP became effective in June 2025 and will apply to 504
  Loan Approvals in the FY 2026 improper payment testing cycle. To improve payment integrity, the SBA
  provided training on the updated SOP prior to issuance and continues to provide quarterly training. The
  SBA also provides additional training on specific topics throughout the year.

  Root Cause and Corrective Action

  504 Guaranty Approval PIIA reviews are conducted after loan approval but usually prior to
  disbursement. These loans are generally made to the right recipient for the right amount, but
  CDCs failed, in the approval process, to follow all statutes, regulation, and SBA Loan Program
  requirements. In these cases, there is no amount that needs to be recovered. However, because the
  CDC lender failed to adhere to all applicable statutes, the loan is considered technically improper.

  The predominant reasons for 504 Loan Approval improper payments in FY 2025 were (1) CDCs’ failure to
  ensure borrowers adhered to all regulations include confirmation of legal residency status (2) CDC failed
  to properly exercise its delegated authority; (3) CDCs’ failure to adequately address all collateral concerns.

  The root cause categories established by the OMB are: (1) Statutory Requirements of Program
  Were Not Met; (2) Unable to Determine Whether Proper or Improper; (3) Data/Information Needed
  Does Not Exist; (4) Inability to Access Data/Information; and (5) Failure to Access Data/ Information.
  Because the improper payments for these 504 approvals are technically improper, the OMB root
  cause is identified as Statutory Requirements of Program Were Not Met.

  To reduce or eliminate the occurrence of future improper payments, a Corrective Action Plan has
  been formalized for the 504 approval center. Specific corrective actions are determined based upon
  the primary reason for the improper payment with the purpose of both remedying the improper
  payment and preventing recurrence.




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  Plans for improvement include the following:

  •     Collaborating with the Office of Credit Risk Management (OCRM) to recommend that specific
        lender deficiencies be monitored and incorporated into Risk Based Reviews;

  •     Collaborating with the Office of Financial Assistance (OFA) to inform the office of deficiencies
        identified for potential incorporation into policy, regulatory, or standard operating procedure
        rewrite or update; and

  •     Conducting external training for lenders to ensure that appropriate documentation is obtained
        and analyzed prior to loan approval that policy requirements are met.

  The corrective actions are currently in process. The SBA will continue to share the loan level and
  lender deficiencies identified during the reviews with the OFA and the OCRM. The SBA will also
  continue its efforts to ensure that CDC deficiencies are monitored.

  Because 504 loans are usually reviewed prior to monies being disbursed, resolution of an identified
  improper payment is usually through obtaining additional documentation from the CDC to
  remedy the potential improper payment or through cancellation of the loan. There is no monetary
  outlay at approval, and thus no loss to the Federal Government. Specific corrective actions on
  loans reviewed are tracked at the loan level through a centralized database. The Quality Control
  Specialist for 504 approvals monitors errors from identification through completion of the corrective
  action. Management provides oversight to ensure that milestones are met. All improper payments
  identified as a result of the FY 2025 PIIA reviews have been resolved through obtaining additional
  documentation, loan modification, or cancellation of the loan authorization. Corrective actions were
  generally completed at the loan level within 180 days.
  Disaster Assistance Loans

  Disaster assistance loans provide low-interest loans to help businesses and homeowners recover from
  declared disasters. Disaster assistance is available to all businesses located within a declared disaster
  area, private non-profit organizations, homeowners, and renters affected by declared disasters. Disaster
  assistance loans can be used to pay for personal or business losses not covered by insurance or funding
  from other government agencies, as well as for business operating expenses that could have been met
  had the disaster not occurred. The Disaster Assistance Loan Program is a direct loan program, meaning
  that the SBA approves and makes the loans and there are no intermediary lenders.

  The Disaster Assistance Loan Program reviews for improper payments were conducted to determine
  whether loans were materially in compliance with SBA guidance, including determining whether
  borrowers were eligible for the disaster assistance loan, whether the amount approved was correct,
  whether the loan was made in accordance with existing regulations, SOPs and other internal guidance.

  Statistical Sampling

  For Disaster Disbursement reviews, the sample cases were chosen using PPS Sampling with
  replacement from all loan disbursements processed during the 12-month period ended March 31,
  2025. The disbursement population was divided into three strata based on the loan type: home
  loans, business physical loans, and economic injury and disaster (EIDL) loans. The SBA determined



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  the appropriate total sample size to be 241 loans from the population. The sample included net
  disbursements of $34,630,721 and improper payments of $1,998,232 within the sample. Using the
  Hansen-Hurwitz estimation method, the estimated improper payments rate for the annual period
  ending March 31, 2025, was calculated as 4.87%.

  The improper payment rate in FY 2024 was 3.62 percent. The increase in the improper payment rate
  from FY 2024 to FY 2025 were largely the result of improperly assessed closing fees on loans.

  Tolerable Rates and Reduction Targets

  Guidance in Appendix C to OMB Circular A-123 states that “… agency leaders can set Risk Tolerance
  bands for IPs (Improper Payments) … for each program.”

  Prior to the FY 2025 improper payment testing cycle, SBA established a risk tolerance band for the
  Disaster Assistance Loan Program for FY 2025 improper payments. The risk tolerance band for this
  program is 3.96 percent to 10.00 percent. In compliance with SBA’s established processes, the Agency
  conducted the required annual assessment of the established tolerable improper payment range,
  concluding the existing risk tolerance band to be adequate with no recommended revisions for FY
  2026. The SBA will assess the adequacy of this risk tolerance band annually. In addition to the risk
  tolerance band re-evaluation, the SBA has also established a target reduction rate for this program of
  4.25 percent.

  Actions to Improve Payment Integrity

  The SBA is instituting an updated SOP 50 30, disaster assistance program, that streamlines the
  disaster lending process. Processing automation through the Unified Lending Platform, coupled with
  the streamlined SOP, specifically addresses the most prevalent causes of improper payments.

  Root Cause and Corrective Action

  Disaster assistance loan samples are selected from loan disbursements. A disaster assistance loan
  may have several disbursements before it is disbursed in full. During the loan review process, the
  SBA reviews the original loan processing and underwriting, any loan modifications, such as increases
  in the loan amount or additional borrowers, to determine eligibility of the borrower and whether
  the amount is appropriate. The SBA also verifies that the amount of loan is commensurate with the
  amount of damage. Finally, the SBA reviews the actual disbursement to determine that the monies
  are provided to the right person, in the right amount, and for an eligible use of proceeds.

  The root cause categories established by the OMB are: (1) Statutory Requirements of Program Were
  Not Met; (2) Unable to Determine Whether Proper or Improper; (3) Data/Information Needed Does
  Not Exist; (4) Inability to Access Data/Information; and (5) Failure to Access Data/ Information. The
  root cause of improper payments in the Disaster Assistance Loan program was Failure to Access
  Data/Information and Statutory Requirements of Program Were Not Met. The prevalent causes of
  improper payments stemmed from fees charged for secured loans contrary to the Code of Federal
  Regulations (CFR), duplication of benefits not adequately addressed, and improper calculation or
  determination of economic injury eligibility.

  During FY 2025, Disaster Lending Operations Division (DLOD) utilized the new Unified Lending



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  Platform (ULP) to facilitate loan closings for disaster survivors, aiming to streamline the process and
  reduce burden. It was subsequently identified that the DLOD was not authorized to charge fees under
  the Code of Federal Regulations (CFR). In response, a corrective action was implemented in February
  2025, providing disaster survivors the option to either close the loan themselves or authorize the
  Agency to do so on their behalf, thereby ensuring compliance with 13 CFR 123.8.
  Paycheck Protection Program (PPP)

  The CARES Act established the Paycheck Protection Program (PPP) loans to provide economic relief
  to small businesses and incentivize small businesses to keep their workers on the payroll because of
  the COVID-19 pandemic. The SBA separated PPP into three payment integrity reporting categories –
  PPP Approvals, PPP Forgiveness, and PPP Purchases. PPP ended in May 2021. Although no new PPP
  funds are being disbursed, borrowers may still request forgiveness for a PPP loan, and lenders may
  request guaranty purchase of a PPP loan. The SBA is reporting under PIIA on these aspects of the
  program.
  Paycheck Protection Program (PPP) Loan Forgiveness

  PPP loans can be forgiven if the funds are used for payroll costs, interest on mortgages, rent, utilities,
  or other eligible expenses. A borrower can apply for forgiveness once all loan proceeds for which
  the borrower is requesting forgiveness have been used. Borrowers can apply for forgiveness at any
  time for up to 5 years from the date that SBA issued the loan number. If borrowers do not apply for
  forgiveness within 10 months after the last day of the covered period, then PPP loan payments are no
  longer deferred, and borrowers will begin making loan payments to their PPP lender.

  PPP loan forgiveness requests were submitted via SBA’s forgiveness platform and, although the
  lenders and borrowers were required to retain supporting documentation, they were not required to
  submit that documentation to the SBA. In FY 2024, SBA requested supporting documentation from
  lenders in order to review the propriety of PPP forgiveness samples. The SBA reviewed samples to
  determine whether the borrower was eligible for an SBA loan under 13 CFR 120.110, and whether the
  borrower met all other regulatory criteria for a PPP loan.

  Statistical Sampling

  For Paycheck Protection Program (PPP) Forgiveness reviews, the sample cases were chosen using
  PPS Sampling with replacement from all forgiveness outlays processed during the 12-month period
  ended March 31, 2025. The forgiveness population was divided into three strata based on the lender
  type: 1) Bank lender, 2) State Regulated Finance Company lender, and 3) All Other lender types. The
  SBA determined the appropriate total sample size to be 412 loans from the population. The sample
  included aggregate forgiveness outlays of $426,436,779 and an absolute value of improper payments
  of $14,656,755 within the sample. Using the Hansen-Hurwitz estimation method, the estimated
  improper payment rate for the PPP Purchase population is 19.04 percent for the annual period
  ending March 31, 2025.

