SBA Special Purpose Property List: The 25 Items in SOP 50 10 8.1
The SBA special purpose property list has 25 items, printed in the 504 section of SOP 50 10 8.1 (Section C, Chapter 1, Borrower's Contribution); SBA removed clubhouses and museums from it as of 1 January 2018, and two 504 loan websites still printed both on 10 October 2026. The statute, 15 U.S.C. § 696(3)(C), and the regulation, 13 CFR 120.910, say "limited or single purpose building or structure", and neither section defines it. The SOP calls its list "not intended to be all-inclusive", and the Certified Development Company (CDC) must explain its conclusion in the credit memorandum. On a $1,000,000 504 project the label means at least $150,000 from the borrower instead of $100,000. A business in operation for 2 years or less when the loan is approved owes at least $150,000 without the label and $200,000 with it.
This page covers the SBA 504 loan program and is general information, not legal or lending advice. We are not a CDC, a lender or attorneys. Confirm the classification with your CDC before you budget the contribution. On a 7(a) business acquisition the same words do a different job, covered below.
What is on the SBA special purpose property list?
Twenty-five entries. The list sits in SOP 50 10 8.1, Section C (the 504 program), Chapter 1, under Borrower's Contribution; the SOP's own cross-reference calls it "the Limited or Special Purpose Property List at Paragraph E.1.c.i.c)". In full:
- Amusement parks;
- Bowling alleys;
- Car wash businesses;
- Cemeteries;
- Cold storage facilities where more than 50% of total square footage is equipped for refrigeration;
- Dormitories;
- Farms, including livestock and dairy facilities;
- Funeral homes with crematoriums;
- Gas stations;
- Golf courses;
- Hospitals, surgery centers, urgent care centers, and other health or medical facilities;
- Hotels, motels, and other lodging facilities;
- Marinas;
- Mines;
- Nursing homes, including assisted living facilities;
- Oil wells;
- Quarries, including gravel pits;
- Railroads;
- Sanitary landfills;
- Service centers (e.g., oil and lube, brake, or transmission centers) with pits and in-ground lifts;
- Sports arenas;
- Swimming pools;
- Tennis clubs;
- Theaters and auditoriums; and
- Wineries.
Those are all 25 printed entries. Three carry their own conditions: funeral homes "with crematoriums", service centers "with pits and in-ground lifts" and cold storage "where more than 50% of total square footage is equipped for refrigeration". A property outside the condition is not named, which under the next section does not clear it. The same 25 entries appear, character for character, in SOP 50 10 8 (effective 1 June 2025).
Is the list complete, and who decides?
No. The CDC must address the question in writing, and SBA may determine that a property the list does not name meets the definition. The two paragraphs directly above the list:
CDCs must address whether the Project Property is Limited or Special Purpose in their credit memorandum and include an explanation of their conclusion.
Below is a list that contains examples of properties that SBA considers to be a Limited or Special Purpose Property. This list is not intended to be all-inclusive and SBA may determine that other properties meet the Limited or Special Purpose Property definition.
The percentages are floors as well: the SOP says the required contribution and collateral "are the minimums required by policy". Ask your CDC how its credit memorandum will address the property, not only whether the list names it.
What does being on the list cost on a 504 loan?
Five more percentage points of project cost on the minimum: 15 percent instead of 10, or 20 instead of 15 if the business is also a New Business, which is ten above the standard structure. The contribution paragraph sets minimums as a share of the project, excluding administrative costs: "All Borrowers must contribute at least 10%", "New businesses must contribute at least 15%", and for the property on this page:
Businesses with a Limited or Special Purpose Property:
Must contribute at least 15%, in which case the Debenture will finance no more than 35% of the Project and at least 50% of the Project financing will be from banks or other financial institutions, state or local government, or foundations or other non-profit institutions.
Must contribute at least 20%, if the Project involves a new business 13 CFR § 120.910.
