FY2025 was a large year for SBA lending, but FY2026 opened with a shutdown-driven backlog.

FY2025 sits in the highlighted last row: 77,805 7(a) approvals, $37.22B gross, median loan size $167,900 (up 12% YoY against roughly 30% cumulative inflation over the full panel). The $37.22B figure is the second-largest 7(a) year on record, and the only non-PPP year above $37B. 504 ran a parallel line — 6,759 approvals at a $1.15M average, 71,863 jobs supported, up from 5,993 and $1.11M in FY24.

The pattern to watch year to year is count versus dollars. When counts rise faster than dollars, it is a small-loan year; when dollars rise faster, it is a big-loan year. FY21 was the largest dollar distortion in the panel. FY25 is the cleanest recent baseline.

FY2025 closed hot, with 814 approvals on the final day and 1,404 across the two-day Sep 29–30 sprint as lenders cleared end-of-year pipelines. Then the agency went dark. From Oct 1 through Nov 12, 2025 — 43 consecutive calendar days — SBA approved zero 7(a) or 504 loans, a stretch with no comparable precedent in the public lending record. When operations resumed on Nov 13, the backlog released in a single session: 1,116 7(a) approvals versus an FY24 Thursday median of 279. The week of Nov 13–20 moved $1.84B in 7(a) volume, 1.98× the same week in FY24 ($927M). A year's worth of volume moved in a week.

The week after Nov 13 was not a steady return-to-normal glide. Nov 14 cleared another 915 approvals. Nov 15–16 fell to 101 and 20 (weekend). The rest of the month ran at or above typical pace. The backlog went out the door on the first two days.

The middle of the 7(a) market grew and the under-$50K micro end shrank. In FY2015 the under-$50K bucket was 28% of 7(a) count (17,447 of 62,854); in FY2025 it was 15.6% (12,120 of 77,805), even as the overall market added nearly 15,000 loans. The $50K–$350K mid-band ran the other way, rising from 45.4% of count in FY15 to 50.7% in FY25, an absolute gain of nearly 41,000 loans. The $350K–$1M band went from 16.2% share to 21.6%. Above $1M crossed 12% share for the first time. Median loan size is up 43% nominally (FY15 $117K to FY25 $167,900) against roughly 30% cumulative inflation, so the real median is rising, though not by as much as the headline number suggests.

The FY21 spike on the largest bands is PPP-era policy distortion — the $5M guarantee ceiling and temporary-increase interactions. By FY23 the panel had reset. FY24 and FY25 show the underlying drift: SBA 7(a) is becoming less of a microloan program and more of a working-capital and acquisition platform for borrowers in the $150K–$1M band.

Market concentration climbed from a 2021 low to its highest level since FY2017. We measure it with HHI — the Herfindahl-Hirschman Index, the standard antitrust gauge that sums each lender’s squared market share, where higher values mean fewer lenders hold more share. The 7(a) funded-volume HHI moved from 112 in FY21 to 181 in FY25, up 62% in four years, still well below the DOJ’s 1,500 “unconcentrated” threshold but trending the wrong way. Active lender count fell from 1,451 to 1,308 over the same stretch, a 10% decline. The more useful fact sits in the wedge chart below: the top-10 line for loan count (44.7% in FY25) sits well above the top-10 line for dollar volume (32.0%), and the gap has been widening since FY22. Nearly half of every SBA 7(a) borrower in FY25 walked into one of ten lenders; only a third of the dollars went to those same ten names. The top-10 cohort is weighted toward smaller-dollar Express loans, so the borrower experience is more concentrated than the dollar-flow headline reveals.

The named lender stories — who wrote what, at what average check, with what fall-out rate — sit in Section 6. The pricing story, including the 514-bp all-lender spread range and how dispersion by loan size dwarfs the FY25 Fed cut, lives in Section 3.

Change-of-ownership 7(a) lending hit $8.80B in FY25 across 7,515 loans, both all-time records. Dollar volume rose 31% in a single year. Share of 7(a) count rose from 8.63% in FY24 to 9.66% in FY25, reversing a three-year slide from the FY21 peak of 12.79%. The FY23 trough at 8.80% share now looks, in hindsight, like the bottom.

The full breakdown of the acquisition book by size, industry, and lender sits in Section 4.