  In FY 2024, the PPP Loan Forgiveness improper payment rate was 21.09 percent, and the unknown
  payment rate was 4.06 percent.




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  Reduction Targets

  The SBA has set a reduction target for PPP Loan Forgiveness at 10.0 percent, the statutory
  compliance limit, for FY 2025. Meeting this reduction target will also bring this program into
  compliance with the PIIA.

  Root Cause and Corrective Action

  PPP Loan Forgiveness payments are reviewed after the forgiveness has been paid to the borrower.
  Borrower and lender documentation is reviewed to determine whether the borrower was eligible,
  whether the loan was free of “hold” codes, and whether required documentation was completed and
  accurate. The SBA also reviewed forgiveness payments to determine whether the loan amount was
  documented and calculated correctly.

  The predominate reasons for improper payments in PPP Loan Forgiveness were missing or
  incomplete documentation, and borrower and lender errors in calculation.

  The root cause categories established by the OMB are: (1) Statutory Requirements of Program Were
  Not Met; (2) Unable to Determine Whether Proper or Improper; (3) Data/Information Needed Does
  Not Exist; (4) Inability to Access Data/Information; and (5) Failure to Access Data/ Information. The
  root cause of these overpayments was Failure to Access Data.

  Corrective actions to address the improper payments identified may include, but are not limited to,
  the following: (1) implementing a quality control review process and/or (2) internally escalating the
  loan review of a loan for a loan review decision.
  Paycheck Protection Program (PPP) Loan Guaranty Purchases

  If a PPP loan is not forgiven, the SBA may purchase (honor) all or part of the PPP loan guaranty.
  Lenders may request that the SBA purchase the guaranty of a PPP loan in the event of a default or
  other qualifying event. A lender must have made certain certifications about the loan and supporting
  information. The SBA reviews the lender’s request for guaranty purchase and charge-off in
  accordance with PPP Loan Program requirements. The SBA will honor its guaranty and will purchase
  100 percent of the outstanding balance of the loan provided that the lender has complied with all
  PPP Loan Program requirements.

  PPP Loan Guaranty Purchase requests were submitted via SBA’s PPP platform and, although the lenders
  were required to retain supporting documentation, they were not required to submit that documentation
  to the SBA. The SBA requested documentation from lenders for those guaranty purchases that were a
  part of the sample. PPP guaranty purchase samples were reviewed to determine whether the lender was
  eligible to receive a loan guaranty payment; whether the lender received required borrower certifications;
  and whether the PPP loan met all statutory, regulatory, and internal requirements for payment.

  Statistical Sampling

  For Paycheck Protection Program (PPP) Purchase reviews, the sample cases were chosen using
  PPS Sampling with replacement from all purchases processed during the 12-month period ended
  March 31, 2025. The purchase population was divided into three strata based on the lender type:



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  1) Bank lender, 2) State Regulated Finance Company lender, and 3) All Other lender types. The SBA
  determined the appropriate total sample size to be 408 loans from the population. The sample
  included aggregate purchase outlays of $236,626,898 and an absolute value of improper payments
  of $16,093,240 within the sample. Using the Hansen-Hurwitz estimation method, the estimated
  improper payment rate for the PPP Purchase population is 5.17 percent for the annual period ending
  March 31, 2025.

  In FY 2024, the PPP Loan Guaranty Purchase improper payment rate was 24.47 percent and the
  unknown payment rate was 0.25 percent. Improper payments were largely due to lack of supporting
  documentation due to time constraints. The FY 2025 estimated improper payment rate for PPP Loan
  Guaranty Purchases shows a significant reduction in improper payments and improvement in the
  program’s payment integrity. The program both met the previously established reduction target of 10
  percent and has brought the program into compliance with PIIA.

  Reduction Targets

  The SBA has set a reduction target for PPP Loan Guaranty Purchase at 5.17 percent, which anticipates
  the program remaining in compliance with PIIA.

  Root Cause and Corrective Action

  PPP Loan Guaranty Purchase payments are reviewed after the guaranty has been paid to the lender.
  Borrower and lender documentation is reviewed to determine whether the lender is eligible, and
  whether the amount of guaranty purchase request equaled the amount in SBA systems. The SBA
  also verifies that the lender received borrower certifications, including whether the borrower had
  been in business on or around February 20, 2020. The SBA also checked that the eligible payroll was
  accurately accounted for.

  The predominate reasons for improper payments in PPP Loan Guaranty Purchases were (1) lender’s
  failure to verify that the borrower was in business on February 20, 2020; (2) lender’s failure to verify
  average monthly payroll; and (3) unacceptable or missing identification of the borrower.

  The root cause categories established by the OMB are: (1) Statutory Requirements of Program Were
  Not Met; (2) Unable to Determine Whether Proper or Improper; (3) Data/Information Needed Does
  Not Exist; (4) Inability to Access Data/Information; and (5) Failure to Access Data/ Information. The
  root cause of these overpayments was Failure to Access Data.

  To recover PPP Loan Guaranty improper payments, the SBA will use processes similar to the process
  used for its 7(a) guaranty purchase portfolio, which begins with demanding repayment from the lender.
  Section 1112 Payments

  Section 1112 of the CARES Act authorized the SBA to provide temporary debt relief to eligible
  borrowers in the 7(a), 504, and Microloan programs by making principal, interest, and fee payments
  on their behalf. This authority was time-limited, and all appropriated funding for the Section 1112
  program has been fully expended. As a result, SBA no longer administers or disburses payments
  under this program. Accordingly, this reporting period represents the final year in which SBA is
  conducting payment integrity review and reporting for Section 1112 payments.



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  Statistical Sampling

  For Section 1112 reviews, sample cases were chosen using Probability Proportional to Size (PPS)
  with Replacement sampling against the population of all disbursements processed during the period
  April 1, 2020, through March 31, 2025. This population was divided into three strata based on their
  program type: 7(a), 504, and Microloan. The SBA determined the appropriate total sample size to be
  386 loans from this population. The samples selected from the population totaled $4,673,849. The
  results of sample review identified improper payments totaling $12,989. Using the Hansen-Hurwitz
  estimation method, the estimated improper payments rate for the entire Section 1112 population
  was calculated as 0.34%. The SBA did not identify any unknown payments for Section 1112.

  Reduction Targets

  Authority under the Section 1112 Payment program was authorized under Section 1112 of the CARES
  Act and has since expired with all appropriated funds expended. FY 2025 improper payment rate
  estimates encompassed all disbursements for the program. There was no funding for this program in
  FY 2025, no disbursements will be made in FY 2026, and therefore no improper payment rates will be
  extrapolated. Further, the SBA has not set a reduction target, as this program has ended.

  Actions to Improve Payment Integrity

  All funding for this program has been expended. The SBA has not planned any actions to improve
  program integrity that are specific to this program.
  Shuttered Venue Operators Grant Program (SVOG)

  The Shuttered Venue Operators Grant program was established by the Economic Aid to Hard-Hit
  Small Businesses, Nonprofits, and Venues Act (also known as the Economic Aid Act) on December
  27, 2020, to offer critical assistance to qualifying venues and performing arts entities impacted by the
  COVID-19 pandemic. The SVOG program commenced with an appropriation of $15 billion under the
  Economic Aid Act and an additional allocation of $1.2 billion through the American Rescue Plan Act
  on March 11, 2021. Collectively, the SVOG program was allocated a total of $16.2 billion.

  Administered by the Small Business Administration’s (SBA) Office of Disaster Recovery and Resilience
  (ODR&R), the Shuttered Venue Operators Grant provided emergency assistance to ensure the
  sustainability of eligible live venues, promoters, theatrical producers, talent agents, live performing
  arts organizations, museums, and film theaters during economic conditions caused by COVID 19
  pandemic.

  Statistical Sampling

  The first SVOG disbursement occurred on May 27, 2021. The last SVOG disbursement occurred
  on December 19, 2022. For SVOG reviews, sample cases were chosen using PPS sampling with
  replacement from all SVOG disbursements within the sampling timeframe of April 1, 2021, through
  March 31, 2024, to ensure that all disbursements processed were included. This population was
  divided into six strata based on business type: live performing arts organization operators, live venue
  operators or promoters, motion picture theater operators, museum operators, talent representatives,
  and theatrical producers.



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  The SBA determined the appropriate total sample size to be 547 loans from this population. The
  sample included net approval outlays of $1,779,696,434 and improper payments of $837,260,308
  within the sample. Using the Hansen-Hurwitz estimation method, the estimated improper payments
  rate for the entire SVOG population was calculated as 39.90 percent. Using the Hansen-Hurwitz
  estimation method, the estimated unknown payments rate for the entire SVOG population was
  calculated as 29.05 percent.

  Reduction Targets

  The last SVOG disbursement occurred on December 15, 2022. FY 2025 improper payment rate
  estimates encompassed all disbursements for the program; therefore, no improper payment rates
  will be extrapolated. Further, the SBA has not set a reduction target, as there are no additional
  disbursements in this specific program.

  Actions to Improve Payment Integrity

  The last SVOG disbursement occurred on December 15, 2022. Overpayments identified in the improper
  payments’ reviews are subject to recovery efforts. Determination of a course of action is made on a
  case-by-case basis, depending on the specific details of the reason for the improper payment.