The extra money replaces debenture: "The additional Borrower's contribution will reduce the SBA's portion of the financing". The SOP's table of Typical 504 Structures gives three splits between Third Party Lender, CDC/SBA and Borrower, and Chapter 3 of Section C prices a "hypothetical project for a new business or for a Limited or Special Purpose Property" at $1,000,000, the middle row below. The other two rows are our arithmetic from the SOP's percentages:
| $1,000,000 project (SOP column heading) | Third Party Lender | CDC/SBA (net debenture) | Borrower | Extra versus standard |
|---|---|---|---|---|
| "Standard Financing Structure", 50 / 40 / 10 | $500,000 | $400,000 | $100,000 | $0 |
| "New Business OR Limited or Special Purpose Property", 50 / 35 / 15 (the SOP's example) | $500,000 | $350,000 | $150,000 | $50,000 |
| "Both New AND Limited or Special Purpose Property", 50 / 30 / 20 | $500,000 | $300,000 | $200,000 | $100,000 |
Each row sums to $1,000,000. Two points on scope:
- The two-year clock. A New Business is "A business that has been in operation for 2 years or less at the time the loan is approved" (Appendix 3), counted from when it "begins generating revenue from its intended operations". An older business "may be considered a New Business if it is a change of ownership that will result in new, unproven ownership/management and increased debt unrelated to business operations".
- Debt refinancing without expansion is covered. There the SOP says that when "the Refinancing Project involves a Limited or Special Purpose Property" the borrower must meet the same contribution paragraph. 13 CFR 120.882(g)(5), which bases the funding on the current fair market value of the collateral, sets "not less than 15% (excluding administrative costs)" for a limited or single purpose building, or 10 percent during a recession SBA has announced in the Federal Register. The one such notice we found is dated 3 August 2020 (85 FR 46775), and the regulation keeps the lower figure "until the first day of the calendar quarter following the end of the economic recession"; ask your CDC which figure applies.
Run your figures in our free SBA equity calculator; 7(a) equity is on SBA equity injection requirements.
What is the SBA's definition of a special purpose property?
One sentence in Appendix 3 of the SOP, under the entry Limited or Special Purpose Property:
A limited-market property with a unique physical design, special construction materials, or a layout that restricts its utility to the use for which it was built.
The list names examples of properties SBA considers Limited or Special Purpose; for a property it does not name, the SOP says SBA "may determine that other properties meet the Limited or Special Purpose Property definition". Appendix 15 carries a near-identical sentence for 7(a) business acquisitions, ending "the specific use for which it was built". The 504 appraisal rules add: "When the collateral is a Special Purpose Property, the appraiser must be experienced in the particular industry."
Is a single purpose property the same as a special purpose property for the SBA?
On our reading, yes: one rule under two names. The statute and the regulation say limited or single purpose building or structure; special purpose is the SOP's wording for the rule it cites to 13 CFR 120.910, and in the sections we read the law defines neither phrase. 15 U.S.C. § 696(3)(C)(ii):
at least 15 percent of the total cost of the project financed if the project involves the construction of a limited or single purpose building or structure;
Clause (i) sets the same 15 percent for a business "in operation for a period of 2 years or less", clause (iii) 20 percent for both and clause (iv) 10 percent otherwise.
The regulation, 13 CFR 120.910(a)(2), widens the trigger from construction to "the acquisition, construction, conversion, or expansion of a limited or single purpose building or structure". Neither 13 CFR 120.10 nor 120.802, the definitions sections, has an entry for either phrase. Of the texts we read, the SOP alone has a definition and a list.
A bill would delete the statutory clause. H.R. 5763, the Main Street Parity Act, would amend 15 U.S.C. § 696(3)(C) "by striking clauses (ii) and (iii)". It passed the House on 20 January 2026 and was referred to the Senate Committee on Small Business and Entrepreneurship on 26 January 2026; the bill status file showed no later action on 10 October 2026. It is not law.
What is not on the SBA special purpose property list?
