Who Really Leads SBA 504 Lending? An Audit of the Nation's Certified Development Companies

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  SBA 504 CDC league table rankings.

One nonprofit in Oakland now writes roughly one of every ten SBA 504 dollars. The rest of the scoreboard is murkier than the press releases suggest, and the numbers that matter most to borrowers are the ones nobody publishes.

Every October, a small industry that most business owners have never heard of issues its victory laps. Press releases arrive declaring a "No. 1 SBA 504 lender in the nation," a "top CDC in the state," a "record year." Brokers repost them. Lender-comparison sites fold them into rankings. Within weeks, the claims harden into something that looks like settled fact.

They are not always settled, and some of them are not facts.

The companies making these claims are Certified Development Companies, or CDCs: the nonprofit lenders that the Small Business Administration certifies to deliver its 504 loan program. If you are buying a building for your business, constructing a facility or financing heavy equipment with SBA support, a CDC will hold the SBA-backed piece of your loan for the next 10, 20 or 25 years. Choosing one is a long-term decision, and most borrowers make it on the strength of a referral and a ranking.

We set out to test those rankings against the public record. We went through SBA's loan-level FOIA files, the agency's own announcements, Inspector General reports, congressional filings and the CDCs' own disclosures. What emerged is a market that is more concentrated than most borrowers realize, a leaderboard that depends heavily on what you choose to measure, and a performance picture that the government tracks closely and publishes almost nothing about.

The 504 program, in proportion

Start with scale, because it is routinely overstated.

The 504 program is often described as a pillar of SBA lending, and in economic terms it is. Each 504 project typically combines a bank first mortgage of about half the cost, an SBA-guaranteed CDC debenture of up to 40 percent, and a borrower contribution of at least 10 percent. Because the bank and borrower pieces sit outside the SBA's numbers, the program's reported volume understates the real estate and equipment it moves.

But measured the way SBA measures it, 504 is the smaller program. According to SBA's fiscal 2025 year-end announcement, the agency approved about 6,750 504 loans worth $7.8 billion, against 77,600 7(a) loans worth $37 billion. The final FOIA count for 504 settled slightly higher, at 6,762 loans. Either way, 504 accounted for roughly 17 percent of combined 7(a) and 504 dollars and about 8 percent of the loans.

That proportion matters, because a figure in circulation among some industry commentators puts 504 at 30 to 60 percent of SBA volume. Nationally, the data do not support that. Our own earlier research made this error and corrected it before publication. Anyone citing a 504 share should name the measure, the year and the geography.

Fiscal 2026 was softer. According to American Banker's reporting on the year-end figures, 504 dollar volume fell about 9 percent, to roughly $7.1 billion. Part of the decline likely reflects timing: some industry observers attribute it to loans pulled into late fiscal 2025 ahead of the autumn government shutdown.

The fiscal 2025 league table

Here is what the national leaderboard looked like for fiscal 2025, measured in SBA debenture dollars, the portion of each project the CDC actually funds with SBA backing. These figures are compiled from SBA approval data as published by LendingTree and Bankrate.

Rank	CDC	Home market	504 debenture dollars (FY2025)	Share of national 504 dollars
1	TMC Financing	California	$836.4 million	10.7%
2	Florida Business Development Corp.	Florida	$440.9 million	5.7%
3	Florida First Capital Finance Corp.	Florida	$427.0 million	5.5%
4	Business Finance Capital	California	$385.0 million	4.9%
5	California Statewide CDC	California	$377.2 million	4.8%

Rank the same field by number of loans and the order shifts. According to SBA approval counts compiled by Nav, the fiscal 2025 top ten by count was TMC (548 loans), Florida Business Development (418), Florida First Capital (349), California Statewide (308), Business Finance Capital (303), Mountain West Small Business Finance in Utah (264), Pursuit in New York (230), Granite State Economic Development in New England (194), WBD in Wisconsin (184) and Small Business Growth Corp. in Illinois (178).

Two things stand out.

The first is the size of the lead. TMC Financing, formally The Mortgage Capital Development Corporation, approved nearly twice the dollar volume of the next CDC. Its average debenture of roughly $1.5 million was about 45 percent larger than Florida Business Development's average of roughly $1.05 million. TMC does more deals, and bigger ones.