  Root Cause and Corrective Action

  The root cause categories established by OMB are: (1) Statutory Requirements of Program Were Not
  Met (SR); (2) Unable to Determine Whether Proper or Improper (UD); (3) Data/Information Needed
  Does Not Exist (DI); (4) Inability to Access Data/Information (IA); and, (5) Failure to Access Data/
  Information (FA).

  The predominant root cause identified for the Shuttered Venue Operators Grant (SVOG) program is
  Statutory Requirements of Program Were Not Met. The disbursements categorized under this root
  cause pertain to instances where the Principal Business Activity did not align with the established
  statutory guidelines. Furthermore, the completion of closeout requirements was not executed in
  accordance with statutory provisions.

  The second root cause identified relates to the Failure to Access Data/Information. Disbursements
  within this category resulted from the SBA’s inability to obtain critical documentation when assessing
  eligibility, as well as accessing essential documents required for calculating revenue and/or grant
  award amounts.

  To mitigate the occurrence of improper future payments and identify overpayments, SBA will
  implement the following corrective actions:

  •     Train staff to address procedural inconsistencies.

  •     Obtain and analyze appropriate eligibility documentation to ensure that policy requirements are met.

  •     Identify deficiencies for potential incorporation into policy, regulatory, or standard operating
        procedure rewrites or updates.

  •     Review improper payments for recoupment.



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  The FY 2025 Unknown Payment (UP) estimate rate is 29.052 percent. The root causes of the
  “Unknown Payment” were identified as: (1) A lack or insufficiency of eligibility documentation to
  determine whether the payment was proper or improper, (2) The Agency did not complete the
  required cost compliance monitoring, which would have identified if the payment was utilized
  according to statutory requirements, and (3) The closeout requirement for the grant has not been
  fulfilled. Unknown payments require further investigation and resolution to ensure the proper
  allocation of resources and maintain the integrity, efficiency, and compliance of the program with
  established guidelines and regulations.

  SBA’s approach to resolving the identified unknown payments is to employ corrective actions that
  efficiently prioritize resources and maintain the program’s integrity. SBA will implement corrective
  actions to include, but are not limited to:

  •     Uploading the necessary eligibility documentation such as LexisNexis reports, Audit reports, etc.

  •     Completing the Cost Compliance Monitoring events.

  •     Finalizing the closeout process.
  Payment Recovery Effort

  The SBA makes every effort to recover improper payments identified during their improper payment
  review process. This recovery effort is independent of the recapture audit process, which can be
  deemed costly and ineffective. The Agency’s efforts to recapture improper payments are discussed
  by program or activity below.
  7(a) Loan Guaranty Purchases

  Overpayments identified in the improper payments’ reviews are recaptured from the lender. The
  Quality Control staff tracks and collects any monetary overpayment. In some instances, the loan is
  referred to the Guaranty Review Team for further action. Determination of a course of action is made
  on a case-by-case basis, depending on the specific details of the reason for the improper payment.
  Refer to section above for corrective action plans to prevent future improper payments.
  7(a) Loan Guaranty Approvals and 504 Certified Development Loans Approvals

  Overpayments recaptured outside payment recapture audits are not applicable to 7(a) loan guaranty
  approvals and 504 certified development loans approvals as no payments are made at the time
  of approval. Improper payments identified through the annual improper payment reviews for the
  7(a) loan guaranty approvals program and 504 certified development loans approvals program are
  resolved through obtaining additional documentation, loan modification, or cancellation of the loan.
  Improper payments identified as a result of the FY 2025 PIIA reviews have been resolved through
  obtaining additional documentation, or cancellation or reduction of the loan guaranty and/or referral
  to other offices within the Office of Capital Access, as appropriate. Determination of a course of
  action is made on a case-by-case basis, which varies substantially depending on the circumstances
  of the loan approval and lender’s authority.




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  Disaster Direct Loan Program

  Overpayments are the result of the borrower receiving both an SBA loan and insurance payments or
  other benefits as a result of the disaster. If the duplication of benefit is recognized prior to the final
  disbursement, the loan amount is modified to reflect a lower amount and no repayment is required.
  If the duplication of benefit is identified after the final disbursement of the loan, then the borrower is
  given 30 days to provide evidence to prove that the disaster loan was not over-disbursed. Collection
  efforts continue at the disaster loan servicing centers, but if these efforts fail, the borrower will still be
  liable for the over-disbursed amount in the form of monthly payments in accordance with the loan
  agreement. Thus, any actual loss is the cost of funds related to the over-disbursement.
  Paycheck Protection Program Loan Forgiveness

  If the SBA determines that the borrower was ineligible for the loan amount or used PPP loan
  proceeds for unauthorized uses, the SBA may seek repayment of part or all of the outstanding PPP
  loan balance or pursue other available remedies. If the SBA uncovers information that indicates
  that the borrower made a material misstatement of fact or provided a false certification, before
  or after the SBA remits a forgiveness payment to the lender, the SBA may seek repayment of the
  outstanding PPP loan balance, refer the borrower to SBA Office of Inspector General (OIG), or pursue
  other available remedies. Further, if the SBA determines that the loan is not eligible for forgiveness (in
  whole or in part), the borrower must begin paying principal and interest.
  Paycheck Protection Program Loan Guaranty Purchases

  If the SBA determines that the guaranty purchase was not in accordance with PPP Loan Program
  requirements, SBA will request that the lender repay the guaranty purchase funds. In some instances,
  the loan may be referred to the Guaranty Review Team for further action. Determination of a course
  of action is made on a case-by-case basis, depending on the specific details of the reason for the
  improper payment.
  Shuttered Venue Operators Grant Program

  The last SVOG disbursement occurred on December 15, 2022. Overpayments identified in the improper
  payments’ reviews are subject to recovery efforts. Determination of a course of action is made on a
  case-by-case basis, depending on the specific details of the reason for the improper payment.
  Payment Recapture Audits

  The SBA conducts cost-benefit analyses, as needed, for programs with over $1 million in
  disbursements and not covered by a similar cost-benefit analysis completed in prior years. Some
  of the factors considered include the following: program was not identified as being susceptible to
  significant improper payments in the last risk assessment, there have been no recent audit findings
  or reports to suggest that the program is susceptible to improper payments, prior internal control
  assessments did not identify the program as being susceptible to significant improper payments,
  and the cost to perform a recovery audit exceeded the potential recovery amount.

  Currently, there are costs-benefit analyses for the following programs: 7(a) Business Loan Guaranty
  Program, the 504 Certified Development Company Loan Guaranty Program, the administrative



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  payroll disbursements, the administrative travel disbursements, the Boots to Business Program, the
  Community Navigators Pilot Program, the COVID-19 EIDL program, the Disaster Direct Loan Program,
  Disbursements for Goods and Services, the COVID-19 EIDL Advance program, Grants (which included
  all grant programs), the Growth Accelerator Fund Competition Program, the Microloans program,
  the OED’s Resource Partners Training Portal, the Paycheck Protection Program, the Prime Technical
  Assistance Grants Program, the SCORE Program, the Shuttered Venue Operators Grant Program, the
  Small Business Development Center Program, the Small Business Investment Company Financing
  Guaranty Program, the State Trade Expansion Program (STEP), the Surety Bond Guarantee Program,
  and the Veterans Business Outreach Program.

  In FY 2025, the SBA did not conduct any recovery audits. As mentioned above, in prior years, the
  SBA has conducted cost-benefit analyses on programs subject to payment recapture audit, and
  the Agency deemed the costs to perform a payment recapture audit outweighed the benefits of the
  audit. Although a payment recapture audit is not conducted, the SBA makes every effort to recover
  any improper payments identified through the improper payment review process or other internal
  review process.
  Agency Improvement of Payment Accuracy with the Do Not Pay Initiative

  The SBA has implemented the Do Not Pay Initiative (DNP) and incorporated the use of the DNP by
  submitting all programmatic disbursements through the DNP portal. If anomalies are identified,
  the SBA takes corrective actions to remedy the anomalies. For disbursements that have not
  been disbursed to the recipient, the SBA requires the recipient to resolve the DNP finding prior
  to becoming eligible for SBA funding. For disbursements that have already be disbursed to the
  recipient, the SBA would place a hold code on the loan or grant and/or deny future loan or grant
  requests or loan relief requests until the recipient was able to successfully resolve the DNP finding.




