? The SBA fixed a show-stopper issue with Trusts & made the Quality of Earnings process significantly easier before the new rules take effect 10/1: THE TRUST ISSUE The new rules, scheduled to take effect October 1st, would have required ANY trust with ownership in an SBA-backed deal to personally guarantee the loan. This was going to be a major issue for (1) any investment fund, as they all have trusts among their LPs, and (2) anyone wanting to do estate planning. The updated rule is that a personal guarantee is required only if trusts own at least 20% of the business in aggregate, at which point they must all PG. It's not perfect, but it's dramatically better. QUALITY OF EARNINGS The new rules required banks to procure a QoE as part of their underwriting process. QoEs should be done, but buyers already do them. Requiring banks to hire their own QoE firm would add costs, complexity, and slow deals down. The updated rule is that banks can use a *buyer's* QoE, as long as they put a reliance letter in place or have a secondary review by a different firm. OTHER TECHNICAL FIXES - Working capital true-ups in the purchase agreement are not treated as seller rebates. - For deals involving owner-occupied special purpose property, amortization can run up to 25 years. Let me know if I missed anything meaningful!