The second is concentration. The top five CDCs by dollars wrote about 32 percent of all 504 dollars in fiscal 2025. The top ten by count handled about 44 percent of all 504 loans. The remaining 170 or so active CDCs split the rest. For a program built on the idea of community-based, locally rooted lenders, that is a notable degree of consolidation, and it has been building for years.

The long view confirms it. According to an analysis of SBA FOIA data from fiscal 2010 through March 2026, CDCs funded about 116,000 504 loans worth $96.7 billion over that period. Five organizations account for an outsized share: Florida Business Development (5,748 loans), TMC (5,420), CDC Small Business Finance (5,090), Florida First Capital (4,401) and Empire State Certified Development Corp., now Pursuit (4,145). TMC leads that cumulative list on dollars, at about $6.4 billion.

The first trap: which number is the 504 number?

When TMC announced its fiscal 2025 results, it cited more than $2.4 billion in financing. That figure is accurate, but it is not 504 lending volume. It is total project financing: the bank first mortgage, the CDC debenture and the borrower's equity combined.

TMC's SBA-backed debenture volume was $836.4 million, about 35 percent of the headline number. The firm is not hiding this; its release describes the figure as total project financing. But headlines and broker summaries frequently drop the qualifier. A CDC's total project figure and its debenture figure are not interchangeable, and comparing one CDC's project total with another's debenture total produces a meaningless ranking.

The same applies to fiscal 2026. TMC reports 471 loans, $734 million in 504 financing and $2.2 billion in total project financing, and claims a sixth consecutive year as the nation's top 504 lender. The $734 million would equal about 10 percent of the national total. Those are self-reported figures. SBA has not yet published a fiscal 2026 lender ranking, and the agency's year-end FOIA extract had not been released at the time of writing. TMC has a strong claim to the title, but it remains unverified until those files arrive.

There are also counting differences within SBA's own data. "Approved" loans and "funded" loans are different populations: some approvals are cancelled, reduced or never close. A ranking built from approvals at year-end will not match one built from funded loans a year later. Neither is wrong, but they are not the same list.

The disputed crown

The most revealing inconsistency involves fiscal 2022, and it pits two of California's largest CDCs against each other.

TMC's annual releases describe it as the nation's No. 1 504 lender for five consecutive years through fiscal 2025, in both loan count and dollar volume. That streak includes fiscal 2022. A 2024 TMC release adds that it approved more than $600 million in 504 financing for three consecutive years, which would also take in fiscal 2022.

CDC Small Business Finance, based in San Diego and part of the Momentus Capital family, tells a different story. In a release dated October 2022 and still live on its website, it states that it finished fiscal 2022 as the top 504 lender in the country, with about $592.3 million in approved 504 loans across 428 deals. It says that was $5.6 million more than the next-ranked lender.

Both cannot be right on the same measure. If TMC approved more than $600 million in fiscal 2022, CDC Small Business Finance did not lead on dollars. If CDC Small Business Finance led by $5.6 million, TMC did not lead on both count and dollars that year.

The likeliest explanation is mundane. The two organizations probably measured at different points in time, before and after cancellations, or used different definitions of volume. That is exactly the problem with self-reported leaderboards: each claimant chooses the metric that flatters it, and the market has no neutral referee publishing an authoritative annual table. Until someone reconciles the claims against the FOIA file, the honest description of fiscal 2022 is "disputed."

What is not disputed is what happened next. CDC Small Business Finance, historically a top-three CDC, has dropped out of the national leaderboards. It does not appear in published fiscal 2025 top-504 tables, whose lower ranks begin around $100 million. In the Los Angeles district, according to SBA data reported by the Los Angeles Business Journal, it approved 11 loans for $11.6 million in fiscal 2025, down from 55 loans for $69.6 million the year before. Momentus Capital's 2025 annual report lists about $79.3 million in SBA 504 loans.

Measured against its fiscal 2022 claim, that is a decline on the order of 85 percent, though the annual report's reporting period may not align exactly with SBA's fiscal year. We found no public explanation from the organization. For borrowers, the lesson is simple: a CDC's market position can change quickly, and a ranking from three years ago describes a lender that may no longer exist in the same form.

Correction note: Several third-party lender profiles still list CDC Small Business Finance's fiscal 2025 activity at about $152 million across 435 loans. That figure appears to combine 504 loans with the organization's 7(a) Community Advantage lending. Its implied average of about $350,000 is far below any plausible 504 average. It should not be read as 504 volume.

How many CDCs are there?