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  Summary of Financial Statement Audit and
  Management Assurances
  As required by OMB Circular A-136, Section II.4.1, the following summarizes the SBA’s Financial State-
  ment Audit and Management Assurances:

  SUMMARY OF FINANCIAL STATEMENT AUDIT
   Audit Opinion                                       Disclaimer
   Restatement                                         No

   Material                          Beginning                                                    Ending
                                                 New        Resolved       Consolidated
   Weaknesses                         Balance                                                     Balance

   Controls over PPP
                                         1        0              0                0                     1
   Loan Program

   Controls over
                                         1        0              0                0                     1
   COVID-19 EIDLs

   Controls over Subsidy
                                         1        0              0                0                     1
   Reestimate
   Controls over the
   Evaluation of Service                 1        0              1                0                     0
   Organizations

   Entity Level Controls                 1        0              0                0                     1

   Controls over
   Restaurant
                                         1        0              1                0                     0
   Revitalization and
   Shuttered Venues
   Controls over
   General Information                   1        0              1                0                     0
   Technology
   Total Material
                                         7        0              3                0                     4
   Weaknesses




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  SUMMARY OF MANAGEMENT ASSURANCES

   Effectiveness of Internal Control over Financial Reporting (FMFIA § 2)

   Statement of
                                     Modified
   Assurance
   Material                          Beginning                                                    Ending
                                                 New   Resolved Consolidated Reassessed
   Weaknesses                         Balance                                                     Balance

   Controls over PPP
                                         1        0       0          0               0                 1
   Loan Program

   Controls over
                                         1        0       0          0               0                 1
   COVID-19 EIDLs

   Controls over
                                         1        0       1          0               0                 0
   Subsidy Reestimate
   Controls over the
   Evaluation of Service                 1        0       1          0               0                 0
   Organizations

   Entity Level Controls                 1        0       0          0               0                 1

   Controls over
   Restaurant
                                         1        0       1          0               0                 0
   Revitalization and
   Shuttered Venues
   Controls over
   General Information                   1        0       1          0               0                 0
   Technology
   Total Material
                                         7        0       4          0               0                 3
   Weaknesses




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   Effectiveness of Internal Control over Operations (FMFIA § 2)

   Statement of
                                     Modified
   Assurance
   Material                          Beginning                                                        Ending
                                                 New     Resolved Consolidated Reassessed
   Weaknesses                         Balance                                                         Balance

   None                                  0         0        0            0               0                 0


   Total Material
                                         0         0        0            0               0                 0
   Weaknesses




   Conformance with Financial Management System Requirements (FMFIA § 4)

   Statement of                      Federal Systems do not conform to financial management system
   Assurance                         requirements.
   Non-Conformanc-                   Beginning                                                        Ending
                                                 New     Resolved Consolidated Reassessed
   es                                 Balance                                                         Balance
   Federal Financial
   Management
                                         1         0        1            0               0                 0
   System
   Requirements
   Federal Accounting
                                         1         0        1            0               0                 0
   Standards

   Total Non-
                                         2         0        2            0               0                 0
   conformances




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   Compliance with Section 803(a) of the Federal Financial Management Improvement Act
   (FFMIA)

                                                      Agency                  Auditor

   1. Federal Financial Management System             No lack of compliance Lack of compliance
      Requirements                                    noted                 noted

                                                      No lack of compliance Lack of compliance
   2. Applicable Federal Accounting Standards
                                                      noted                 noted

                                                      No lack of compliance No lack of compliance
   3. USSGL at Transaction Level
                                                      noted                 noted

  The auditor identified a material weakness related to Controls over the Subsidy Reestimate. Manage-
  ment acknowledges the conditions but has concluded that one of the conditions is encompassed
  within SBA’s existing material weaknesses related to controls over COVID-19 EIDLs and controls over
  the PPP loan program. Because the root causes and corrective actions overlap, SBA management
  does not classify this as a separate material weakness. Management concluded that the remaining
  condition does not rise to the level of a material weakness.

  The auditor identified instances of noncompliance with FFMIA Federal Financial Systems Require-
  ments and Federal Accounting Standards. SBA management’s assessment did not identify any FFMIA
  noncompliance. SBA management believes the deficiencies identified by the auditor were related to
  factors external to the financial management systems.

  SBA remains committed to constructive engagement to resolve these matters and will continue to
  evaluate auditor identified material weaknesses and implement suggested recommendations where
  applicable.




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  Grants Programs
  In accordance with Federal reporting requirements, this report includes a high-level summary of
  expired, but not closed, Federal grants and cooperative agreements. The summary table below
  shows the total number of awards and balances for which closeout has not yet occurred, but for
  which the period of performance has lapsed by two years or more prior to September 30, 2025.

                                                                                            More than 5
   Category                                             2-3 Years        3-5 Years
                                                                                              Years
    Number of Grants/Cooperative Agreements
                                                                 172              209                          1
    with Zero Dollar Balances
    Number of Grants/Cooperative Agreements
                                                                    95            131                          1
    with Undisbursed Balances

    Total Amount of Undisbursed Balances            $   2,212,870.00 $ 10,413,866.00 $                       11


  The SBA works to continuously improve its grants management process and manage risk. The
  Agency used the following procedures to assess risk in the Agency’s grant closeout process and
  improve closeout rates:
  •     Evaluating the nature and type of grants issued to recipients;

  •     Examining Agency policy and procedures related to grant closeout; and

  •     Reviewing the consistency of procedures with federal regulation, industry standards, and other
        guidance, including but not limited to evaluating the complexities of procedures in the grant
        closeout process, assessing the population of expired grant accounts, reviewing information
        systems used to process grant data, assessing challenges, and assessing internal controls.

  To maintain 100 percent accuracy in the closeout rate, the Agency developed a second-tier approval
  mechanism to ensure that all grant awards are in compliance and are accurately closed in its grants
  management information technology systems. The closeout team reviews the status of grants
  regularly, including the number of grants by period of expiration, the number with zero-dollar
  balances, and the number with undisbursed balances.




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  Civil Monetary Penalty Adjustment for
  Inflation
  The Federal Civil Penalties Inflation Adjustment Act of 1990 (Act), as amended, requires agencies
  to make regular and consistent inflationary adjustments of civil monetary penalties to maintain
  their deterrent effect. A civil monetary penalty is defined as any penalty, fine, or other sanction that
  is for a specific monetary amount as provided by federal law or has a maximum amount provided
  for by federal law, is assessed or enforced by an agency pursuant to federal law, and is assessed or
  enforced pursuant to an administrative proceeding or a civil action in the federal courts. To improve
  compliance with the Act and in response to multiple audits and recommendations, agencies must
  report the most recent inflationary adjustments to civil monetary penalties to ensure that penalty
  adjustments are both timely and accurate. Pursuant to the Act, the SBA reviewed each of the penalty
  amounts under its statutes and adjusted them for inflation when required under the law. The SBA
  applied a prescribed formula from the Act for calculating the penalty.

  The following table reflects the authorities imposing the penalties, the basis for imposing the
  penalties, the year the penalties were authorized, the current penalty levels, the program offices
  responsible for imposing the penalties, and the citation for the most recent publication of the
  penalty updates.




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  (Dollars in Thousands)

   SBA FEDERAL CIVIL PENALTIES

                                                                             Latest Year of    Current
                                                                                                                                      Location for
                                     Penalty (Name or                        Adjustment        Penalty Level Sub- Agency/
   Statutory Authority                                        Year Enacted                                                            Penalty Update
                                     Description)                            (via Statute or   ($ Amount or Bureau/ Unit
                                                                                                                                      Details
                                                                             Regulation)       Range)

                                     Failing to File Report
   Small Business                                                                                                    Office of
                                     Timely for a Small                                                                                  90 F.R. 23422-
   Investment Act, 15                                             1966            2025         $          332    Investment and
                                     Business Investment                                                                                 23423 (6/3/25)
   USC 687g                                                                                                        Innovation
                                     Company (SBIC)


                          Failing to File Report
   Small Business Act, 15 Timely for a Small                                                                     Office of Capital        90 F.R. 23423
                                                                  2004            2025         $        8,267
   USC 650(j)(1)          Business Lending                                                                            Access                (6/3/25)
                          Company (SBLC)


                                                                                                                    Office of
   Small Business Act, 15 Types of Formal                                                                                                 90 F.R. 23423
                                                                  2020            2025         $      306,652      Credit Risk
   U.S.C. 657t(e)(2)(B)   Enforcement Actions                                                                                               (6/3/25)
                                                                                                                  Management


   Small Business Act,
                                     Administrative
   15 USC 634(b)(6) and
                                     Remedies for False                                                                                   90 F.R. 23423
   Program Fraud Civil                                            1986            2025         $       14,308    Multiple offices
                                     Statements and                                                                                         (6/5/25)
   Remedies Act 31 USC
                                     Claims
   3802(d)

   Small Business Act,
                                                                                                 not less than
   15 USC 634(b)(6) and              Penalty for Violation
                                                                                               $ 25,132 and                                90 F.R. 234
   Program Fraud Civil               of Lobbying                  1990            2025                           Multiple offices
                                                                                               not more than                                (6/3/25)
   Remedies Act 31 USC               Restrictions
                                                                                               $       251,322
   1352




U.S. Small Business Administration                                                                                         Agency Financial Report Fiscal Year 2025 194
SECTION 4




Appendices
            (UNAUDITED)
                                                                                           Appendices (Unaudited)



  Appendix 1 – Contact SBA: Useful Websites
  and Phone Numbers
  The SBA home page is www.sba.gov. Information on SBA programs may be accessed from this
  website. Several of the more frequently visited websites are listed here:

  SBA AND BUSINESS INFORMATION
  About the SBA                            www.sba.gov/about-sba
  SBA Performance, Budget & Finances       www.sba.gov/performance
  Small Business USA                       www.usa.gov/business
  Local Assistance                         www.sba.gov/local-assistance
  Qualifying as a Small Business           www.sba.gov/size
  Business Guide                           www.sba.gov/business-guide

  CAPITAL
  Small Business Loans & Grants            www.sba.gov/funding-programs
  Lender Resources                         www.sba.gov/lenders
  Surety Bonds                             www.sba.gov/funding-programs/surety-bonds
  Export Products                          www.sba.gov/exporting

  CONTRACTING
  Government Contracting                   www.sba.gov/federal-contracting
  Register as a Contractor                 www.sam.gov
  Contracting Certifications               certify.sba.gov

  COUNSELING
  SBA Learning Center                      learn.sba.gov
  Small Business Development Centers       www.sba.gov/sbdc
  Women’s Business Centers                 www.sba.gov/wbc
  SCORE                                    www.sba.gov/score
  Veterans Business Outreach Centers       www.sba.gov/vboc

  DISASTER ASSISTANCE
  Disaster Assistance                      www.sba.gov/disaster
  COVID-19 Relief Options                  www.sba.gov/coronavirus
  Disaster Assistance Customer Service     (800) 659-2955
  Center (Toll Free)

  SBA INFORMATION
  SBA National Answer Desk (Toll Free)     (800) 827-5722
  Facebook                                 www.facebook.com/sbagov
  X (formerly Twitter)                     www.x.com/sbagov
  YouTube                                  www.youtube.com/sba
  Blogs                                    www.sba.gov/blogs
  Instagram                                www.instagram.com/sbagov



U.S. Small Business Administration                                     Agency Financial Report Fiscal Year 2025 196
                                                                                                  Appendices (Unaudited)



  Appendix 2 – Glossary
  504 Loan 504 Certified Development Loan                  AGA      Association of Government Ac-
           Program                                                  countants
           Provides small businesses with                           The member organization for
           long-term, fixed-rate financing for                      government financial management
           the purchase of land, buildings, and                     professionals.
           long-life capital equipment.
                                                           APG      Agency Priority Goal
  7(a)              7(a) Loan Guaranty Program                      A set of 2-year goals required by
                    The SBA’s primary loan program; it              GPRAMA that reflect the highest
                    provides general loan financing for             priorities of a federal agency’s lead-
                    a wide variety of purposes.                     ership.

