CAIVRS, SAM.gov and SAFER Web Searches: Understanding upcoming SBA Lender Requirements

Which should you search as part of your SBA underwriting process? CAIVRS or SAM.gov?

Both, because they serve different purposes.

It’s one of the most common questions we hear as part of our SBA consulting services.  And with SBA SOP 50 10 8.1 taking effect October, 1, 2026, now is a good time for lenders to make sure their procedures reflect the new requirements.

Today’s loans can involve multiple owners, holding companies, Eligible Passive Companies (EPCs), Operating Companies (OCs), and outside service providers.  Knowing who gets searched, where they are searched and why is important to maintaining SBA compliance.

Different Searches for Different Reasons

CAIVRS and SAM.gov are often discussed together, but they serve different purposes.

Under the upcoming SBA SOP 50 10 8.1, CAIVRS will be used to determine whether an Applicant may be ineligible because of a Prior Loss to the Government or Delinquent Federal Debt.

SAM.gov determines whether and individual or entity has been suspended, debarred, revoked, or otherwise excluded from dong business with the federal government.

And beginning October 1, certain Applicants will require another verification: SAFER Web.

Who gets searched in CAIVRS?

Under SBA SOP 50 10 8.1, who must be checked depends on what the Lender is checking.

For Prior Loss to the Government, the Lender must determine whether there has been a prior loss involving:

• The Applicant

• Any business owned, operated, or controlled by the Applicant

• Any business owned, operated, or controlled by an associate of the Applicant

A prior loss does not necessarily make an Applicant ineligible if the debt was fully satisfied.

In other words, don’t assume the one list of parties applies to every CAIVRS eligibility questions.  Knowing what you are checking for and who the SBA SOP requires you to check matters.

The new SBA SOP 50 10 8.1 also incorporates SBA’s updated Prior Loss Rule for certain non-controlling minority equity investors.  In qualifying circumstances, SBA may consider a waiver when an owner of the current Applicant held less than 20% of the business associated with the prior loss, was not a guarantor or co-borrower, and did not control that business.

The takeaway? Know what you’re checking for, search the right parties, and document the results.

Who gets searched in SAM.gov?

SAM.gov searches are also broader than many lenders realize.

Depending on the Applicant’s structure, searches can include:

• Sole proprietors

• Applicant Owners, officers, directors, members, partners, trustors, and key employees 

• Legal entities owning at least 20% of the Applicant

• An EPC or an OC when the loan uses and EPC/OC structure, regardless of whether the OC is a Borrower or guarantor.

And SAM.gov isn’t just an Applicant search.

Applicable Lender personnel involved in SBA lending or with access to SBA loan information must be checked, along with agents and Lender service providers retained to assist with the SBA loans and applicable 504 professional service contractors.

For these parties, the search is required before their first day of SBA-related work.

One More Search: SAFER Web

SBA SOP 50 10 8.1, Adds another consideration for certain Applicants.

Beginning October 1, if an Applicant is required by the Federal Motor Carrier Safety Administration (FMCSA) to have a USDOT number, the Lender must also verify the Applicant through SAFER Web.

The Lender must document the Applicant has:

• An active USDOT number in good standing

• That the physical address in SAFER Web matches the company’s physical address

A P.O. Box does not satisfy the physical address requirement.

Show your work

As always, documentation matters.

Lenders should be able to demonstrate that required searches and verifications were completed, including who was searched, when the search occurred, the results, and how any matches or eligibility issues were resolved.

For SAM.gov searches, retain evidence of the search, such as a screenshot.  Required CAIVRS searches and applicable SAFER Web verifications should also be documented in accordance with the SBA SOP.

Get Ready for October 1

These searches may take only a few moments.  Understanding who should be searched, where, and why is what helps protect loan eligibility and avoid SBA compliance problems.

With SBA SOP 50 10 8.1 effective October 1, 2026, now is the time to review procedures, checklists, training materials, onboarding processes, and vendor practices to make sure your SBA lending program is ready.

That’s where we can help.  Whether it’s updating those procedures, providing SBA lender training, assisting with SBA compliance or delivering ongoing SBA consulting services, our SBA experience can help your team prepare for changing SBA lender requirements.

Give us a call today at 877-576-0819, or drop us a line through our website here.