A simple question with a surprisingly slippery answer.

SBA maintains a public directory of Certified Development Companies, but the directory is a search tool with no total. We found no current official count from SBA, its Inspector General or the Government Accountability Office.

The figures in circulation trace a clear decline. GAO counted about 270 CDCs in a 2014 report on the 504 program. The industry's trade association, the National Association of Development Companies, told a House committee in 2017 that it represented more than 95 percent of the nation's 230 CDCs. Later NADCO materials say "over 200."

The loan data are more precise. According to an analysis of SBA FOIA records, 202 distinct CDC names funded at least one 504 loan from fiscal 2010 through March 2026, and 188 funded at least ten. But that list includes an entry called "SBA CLSC Servicing," credited with nearly 1,900 loans. CLSC stands for Commercial Loan Service Center, the SBA's own units in Fresno and Little Rock that handle 504 servicing and liquidation. Those are loans transferred to the agency, typically after a CDC exited the program or a loan went into liquidation. That entry is not a CDC, which brings the count to 201 before accounting for name variants and mergers.

Name variants matter more than they should. TMC appears in SBA data as "Mortgage Capital Development Corporation" and in other compilations with "The" in front. Cincinnati's Alloy Development Co. appeared in earlier SBA rankings under its former name, Hamilton County Development Company. New York's largest CDC, long known as Empire State Certified Development Corp., now operates as Pursuit.

Narrow the window to recent activity, and the number falls again: about 183 CDCs originated at least one 504 loan in fiscal 2021 through 2025. The defensible answer is roughly 180 to 200 active CDCs, down from about 270 a decade ago. Any article citing "270" today is quoting 2014.

The decline is partly by design. Federal rules require a CDC to maintain a minimum level of activity, at least four approvals across two consecutive fiscal years, and SBA can decertify those that fall short. Small CDCs have merged into larger ones or exited. The result is the concentration visible in the league table.

A state case study: who really leads Ohio?

State-level "No. 1" claims are where the scoreboard problem becomes most visible, because the field is small and the marketing is local.

Ohio has two claimants. Growth Capital Corp. in Cleveland states on its homepage that it has been the state's number one SBA 504 lender for almost 15 years. Alloy Development Co. in Cincinnati describes itself as the top CDC in Ohio and Kentucky.

The cumulative FOIA record for Ohio projects, fiscal 2010 through March 2026, looks like this:

CDC	Headquarters	Ohio 504 loans	Ohio 504 dollars
Alloy Development Co. (formerly Hamilton County Development Co.)	Cincinnati	655	$482.0 million
Growth Capital Corp.	Cleveland	599	$387.3 million
Ohio Statewide Development Corp.	Columbus	472	$255.4 million
Community Capital Development Corp.	Columbus area	463	$258.0 million
Cascade Capital Corp.	Akron area	227	$160.6 million

Over the long run, Alloy leads on both count and dollars, though Growth Capital is close on count.

The more telling evidence comes from Growth Capital itself. In an August 2022 post on its own website, citing SBA's most recent ranking of CDCs by state, Growth Capital listed Ohio's leaders as Hamilton County Development Company first, Ohio Statewide Development Corporation second and Growth Capital third. The company's own published ranking contradicts the "No. 1 for almost 15 years" claim that remains on its homepage.

This does not mean Growth Capital is a weak lender; it may well have led in particular years, by particular measures. It means the homepage claim cannot be squared with the firm's own citation of SBA data, and borrowers have no way to tell which version is current. The same pattern runs through state after state: a claim made once, about one metric in one year, survives on a website long after the underlying ranking has changed.

The performance question nobody can answer

League tables measure volume. Volume tells a borrower how experienced a CDC is. It says nothing about whether that CDC underwrites well, closes on time, services loans responsibly or handles a troubled borrower with competence.

That information exists. SBA's Office of Credit Risk Management oversees CDCs and assigns them risk ratings, conducts reviews and can require corrective action. None of those ratings are public. A borrower choosing between two CDCs cannot see how SBA grades either one.

The government also forecasts risk at the loan level. According to the SBA Inspector General's 2025 report on management challenges, SBA uses a machine-learning model to estimate the probability that individual 7(a) and 504 loans will default within a year. Those scores are not public either.