  7(j)              7(j) Management and Technical          APR      Annual Performance Report
                    Assistance Program                              A report that is required by the Gov-
                    Provides specialized assistance to              ernment Performance and Results
                    underserved small businesses.                   Act and presents a federal agency’s
                                                                    progress in achieving the goals in
  7(m)              7(m) Microloan Program                          its strategic plan and performance
                    Provides small, short-term loans to             budget.
                    small businesses and certain types
                    of nonprofit childcare centers.        ARP(A)   American Rescue Plan (Act)
                                                                    A law that provides relief to indi-
  8(a)              8(a) Business Development Pro-                  viduals and businesses affected by
                    gram                                            the COVID-19 pandemic.
                    Assists firms owned and controlled
                    by socially and economically disad-    B2B      Boots to Business
                    vantaged individuals compete for                An entrepreneurial education and
                    federal contracts.                              training program offered by the U.S.
                                                                    Small Business Administration as
  A-123             Designation for OMB Circular on                 part of the Department of Defense
                    Internal Control Systems                        Transition Assistance Program.
                    Prescribes policies and procedures
                    to be followed by federal agencies     BATF     Business Assistance Trust Fund
                    in establishing, maintaining, evalu-            A revolving trust fund in which all
                    ating, improving, and reporting on              donated funds are to be deposited.
                    internal controls in their program
                                                           BLIF     Business Loan and Investment
                    and administrative activities.
                                                                    Fund
  AFR               Agency Financial Report                         Assists eligible small businesses
                    An annual report that provides to               through various loan programs.
                    OMB, Congress, and the public an
                    overview of the Agency’s financial
                    and performance data.




U.S. Small Business Administration                                            Agency Financial Report Fiscal Year 2025 197
                                                                                               Appendices (Unaudited)


  CAP Goals Cross-Agency Priority Goals                          A law that aims to make informa-
            A limited number of Presidential                     tion on federal expenditures more
            priority areas where implementa-                     easily accessible and transparent.
            tion requires active collaboration            DCMS   Disaster Credit Management
            among multiple agencies.                             System
  CARES Act Coronavirus, Aid, Relief and Eco-                    Electronic system used to process
            nomic Security Act                                   loan applications for all new disas-
            A $2.2 trillion economic stimu-                      ter declarations.
            lus bill passed in response to the            DLF    Disaster Loan Fund
            economic fallout of the COVID-19                     Assists eligible small businesses
            pandemic in the United States.                       impacted by disasters.
  CBJ               Congressional Budget Justifica-       DNP    Do Not Pay Initiative
                    tion                                         Established by IPERIA to support
                    A federal agency’s annual budget             federal agencies with their efforts to
                    request to Congress.                         prevent and detect improper pay-
  CDC               Certified Development Company                ments.
                    Nonprofit corporations, certified     DO     District Office
                    and regulated by the SBA, that work          SBA offices that are responsible
                    with participating lenders to pro-           for the delivery of the SBA’s many
                    vide financing to small businesses.          programs and services throughout
  CFO               Chief Financial Officer                      the country.
                    The financial leader whose du-        DOW    Department of War
                    ties include overseeing all Agency           The federal agency charged with
                    disbursements, management and                coordinating national security and
                    coordination of Agency planning,             the armed services (formerly the
                    budgeting, analysis, and account-            Department of Defense).
                    ability processes.
                                                          EAA    Economic Aid to Hard-Hit Small
  CNPP              Community Navigator Pilot Pro-               Businesses, Non-Profits and Ven-
                    gram                                         ues Act
                    Engages in targeted outreach to              Authorizes the U.S. Small Business
                    underserved communities through              Administration to Guarantee ad-
                    states, local governments, resource          ditional loans under the temporary
                    partners, and non-profit organiza-           Paycheck Protection Program and
                    tions.                                       adds a second temporary program
  COVID-19 Coronavirus Disease, 2019                             to SBA’s 7(a) Loan Program titled,
           Highly contagious respiratory                         “Paycheck Protection Program Sec-
           disease caused by the SARS-CoV-2                      ond Draw Loans”
           virus.

  DATA Act          The Digital Accountability and
                    Transparency Act


U.S. Small Business Administration                                         Agency Financial Report Fiscal Year 2025 198
                                                                                                   Appendices (Unaudited)


  EDP               Entrepreneurial Development                      agency to implement and maintain
                    Program                                          financial management systems that
                    An account that reports entrepre-                comply substantially with federal
                    neurial development expenses.                    financial management system re-
                                                                     quirements, applicable federal ac-
  EIDL              Economic Injury Disaster Loan                    counting standards and the United
                    A grant to provide economic relief               States Standard General Ledger.
                    to businesses experiencing a tem-
                    porary loss of revenue due to the       FISMA    Federal Information Security
                    COVID-19 pandemic                                Management Act
                                                                     A law that defines a comprehensive
  ERM               Enterprise Risk Management                       framework to protect government
                    Provides a framework to man-                     information, operations, and as-
                    age risks and seize opportunities                sets against natural or man-made
                    related to the achievement of their              threats.
                    objectives.
                                                            FITARA   Federal Information Technology
  FAST              Federal and State Technology                     Acquisition Reform Act
                    (FAST) Grants                                    Legislation to improve the acquisi-
                    One year funding opportunity to                  tion and management of federal
                    help increase the number of SBIR                 information technology assets.
                    and STTR proposals.
                                                            FMFIA    Federal Managers Financial In-
  FCRA              Federal Credit Reform Act                        tegrity Act
                    A law enacted to provide a more                  A law that primarily requires ongo-
                    realistic picture of the cost of U.S.            ing evaluations and reports on the
                    Government direct loans and loan                 adequacy of the internal account-
                    guaranties.                                      ing and administrative control sys-
                                                                     tems of executive agencies. It also
  FEMA              Federal Emergency Management
                                                                     requires evaluations and reports
                    Agency
                                                                     on the conformance of financial
                    Coordinates the response to a
                                                                     management systems.
                    disaster that has occurred in the
                    United States.                          FR       Financial Report of the U.S. Gov-
                                                                     ernment
  FEVS              Federal Employee Viewpoint
                                                                     Record of the United States govern-
                    Survey
                                                                     ment’s financial activities.
                    An OPM survey administered to
                    federal employees that measures         FRMB     Fraud Risk Management Board
                    perceptions of whether, and to                   Anti-fraud entity responsible for the
                    what extent, conditions character-               oversight and coordination of the
                    istic of successful organizations are            SBA’s fraud risk activities.
                    present in their agencies.

  FFMIA             Federal Financial Management
                    Improvement Act
                    A law that requires each federal


U.S. Small Business Administration                                             Agency Financial Report Fiscal Year 2025 199
                                                                                                     Appendices (Unaudited)


  FTA               Fiscal Transfer Agent                              the best value real estate, acquisi-
                    The central registry for all guaran-               tion, and technology services to
                    teed individual loan and SBA pool                  government agencies.
                    certificate interests.                  GTAS       Governmentwide Treasury Ac-
  FTE               Full-Time Equivalent                               count Symbol Adjusted Trial
                    Indicates the workload of an em-                   Balance System
                    ployed person. An FTE of 1.0 means                 Used by government entities to
                    that the person is equivalent to a                 provide proprietary financial report-
                    full-time worker while an FTE of 0.5               ing and information about budget
                    means that the worker is half-time.                execution to the Department of the
                                                                       Treasury.
  FY                Fiscal Year
                    The Federal Government fiscal year      HHS        U.S. Department of Health and
                    begins October 1 and ends the fol-                 Human Services
                    lowing September 30.                               The federal agency that aims to
                                                                       protect the health of all Americans
  GAAP              Generally Accepted Accounting                      and provide essential human ser-
                    Principles                                         vices.
                    The standard framework of guide-
                    lines for financial accounting gener-   HUBZone Historically Underutilized Busi-
                    ally known as accounting standards              ness Zone
                    or standard accounting practice.                An SBA program that encourages
                                                                    economic development by the
  GAO               U.S. Government Accountability                  establishment of federal contract
                    Office                                          award preferences for small busi-
                    An independent, nonpartisan                     nesses located in historically under-
                    agency that investigates how the                utilized business zones.
                    federal government spends taxpay-
                    er dollars and reports their findings   ICD        Internal Controls Division
                    to Congress.                                          Ensures managers comply with
                                                                       internal control standards.
  GPRAMA            Government Performance and
                    Results Act (GPRA) Moderniza-           ICOR       Internal Control Assessment
                    tion Act                                           Over Reporting
                    A law that modernizes the federal                  A reporting methodology that
                    government’s performance man-                      manages assets (including data),
                    agement framework, retaining                       improves data quality, and reduces
                    and amplifying some aspects of                     compliance-oriented burdens shift-
                    the Government Performance and                     ing activities to support attaining
                    Results Act (GPRA) of 1993 while ad-               high quality data.
                    dressing some of its weaknesses.