Clubhouses and museums, which SBA took off it. SOP 50 10 5(I), effective 1 January 2017, listed 27 property types, Clubhouses and Museums among them. SBA Notice 5000-17028, on the technical corrections to SOP 50 10 5(J), says the list was reinserted without those two, "which have been removed from the list", and SOP 50 10 5(J), effective 1 January 2018, prints 25 entries. Pages on two 504 loan websites, TMC Financing and 504 Capital, each still printed 27 entries, clubhouses and museums included, when we retrieved them on 10 October 2026.
Counts of each word, singular or plural, across the full text of SOP 50 10 8.1 for property types the list does not name:
| Property type | Occurrences | Where |
|---|---|---|
| Veterinary | 0 | Nowhere |
| Self-storage | 0 (storage units: 1) | Appendix 15, as a 7(a) acquisition example |
| Brewery; distillery | 1; 0 | Appendix 6, an exception inside a NAICS entry |
| RV park; campground | Recreational vehicle: 3; campground: 1 | A Section A eligibility rule and two Appendix 6 NAICS entries |
The list's health entry ends "and other health or medical facilities", and the SOP does not say how far those words reach. That is the question to put to your CDC for a dental office, a dialysis center or a veterinary hospital.
None of this clears an unnamed property, clubhouses and museums included: the list is not all-inclusive, and the CDC must explain its conclusion either way.
Does special purpose property matter for a 7(a) loan?
Not in the 7(a) program chapters, and in the acquisition appendix it loosens three rules and tightens the valuation. Section B of SOP 50 10 8.1, Chapters 1 to 6, does not contain the words special purpose or single purpose, and we found no property list or property-based contribution step-up there.
Appendix 15, 7(a) Changes of Ownership, uses the term for the acquisition of "an owner-occupied Special Purpose Property which includes the business operating from that property". Four things change. The first three are new in SOP 50 10 8.1, which SBA says applies to applications it receives on or after 1 October 2026.
- Maturity. Change of ownership loans "must not have an amortization that exceeds 10 years", but here the lender "may also structure the loan with a maturity of up to 25 years if 85% or more of the use of the total project costs are for real estate".
- Projections. "In situations where the appraised value fully collateralizes the loan, the Lender may rely on projections to satisfy the DSC requirement", which "must be satisfied within two years from loan funding".
- Due diligence. "A Quality of Earnings report is not required for a transaction involving the acquisition of an owner-occupied Special Purpose Property, regardless of the Business Purchase Price".
- Valuation. The business valuation "must allocate separate values to the individual components of the transaction including land, building, equipment, and intangible assets", and the Certified General Real Property Appraiser "must have completed no less than four going concern appraisals of equivalent special use property as the property being appraised, within the last 36 months".
The first two apply only when the acquisition of the property "cannot be separated from, and is integral to, the acquisition and continued operation of the business". A lender relying on projections must document in its credit memorandum "the basis for its determination that the property meets the definition of a Special Purpose Property".
The acquisition rules in full are on our SBA business acquisition loan requirements page.
What your CDC's credit memorandum, and your business plan, have to show
The CDC writes the conclusion; your plan can give it the facts:
- A property description the definition can be applied to. Design, construction materials, layout and the market for the building. If your property type is not named and you believe it does not meet the definition, the case belongs here, because the CDC must "include an explanation of their conclusion".
- Sources and uses at the right structure. A 10, 15 or 20 percent contribution on project cost excluding administrative costs, showing cash, any borrowed contribution and any equity in land or buildings already owned, which "may be counted toward the Borrower's contribution if the land and/or buildings are part of the Project".
- The date revenue began. It starts the two-year New Business clock, which is read when the loan is approved; a change of ownership can reopen the question.
Our SBA loan business plans are $1,000 Essential, $1,800 Standard and $2,500 Premium, and financial models $750, $1,250 and $1,950, all fixed and published. We never charge a percentage of anything you borrow, invest or raise. If your CDC also asks for a feasibility study, read whether the SBA requires one first; the wider 504 rules are on SBA 504 loan requirements.