What is public is the program-wide picture, and it is very good. In a November 2025 letter to the House Small Business Committee, NADCO President and CEO Rhonda Pointon cited SBA figures showing a one-year 504 charge-off rate of 0.07 percent as of August 31, 2025. She credited the program's two layers of underwriting (the bank's and the CDC's) together with oversight by the Office of Credit Risk Management. By any lending standard, that is an exceptionally low loss rate, and it reflects the program's structure: the borrower's equity and the bank's first lien sit in front of the SBA's exposure.

Congress has noticed the transparency gap, up to a point. The 504 Program Risk Oversight Act, H.R. 5788, would require SBA to deliver an annual 504 portfolio risk report to Congress and publish it. The House passed the bill in January 2026, and it was referred to the Senate Small Business Committee later that month. The Congressional Budget Office estimated its cost at about $1 million over five years.

But the bill draws a careful line. For CDCs above a size threshold, it calls for consolidated reporting that does not identify individual development companies by name. Even the proposed transparency law keeps CDC-level performance anonymous. NADCO supported the bill, and Pointon's letter describes transparent data as the foundation of a productive partnership with the agency. The data envisioned, however, would show the program's risk profile, not which lender is better at managing it.

The Inspector General's recent work adds texture without filling the gap. A 2024 verification inspection found that SBA had effectively implemented earlier recommendations on 504 liquidations. The OIG's fiscal 2026 challenges report noted that SBA was adding front-end verification checks, including Treasury's Do Not Pay system, for 504 loans. A May 2026 audit of SBA's compliance with federal payment-integrity law found that the agency had not met its improper-payment reduction targets for 504 approvals. We found no 2025 or 2026 Inspector General report focused specifically on CDC oversight, and GAO's most recent dedicated review of the program dates to 2014.

The charge-off field that may or may not exist

There is one place a determined analyst might look for CDC-level loss data: the loan-level FOIA files SBA publishes every quarter. Here the published record contradicts itself.

SBA Loan Index, an independent site that ranks lenders from those files, states in its methodology that SBA's 504 dataset never carries a charge-off status. On that basis it reports no default rates for CDCs.

Other analysts working with the same files describe them differently. LoanTape, a data provider, reported that when SBA expanded the 7(a) loan-status field from five codes to thirteen in April 2026, the 504 file remained on the legacy five-code system, a system that includes a charge-off code. A commercial extraction service lists charge-off as a filterable status across both programs. An open-source project that ingests the SBA files reported finding charge-off codes in its 504 sample in September 2026, and at least one regional business publication's 504 database displays a gross charge-off amount field.

The weight of evidence suggests the 504 file does carry a charge-off status and amount, and that the "never" claim is mistaken, perhaps an artifact of one site's processing. The confirming document is SBA's own data dictionary, which accompanies the quarterly files. Loss events in the 504 program are rare, so the field may simply be sparsely populated.

Even if the field exists, it would not deliver clean CDC report cards. When a 504 loan defaults, the loss falls largely on SBA's guarantee of the debenture, not on the CDC. And as the "SBA CLSC Servicing" entry shows, troubled loans can migrate to SBA's own servicing centers, which can sever the link to the CDC that originated them. Any CDC-level loss rate computed from public data would need to trace each loan back to its original CDC, and to say so plainly.

What changed for borrowers this year

The CDC you choose now operates under a different set of rules than it did a year ago.

On July 4, 2026, SBA doubled the combined amount a borrower can hold across the 7(a) and 504 programs to $10 million, the first increase since 2010, according to American Banker. Individual 504 loan caps were unchanged. The practical effect is that a borrower can now pair a full-size 7(a) working capital loan with a full-size 504 real estate loan.

For loans approved from October 1, 2026, through September 30, 2027, SBA is waiving both the upfront guaranty fee and the annual service fee on 504 loans to manufacturers, businesses in the food supply chain and businesses in rural areas, according to the agency's fiscal 2027 fee notice. Other borrowers pay reduced fees, about 0.50 percent upfront and an annual fee of roughly 0.2 percent of the outstanding debenture, according to CDC guidance on the notice.

Rates have eased slightly. For the October 2026 debenture sale, effective 504 rates including fees were just under 7 percent for 20- and 25-year terms, according to rate schedules published by CDCs, and around 6.6 percent for 10-year terms.

SBA's revised lending rulebook, SOP 50 10 8.1, also took effect October 1, 2026, with changes affecting CDC underwriting and project structuring. Borrowers should ask any CDC they consider how the new rules affect their specific deal.