  GSA               General Services Administration
                    A federal agency of the Executive
                    Branch whose mission is to deliver



U.S. Small Business Administration                                               Agency Financial Report Fiscal Year 2025 200
                                                                                                      Appendices (Unaudited)


  IPERA             Improper Payments Elimination              MAT      Modification Adjustment Trans-
                    and Recovery Act                                    fer
                    A law that requires that agencies                   A transfer made between the
                    examine the risk of, and feasibility                financing account as the general
                    of, recapturing improper payments                   fund.
                    in all programs and activities.
                                                               MRA      Master Reserve Account
  IPERIA            Improper Payments Elimination                       The SBA’s fiscal agent maintains
                    and Recovery Improvement Act                        this escrow fund to facilitate the
                    An act to intensify efforts to identify,            operation of the Certified Develop-
                    prevent, and recover payment er-                    ment Company program.
                    ror, waste, fraud, and abuse within
                                                               MRF      Master Reserve Fund
                    federal spending.
                                                                        A reserve fund maintained by the
  IPIA              Improper Payment Information                        SBA’s fiscal and transfer agent that
                    Act                                                 is used to facilitate the operation of
                    A law enacted in 2002 to identify                   the 7(a) secondary market program.
                    and reduce erroneous payments
                                                               OBD      Office of Business Development
                    in the government’s programs and
                                                                        Assists small, disadvantaged busi-
                    activities.
                                                                        nesses to gain access to federal and
  ISS               Industrial Specialists for Size                     private procurement markets.
                    Specialists who perform size deter-
                                                               OCA      Office of Capital Access
                    minations for protests
                                                                        Manages small business loans,
  IT                Information Technology                              lender oversight, and the Surety
                    Refers to matters concerned with                    Bond Guaranty program.
                    the design, development, installa-
                                                               OPPCFO   Office of Performance, Planning,
                    tion, and implementation of infor-
                                                                        and the Chief Financial Officer
                    mation systems and applications.
                                                                        Financial leadership of the Agency,
  JAAMS             Joint Administrative Accounting                     including all disbursements, man-
                    Management System                                   agement, and coordination of
                    A financial management system,                      planning, budgeting, analysis, and
                    also known as the Oracle Adminis-                   accountability processes.
                    trative Accounting System, which
                                                               OCIO     Office of the Chief Information
                    is used to keep records of the SBA’s
                                                                        Officer
                    administrative funding and expen-
                                                                        Manages information technology
                    ditures.
                                                                        for the Agency, including the de-
  LSP               Lender Service Provider                             sign, implementation, and continu-
                    Carries out functions in originating,               ing successful operation(s) of infor-
                    dispersing, servicing, or liquidating               mation programs and initiatives.
                    a specific SBA business loan or loan
                    portfolio for compensation from
                    the lender.



U.S. Small Business Administration                                                Agency Financial Report Fiscal Year 2025 201
                                                                                                 Appendices (Unaudited)


  OCRM              Office of Credit Risk Manage-                   Works to create an environment for
                    ment                                            maximum participation by small,
                    Manages program credit risk,                    disadvantaged, and woman-owned
                    monitors lender performance, and                businesses in Federal Government
                    enforces lending program require-               contract awards and large prime
                    ments.                                          subcontract awards.

  OCORM             Office of Continuous Operations         OIG     Office of Inspector General
                    and Risk Management                             Conducts and supervises audits,
                    Ensures enterprise-wide disaster                inspections, and investigations re-
                    planning, readiness, and imple-                 lating to SBA programs and opera-
                    mentation of ERM best practices for             tions.
                    the SBA.                                OMB     U.S. Office of Management and
  ODR&R             Office of Disaster Recovery &                   Budget
                    Resilience                                      White House office that oversees
                    Promotes economic recovery in                   preparation of the federal budget
                    disaster-ravaged areas and assists              and supervises its administration in
                    survivors with accessing SBA di-                Executive Branch agencies.
                    saster loans. Disaster loans are the    OPM     U.S. Office of Personnel Manage-
                    Agency’s primary form of federal as-            ment
                    sistance for non-farm, private sector           The Federal Government’s human
                    disaster losses for individuals and             resources agency.
                    businesses.
                                                            OPSM    Office of Performance and Sys-
  OFA               Office of Financial Assistance                  tems Management
                    Oversees the SBA’s credit programs              Manages the Capital Access Finan-
                    that provide capital alternatives for           cial System, Lender Loan Manage-
                    small businesses not adequately                 ment System, Central Servicing
                    served by conventional lending.                 Agent system, and Fiscal Transfer
  OFPO              Office of Financial Program Op-                 Agent system.
                    erations                                OSDBU   Office of Small Disadvantaged
                    Leads the financial services indus-             Business Utilization
                    try in quality products and services            Offices located within each federal
                    to SBA partners and customers and               agency that enable small disad-
                    protects the integrity of SBA pro-              vantaged businesses to gain access
                    grams.                                          to economic opportunity through
  OGC               Office of General Counsel                       federal contracts.
                    Provides comprehensive legal
                    services to the Administrator and all
                    Agency offices.

  OGCBD             Office of General Contracting
                    and Business Development



U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 202
                                                                                                Appendices (Unaudited)


  PIIA              Payment Integrity Information                  SBDCs provide management and
                    Act of 2019                                    technical assistance, economic
                    Law established to improve efforts             development, and management
                    to identify and reduce government-             training to existing and prospective
                    wide improper payments; requires               small businesses through coopera-
                    agencies to estimate improper                  tive agreements with universities
                    payments and report on actions to              and colleges and government
                    reduce improper payments.                      organizations.

  PPP               Paycheck Protection Program            SBG     Surety Bond Guarantee
                    A loan designed to provide a direct            Provides guaranties and bid,
                    incentive for small businesses to              performance, and payment bonds
                    keep their workers on the payroll.             for contracts up to $2 million for
                                                                   eligible small businesses that can-
  PPS               Probability Proportional to Size               not obtain surety bonds through
                    A method of sampling that takes                regular commercial channels.
                    the varying size of each item within
                    the population into account when       SBGRF   Surety Bond Guaranty Revolving
                    selecting the audit sample.                    Fund
                                                                   A fund at the U.S. Department of
  QAR               Quality Assurance Review                       the Treasury that collects the SBA’s
                    A review to identify any deficien-             contractor and surety fees and is
                    cies, to include improper payments.            used to pay claims.
  QSMO              Quality Service Management Of-         SBIC    Small Business Investment Com-
                    fice                                           pany
                    Office designated by OMB to pro-               Provides long-term loans, debt-eq-
                    mote the use of shared services in             uity investments, and management
                    specific functional areas.                     assistance to small businesses, par-
                                                                   ticularly during their growth stages.
  RRF               Restaurant Revitalization Fund
                    A COVID-19 relief program autho-       SBIR    Small Business Innovation Re-
                    rized under the American Rescue                search
                    Plan.                                          A highly competitive SBA program
                                                                   that encourages domestic small
  SBA               U.S. Small Business Administra-
                                                                   businesses to engage in federal re-
                    tion
                                                                   search/research and development
                    The federal agency whose mission
                                                                   that has the potential for commer-
                    is to maintain and strengthen the
                                                                   cialization.
                    nation’s economy by enabling the
                    establishment and vitality of small    SBLC    Small Business Lending Com-
                    businesses and by assisting in the             pany
                    economic recovery of communities               Non-depository small business
                    after disasters.                               lending companies listed by the
                                                                   SBA Office of Capital Access.
  SBDC              Small Business Development
                    Center


U.S. Small Business Administration                                          Agency Financial Report Fiscal Year 2025 203
                                                                                                 Appendices (Unaudited)


  SE                Salaries and Expenses                          Provide entrepreneurial develop-
                    Operating expenses of the Agency.              ment services such as business
                                                                   training, counseling, and mentor-
  SMC               Senior Management Council                      ing, and referrals for eligible veter-
                    Established by the Administrator               ans owning or considering starting
                    to ensure the SBA has an effective             a small business.
                    system of internal controls.
                                                            WBC    Women’s Business Centers
  SOP               Standard Operating Procedure                   Provide long-term training and
                    The primary source of the Agency’s             advising to women who own or
                    internal control.                              manage a business, including finan-
                                                                   cial, management, marketing, and
  STEP              State Trade Expansion Program
                                                                   technical assistance and procure-
                    Makes matching fund awards to
                                                                   ment.
                    states to help small businesses
                    enter and succeed in the internal       WCF    Working Capital Fund
                    marketplace.                                   A fund for IT modernization efforts.
  SVOG              Shuttered Venues Operator               WOSB   Women-Owned Small Business-
                    Grant                                          es Program
                    COVID-19 relief program authorized             Allows federal agencies to set aside
                    under the American Rescue Plan.                certain contracts for competi-
                                                                   tion only among small businesses
  TAP               Transition Assistance Program
                                                                   owned and controlled by women.
                    Collaborative program between
                    federal agencies to assist active
                    duty service members’ transition
                    to civilian life through access to
                    employment workshops and other
                    services.