Business Plan Firm is the US practice of Avvale, a London consultancy. We have written 1,000+ plans for 500+ founders across 30+ countries, and our clients have raised $500M+.
How we verified this
Sources were retrieved 6 to 10 October 2026, and every quotation was re-checked against raw text on 10 October 2026, after SBA re-posted the SOP file.
- SBA SOP 50 10 8.1, effective 1 October 2026, quoted from Section C, Chapters 1 and 3, Appendix 3 and Appendix 15 and searched in full, from the current posting on sba.gov; SBA Information Notice 5000-882227 for the applications it covers. SOP 50 10 8 (effective 1 June 2025), to confirm the list is unchanged and the three 7(a) rules are new.
- The removal of clubhouses and museums: SOP 50 10 5(I), SOP 50 10 5(J) and SBA Notice 5000-17028, all on sba.gov.
- 15 U.S.C. § 696(3)(C), at the Legal Information Institute; H.R. 5763 from the bill text and bill status file at govinfo.gov.
- 13 CFR 120.910 and 120.882(g)(5), quoted, and 120.10 and 120.802, searched for a definition: current text at the Legal Information Institute and the 2025 annual edition at govinfo.gov. The quoted passages are identical in both, and a Federal Register search to 10 October 2026 found no later rule changing them. The 2020 recession notice is Federal Register document 2020-16792.
- The two 27-entry pages, retrieved 10 October 2026: TMC Financing and 504 Capital, neither a source for any rule here.
Not verified, and so left out: how SBA or any CDC has classified a veterinary clinic, self-storage facility, brewery or RV park on an actual loan; whether the lower refinancing contribution under 13 CFR 120.882(g)(5) applies today; and the SOP editions between 50 10 5(J) and 50 10 8.
Frequently asked questions
How many items are on the SBA special purpose property list?
Twenty-five. The SBA Limited or Special Purpose Property list is in SOP 50 10 8.1, Section C, Chapter 1, under Borrower's Contribution, and the SOP says it is not intended to be all-inclusive. SBA removed clubhouses and museums as of 1 January 2018; two 504 loan websites still printed both on 10 October 2026.
What is the SBA 504 down payment for a special purpose property?
For a Limited or Special Purpose Property the SBA 504 borrower contribution is at least 15 percent of project cost, excluding administrative costs, against 10 percent for a standard project, under SOP 50 10 8.1 and 13 CFR 120.910. For a New Business, one in operation 2 years or less at approval, it is 20 percent against 15. On $1,000,000: $150,000 instead of $100,000, or $200,000 instead of $150,000.
Is a veterinary clinic a special purpose property for an SBA 504 loan?
SOP 50 10 8.1 does not say. The word veterinary appears nowhere in it, so a veterinary clinic is not named on the SBA special purpose property list, but the list is not all-inclusive and the Appendix 3 definition still applies. Your CDC must address the question in its credit memorandum.
Is self-storage on the SBA special purpose property list?
Not by name. Self-storage does not appear in the SBA 504 Limited or Special Purpose Property list in Section C of SOP 50 10 8.1. Storage units appear once, in Appendix 15, as an example for 7(a) business acquisitions. The list is not all-inclusive, so SBA may still determine that a storage property meets the Appendix 3 definition.
Does the special purpose property rule apply to SBA 7(a) loans?
Not as a contribution rule. Section B of SOP 50 10 8.1, the SBA 7(a) program chapters, does not use the term special purpose. Appendix 15 uses it for business acquisitions: where buying an owner-occupied Special Purpose Property is integral to buying the business, the loan can run up to 25 years if 85 percent or more of project costs are real estate, and valuation rules are stricter.
This page summarizes SBA SOP 50 10 8.1, 13 CFR 120.910 and 120.882 and 15 U.S.C. § 696 as retrieved 6 to 10 October 2026. It is general information, not legal, lending or appraisal advice. SBA policy changes. Confirm the classification and the contribution with your CDC before relying on any figure here.