Finally, leadership is turning over at the top of the market. TMC founder Barbara Morrison, who built the organization into the national leader, described fiscal 2025 as her send-off into retirement, and the firm's fiscal 2026 release names Omar Salah as president and chief executive.

How to read a CDC's claims

Rankings are not useless. Volume is real evidence of experience, and a CDC that closes hundreds of 504 loans a year has seen most of the problems a borrower is likely to encounter. But the published scoreboard rewards marketing as much as performance, and a borrower should read it the way a credit analyst reads a pro forma.

Ask what is being measured. Debenture dollars, total project financing and loan count produce different leaders. A claim that does not name its metric is not a ranking.

Ask what year. Many "No. 1" claims describe a single fiscal year, sometimes several years past. The leader in fiscal 2022 had dropped off the national table by fiscal 2025.

Ask what geography. A CDC can lead a district, a state or the nation, and state rankings can depend on whether they count projects located in the state or loans made by in-state CDCs.

Check the source. A press release is a claim. SBA's FOIA files are the record. Where the two conflict, as they do for fiscal 2022 and for Ohio, the record should win.

Ask the question rankings cannot answer. How long does the CDC take from application to SBA approval in your type of project? How many deals like yours has it closed in your market in the past two years? Who will service the loan after closing, and what happens if your business hits a rough year? A CDC with a strong servicing operation and real experience in your asset class may serve you better than the national volume leader.

Remember what you cannot see. The government grades every CDC, and those grades are not public. Until that changes, borrowers are choosing lenders on volume and reputation, and the most informative number in the market remains confidential.

Where the published record goes wrong

This series documents not only what the data say, but where commonly repeated claims fail against them. For this article:

• TMC Financing's "$2.4 billion" (fiscal 2025) and "$2.2 billion" (fiscal 2026) figures are total project financing, not 504 lending volume. Its SBA debenture volume was $836.4 million and a self-reported $734 million.

• TMC's claim to have led in both count and dollars in every year from fiscal 2021 through 2025 conflicts with CDC Small Business Finance's claim to have led fiscal 2022 by dollars. Both cannot be correct on the same measure.

• Growth Capital Corp.'s claim to have been Ohio's No. 1 504 lender for almost 15 years is contradicted by the company's own 2022 post citing SBA rankings, which placed it third.

• The figure of about 270 CDCs is GAO's 2014 count. The current active field is roughly 180 to 200.

• Rankings that count "SBA CLSC Servicing" as a CDC are counting SBA's own servicing centers.

• SBA's initial fiscal 2025 announcement of about 6,750 504 loans was superseded by a final FOIA count of 6,762.

• The claim that SBA's 504 data contain no charge-off information appears to be mistaken.

• The idea that 504 represents 30 to 60 percent of SBA lending is wrong at the national level. In fiscal 2025, it was about 17 percent of dollars and 8 percent of loans.

Sources:

• U.S. Small Business Administration, 7(a) and 504 FOIA loan-level data, quarterly releases through June 30, 2026, and data documentation

• U.S. Small Business Administration, fiscal 2025 year-end lending announcement, September 2025

• U.S. Small Business Administration, Information Notice on fiscal 2027 504 program fees

• SBA Office of Inspector General, Report 25-02, Verification Inspection of SBA's 504 Loan Liquidation Process

• SBA Office of Inspector General, 2025 Top Management and Performance Challenges

• SBA Office of Inspector General, Report 26-01, Top Management and Performance Challenges, Fiscal Year 2026

• SBA Office of Inspector General, Report 26-09, Audit of SBA's FY2025 Compliance with the Payment Integrity Information Act

• U.S. Government Accountability Office, GAO-14-233, Development Company (504) Loan Program

• H.R. 5788, 504 Program Risk Oversight Act, and Congressional Budget Office cost estimate

• National Association of Development Companies, letter to the House Small Business Committee, November 14, 2025

• National Association of Development Companies, House Small Business Committee testimony, 2017

• American Banker

• Los Angeles Business Journal

• TMC Financing, annual results releases, 2024, 2025 and 2026

• CDC Small Business Finance, press release, October 2022

• Momentus Capital, 2025 Annual Report

• Growth Capital Corp., published website materials

• Alloy Development Co., published website materials

• LoanTape

• SBA Loan Index

• LendingTree

• Bankrate

• Nav

• FitSmallBusiness

• CDC rate schedules, October 2026