  USEAC             U.S. Export Assistance Center
                    Centers located nationwide that
                    help firms grow internationally by
                    assisting in developing a plan of ac-
                    tion with solutions tailored to their
                    needs.

  USSGL             The United States Standard Gen-
                    eral Ledger
                    Provides a uniform chart of ac-
                    counts and technical guidance for
                    standardizing federal agency ac-
                    counting.

  VBOC              Veterans Business Outreach
                    Centers



U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 204
                                                                                                     Appendices (Unaudited)



  Appendix 3 – OIG Audit Follow Up Reports
  OIG audits SBA’s programs, systems, and operations and recommends improvements to management
  based on its findings. Many of these recommendations are not material, relative to their dollar impact
  on the SBA’s financial and administrative operation but are beneficial to SBA’s management. SBA
  management may agree or disagree with the audit’s findings or recommendations. When management
  agrees with recommendations in an audit, it submits a written plan for corrective action and an esti-
  mated target completion date to the OIG for concurrence. If OIG and management agree that the pro-
  posed corrective action will address the finding, the “management decision” process is concluded for
  that recommendation. The memo outlining the terms of the management decision between manage-
  ment and OIG is retained for audit follow-up purposes. When the corrective action plan is implemented
  and the recommendation has been fully addressed, the recommendation is identified as having a “Fi-
  nal Action.” An audit remains open until all corrective actions for each recommendation are completed.

  The SBA maintains a database to track the recommendations through to the conclusion, or Final
  Action. During FY 2025 there were 40 Final Actions, resulting from 4 monetary and 36 non-monetary
  recommendations.

  The following tables depict the SBA’s Final Action activity for FY 2025 and the status of corrective
  action plans not implemented within one year:

  •     Table I: Final Action on Audit Recommendations with Disallowed or Questioned Costs

  •     Table II: Final Action on Audit Recommendations with Funds Put to Better Use

  •     Table III: Final Action on Audit Recommendations Not Completed within One Year

  TABLE I: FINAL ACTION ON AUDIT RECOMMENDATIONS WITH DISALLOWED OR
  QUESTIONED COSTS
  OCTOBER 1, 2024 – SEPTEMBER 30, 2025
                                                                     Number of                  Disallowed
   Recommendations
                                                                  Recommendations                  Costs
   Total recommendations pending final action during period.                65                 $4,500,000,000
   1) Recommendations with management decisions on
   which final action had not been taken at the beginning of                61                 $4,500,000,000
   the period.
   2) Recommendations on which management decisions
                                                                            4                          $0
   were made during the period.
   Total recommendations on which final action was taken
                                                                            4                          $0
   during the period.
   1. Recoveries                                                            1                          $0

   2. Write-Offs                                                            3                          $0




U.S. Small Business Administration                                               Agency Financial Report Fiscal Year 2025 205
                                                                                              Appendices (Unaudited)



  TABLE II: FINAL ACTION ON AUDIT RECOMMENDATIONS WITH FUNDS PUT TO BETTER
  USE
  OCTOBER 1, 2024 – SEPTEMBER 30, 2025
                                                                  Number of    Funds to be Put
   Recommendations
                                                               Recommendations  to Better Use
   Total recommendations pending final action during
                                                                      0                        $0
   period.
   1) Recommendations with management decisions on
   which final action had not been taken at the beginning of          0                        $0
   the period.
   2) Recommendations on which management decisions
                                                                      0                        $0
   were made during the period.
   Total recommendations on which final action was taken
                                                                      0                        $0
   during the period.

   1. Value of recommendations implemented (completed).               0                        $0

   2. Value of recommendations that management
   concluded should not or could not be implemented or                0                        $0
   completed.

  TABLE III: FINAL ACTION ON AUDIT RECOMMENDATIONS NOT COMPLETED WITHIN
  ONE YEAR
  AS OF SEPTEMBER 30, 2025
  Report #20-03 Audit of SBA’s Oversight of High-Risk Lenders
  Program: OCA
  Date Issued: 11/12/2019
  Management Decision Date: 11/15/2019
  Explanation: 6 Recommendations.
  Recommendations 1, 3, 4, 5 and 6 have been closed by OIG.
  Recommendation 2: The SBA is in communication with OIG seeking resolution as OIG denied the
  SBA’s request for closure on 9/8/2025.


  Report #21-08 SBA’s Use of Vendors Without Contracts
  Program: OCA
  Date Issued: 2/3/2021
  Management Decision Date: 2/2/2023




U.S. Small Business Administration                                        Agency Financial Report Fiscal Year 2025 206
                                                                                                   Appendices (Unaudited)


  Explanation: 3 Recommendations.
  Recommendation 2 has been closed by OIG.
  Recommendations 1 and 3: This recommendation is being reviewed by SBA Leadership through the
  Audit Resolution Process, and OCA is currently awaiting leadership’s final decision.


  Report #21-09 Duplicate Loans Made Under the Paycheck Protection Program
  Program: OCA
  Date Issued: 3/15/2021
  Management Decision Date: 3/31/2021
  Explanation: 4 Recommendations.
  Recommendations 2, 3, 4 have been closed by OIG.
  The SBA is currently working with new administration leadership to evaluate PPP remediation
  activities to ensure they are aligned with the current Administration’s priorities. Once this evaluation
  is complete, OCA will address this recommendation.


  Report #21-14 Audit of SBA’s Oversight of Women’s Business Centers’ Compliance with
  Cooperative Agreement Financial Requirements
  Program: OED
  Date Issued: 5/4/2021
  Management Decision Date: 5/4/2021
  Explanation: 9 Recommendations.
  Recommendations 1, 6, 8, 9 have been closed by OIG.
  Recommendations 2, 3 and 7: OWBO is working to remediate this recommendation by
  recovering funds from the WBC for the questioned costs. The SBA will work to remediate these
  recommendations in FY 2026.
  Recommendations 4 and 5: The Standard Operating Procedure (SOP) was finalized and submitted to
  OIG for closure.


  Report #22-01 SBA’s Emergency Economic Injury Disaster Loan Grants to Sole Proprietors
  and Independent Contractors
  Program: OCA
  Date Issued: 10/07/2021
  Management Decision Date: 8/22/2022
  Explanation: 1 Recommendation.
  Recommendation 1: Recommended documents were submitted to OIG for closure on 10/22/2025.




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                                                                                                Appendices (Unaudited)


  Report #22-07 Evaluation of SBA’s Oversight of the Grant Recipient’s Implementation of the
  CARES Act Resource Partners Training Portal
  Program: OED
  Date Issued: 1/18/2022
  Management Decision Date: 4/4/2022
  Explanation: 5 Recommendations.
  Recommendations 1, 2, and 4 have been closed by OIG.
  Recommendations 3 and 5: OIG provided an impasse memo to the SBA on 12/5/2025. The SBA’s
  remediation timeline for these recommendations depends upon the Agency Audit Follow-up Official
  to resolve the disagreement on these recommendations.


  Report #22-11 Evaluation of Fiscal Year 2021 Federal Information Security Modernization
  Act Review
  Program: OEMISS
  Date Issued: 4/28/2022
  Management Decision Date: 4/29/2022
  Explanation: 10 Recommendations.
  Recommendations 1, 3-10 have been closed by OIG.
  Recommendation 2: An extension was approved by OIG to allow the SBA to adequately plan and
  prepare for the Continuity of Operations (COOP) exercise.


  Report #22-19 COVID-19 and Disaster Assistance Information Systems Security Controls
  Program: OCIO
  Date Issued: 9/27/2022
  Management Decision Date: 11/23/2022
  Explanation: 10 Recommendations.
  Recommendations 3, 4, 6, and 9 have been closed by OIG.
  Recommendations for 1 and 8: The closure packages were submitted to OIG on 12/18/25.
  Recommendations 2 and 5: The SBA is recirculating a package that includes a Privacy Program Plan
  and Cybersecurity and Privacy Policy. These documents will implement enterprise-wide privacy risk
  mitigation practices that can be assimilated into new and existing system program designs. Once
  these documents are approved, the SBA will request closure of recommendations 2 and 5 no later
  than 1/30/26.
  Recommendation 7: The SBA will be requesting an extension to implement a Cyber Risk
  Management Platform. This platform will allow users to manage, access, and visualize their
  compliance status, and can trigger reauthorization requirements using compliance/pass/fail status, if
  necessary.



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                                                                                                  Appendices (Unaudited)


  Recommendation 10: The SBA will be requesting closure for this recommendation no later than
  1/30/26. OCA is currently utilizing Microsoft Dynamics for changes and will move to the enterprise
  solution and use of ServiceNow.


  Report #22-21 Paycheck Protection Program Eligibility for Nonprofit Organizations
  Program: OCA
  Date Issued: 9/26/2022
  Management Decision Date: 6/3/2024
  Explanation: 2 Recommendations.
  Recommendation 2 has been closed by OIG.
  Recommendation 1: The SBA is currently working with new administration leadership to evaluate
  PPP remediation activities to ensure they are aligned with the current Administration’s priorities.
  Once this evaluation is complete, OCA will address this recommendation.


  Report #23-03 FY 2022 Federal Information Security Modernization (FISMA) Act Review
  Program: OCIO
  Date Issued: 12/13/2022
  Management Decision Date: 12/16/2022
  Explanation: 6 Recommendations.
  Recommendations 1, 4, and 6 have been closed by OIG.
  Recommendation 2: The closure package submitted for Recommendation 2 on 11/17/2025.
  Recommendations 3 and 5: The SBA released a Cybersecurity Supply Chain Risk Management Plan
  dated 1/9/2026 and will request closure of this recommendation effective 1/14/26.


  Report #23-10 SBA’s Administrative Process to Address Potentially Fraudulent Restaurant
  Revitalization Fund (RRF) Awards
  Program: OCA
  Date Issued: 7/5/2023
  Management Decision Date: 8/15/2023
  Explanation: 1 Recommendation.
  Recommendations 1: The SBA is currently working with new administration leadership to evaluate
  RRF remediation activities to ensure they are aligned with the current Administration’s priorities.
  Once this evaluation is complete, OCA will address this recommendation.


  Report #23-15 SBA’s Oversight of Restaurant Revitalization Fund Recipients
  Program: OCA



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                                                                                                Appendices (Unaudited)


  Date Issued: 9/29/2023
  Management Decision Date: 5/6/2024
  Explanation: 6 Recommendations.
  Recommendation 4 has been closed by OIG.
  Recommendations 1, 2, 3, 5, and 6: SBA has taken recent actions to remediate these findings and will
  coordinate with OIG to close these recommendations.


  Report #24-02 SBA’s Internal Controls to Prevent Shuttered Venue Operators (SVOG) Grants
  to Ineligible Applicants
  Program: ODRR
  Date Issued: 10/25/2023
  Management Decision Date: 8/20/2024
  Explanation: 2 Recommendations.
  Recommendation 1: The extension was requested on 12/04/2025 for a target due date of FY26 Q2.
  Recommendation 2: The closure package was submitted on 12/11/2025.


  Report #24-06 Evaluation of Eligibility and Forgiveness of Paycheck Protection
  Program Loans Made to Borrowers on the Department of Treasury’s Do Not Pay List
  Program: OCA
  Date Issued: 2/22/2024
  Management Decision Date: 3/27/2024
  Explanation: 7 Recommendations.
  Recommendation 5 has been closed by OIG.
  Recommendation 4: The requested documents were submitted to OIG for closure on 9/30/25.
  Recommendations 1, 2, 3, 6 and 7: SBA is currently working with new administration leadership to
  evaluate PPP remediation activities to ensure they are aligned with the current Administration’s
  priorities. Once this evaluation is complete, OCA will address this recommendation.


  Report #24-07 Fiscal Year 2023 Federal Information Security Modernization Act (FISMA)
  Program: OCIO
  Date Issued: 3/7/2024
  Management Decision Date: 3/27/2024
  Explanation: 11 Recommendations.
  Recommendations 1, 2, 3, 4, and 8 have been closed by OIG.
  Recommendation 5: The development of this strategy is currently in progress. A dedicated team



U.S. Small Business Administration                                          Agency Financial Report Fiscal Year 2025 210
                                                                                                 Appendices (Unaudited)


  has been assigned to assess the cybersecurity and supply chain requirements. An initial draft of the
  strategy has been created and is undergoing internal review.
  Recommendation 6: Baseline and configuration weaknesses have been identified, and a timeframe
  for remediation has been outlined.
  Recommendation 7: The SBA is preparing to submit a closure package to OIG no later than 4/30/26.
  Recommendation 9: The SBA will submit the closure package date no later than 4/30/26.
  Recommendation 10: The SBA submitted closure package on 06/15/2025. The SBA is awaiting OIG
  final response to the submitted closure package.
  Recommendation 11: Training programs for individuals with contingency planning roles and
  responsibilities have been created. Subsequent sessions will be held biannually to ensure all relevant
  personnel are trained adequately.


  Report #24-09 Fiscal Year 2023 Audit of SBA’s Restaurant Revitalization Fund (RRF) Program
  Award Practices
  Program: OCA & OCFO
  Date Issued: 3/26/2024
  Management Decision Date: 6/14/2024
  Explanation: 5 Recommendations.
  Recommendation 1: The Chief Operating Officer (COO), Chief Financial Officer (CFO), and Associate
  Administrator of the Office of Capital Access (OCA) have implemented the framework and continue to
  execute it. The framework structures processes and tools to combat fraud. The closure package was
  submitted on 1/7/2026.
  Recommendations 2, 3, 4, and 5: SBA is currently working with new administration leadership to
  evaluate RRF remediation activities to ensure they are aligned with the current Administration’s
  priorities. Once this evaluation is complete, OCA will address this recommendation.


  Report #24-10 Evaluation of SBA’s IT Investment Governance Framework Practices
  Program: OCIO
  Date Issued: 3/29/2024
  Management Decision Date: 06/14/2024
  Explanation: 6 Recommendations.
  Recommendations 1, 3, 4, 5, 6 have been closed by OIG.
  Recommendation 2: The SBA leverages the bi-monthly Business Technology Investment Council
  (BTIC), in accordance with SOPs 90 52 and 90 44, to perform EA reviews. A closure package was
  submitted for this recommendation on 6/17/2025. The SBA is awaiting OIG final response to the
  submitted closure package.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 211
                                                                                                 Appendices (Unaudited)


  Report #24-16 SBA’s Fiscal Year (FY) 2023 Compliance with Payment Integrity Information
  Act of 2019
  Program: OCA & OCFO
  Date Issued: 5/15/2024
  Management Decision Date: 6/14/2024
  Explanation: 10 Recommendations.
  Recommendations 1, 2, 6, and 8 were closed by OIG.
  Recommendations 3, 4, 5, 7, 9, and 10: The SBA has designed and developed a comprehensive PIIA
  tracker system, a systematic quality control system open to program offices to conduct extensive
  reviews of sampled items and record results, evaluate findings, and support the extrapolation of the
  sample results over the population. The closure response was submitted on 12/17/2025.


  Report #24-17 7(a) Loan Approval for Borrowers with Unresolved COVID-19 Pandemic Loan
  Compliance Issues
  Program: OCA
  Date Issued: 5/21/2024
  Management Decision Date: 8/8/2024
  Explanation: 1 Recommendation.
  Recommendation 1: The SBA has completed the reviews and added CHRON notes to the appropriate
  7(a) loans. The closure package will be submitted to OIG.


  Report #24-20 SBA’s Guaranty Purchases for Paycheck Protection Program Loans
  Program: OCA
  Date Issued: 7/9/2024
  Management Decision Date: 9/27/2024
  Explanation: 7 Recommendations.
  Recommendations 1, 2, 4, and 5: SBA has taken additional remediation steps and will coordinate
  with OIG to close out these recommendations.
  Recommendation 3: The SBA submitted a closure package to OIG on 6/2/2025.
  Recommendation 6: The SBA will collaborate with OIG to determine an appropriate remediation
  path that aligns with the current Administration’s priorities.
  Recommendation 7: Extension request was approved; final action target date is 12/31/2025.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 212
                                                                                                Appendices (Unaudited)


  Report #24-21 Audit of SBA’s Oversight of Shuttered Venue Operators Grant Program
  Recipients
  Program: ODRR
  Date Issued: 7/10/2024
  Management Decision Date: 7/11/2024
  Explanation: 3 Recommendations.
  Recommendations 2 and 3 have been closed by OIG.
  Recommendation 1: ODRR is implementing the recovery process based on guidance developments.
  The extension was requested 01/06/2026 for a target due date of FY26 Q2.


  Report #24-23 Audit of SBA’s Oversight of HUBZone Program Participants’ Continuing
  Eligibility
  Program: GCBD
  Date Issued: 7/10/2024
  Management Decision Date: 8/20/2024
  Explanation: 4 Recommendations.
  Recommendations 2 and 4 have been closed by OIG.
  Recommendation 1: Extension request was approved. SBA’s planned actions satisfy the intent of this
  recommendation, and it can be closed when management provides evidence that the program office
  revised the SOP.
  Recommendation 3: Extension request approved. GCBD is currently working to prepare the
  submission to OIG to demonstrate the functionality established within the new UCP system and
  support a successful closure.


  Report #24-25 Oversight of Community Navigator Pilot Program
  Program: OED
  Date Issued: 9/24/2024
  Management Decision Date: 12/20/2024
  Explanation: 5 Recommendations.
  Recommendations 3 and 5 have been closed by OIG.
  Recommendation 1: SBA management partially agreed with the recommendation. An extension
  request has been approved by OIG.
  Recommendation 2: The SBA submitted a closure package OIG on 11/19/2025.
  Recommendation 4: SBA management did not concur with the recommendation. Management
  stated they do not believe SBA can legally implement the recommended comparison of performance
  results due to existing statutory language that limits the data SBA resource partners share with SBA.




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                                                                                                 Appendices (Unaudited)



  Acknowledgments
  This Agency Financial Report was produced with the energies and talents of the SBA staff. To the
  dedicated groups listed below, the Office of Performance, Planning, and the Chief Financial Officer
  would like to offer sincere thanks and acknowledgment.
         ACCOUNTING LIAISON, QUALITY ASSURANCE, AND FINANCIAL REPORTING DIVISION
                                      FINANCIAL ANALYSIS AND REPORTING DIVISION
                                             FINANCIAL SYSTEMS DIVISION
                                     OFFICE OF COMMUNICATIONS AND PUBLIC LIAISON
                       OFFICE OF STRATEGIC MANAGEMENT AND ENTERPRISE INTEGRITY
                                         PERFORMANCE MANAGEMENT DIVISION
                                                    SAVALAN, LLC
                                                  SIGNIFICANCE, INC

  We would also like to acknowledge the Office of Inspector General and KPMG LLP for their
  professionalism while conducting the audit of the Fiscal Year 2025 Financial Statements. We offer our
  special thanks to BrennSys Technology, LLC for contributions in producing this report.




U.S. Small Business Administration                                           Agency Financial Report Fiscal Year 2025 214
Office of Performance, Planning, and the Chief Financial Officer

         409 Third Street, S.W. Washington, DC 20416


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