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Small Businesses Are Losing Two Important Cash-Flow Safety Nets 

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Small businesses have two common ways to survive a cash-flow crunch: borrow money or chase down unpaid bills. Both are getting less predictable at the same time. 

Small businesses are getting squeezed from two directions at once. It is harder to borrow your way through a cash-flow crunch, and it is riskier to trust whoever is collecting on your behalf. 

A deep dive from The Kaplan Group examines two rule changes moving through Washington right now, and what they mean for any business caught in the gap between billing a customer and actually getting paid.

Key Takeaways

  • The Small Business Administration (SBA) dropped its quick credit score check for small loans on March 1, 2026. A fuller credit review took its place, and it now varies by lender.
  • The Consumer Financial Protection Bureau (CFPB) may drop about 95% of supervised debt collectors from routine federal exams. That only happens if it picks the highest threshold on the table.
  • Overdue invoices make up 43% of credit-based B2B sales across North America. Both changes land just when small businesses need help the most.

Two Backup Plans, Both Changing Shape

Small businesses live in the gap between sending an invoice and getting paid. When that gap gets too wide, owners usually turn to one of two backup plans. They either borrow money to cover the shortfall, or they hire a collector to chase down what they are owed.

In 2026, both backup plans are changing shape at the same time. Borrowing became slower and less predictable, and hiring a collector became a little riskier to do without research. Neither change makes it illegal or technically harder to get a loan or collect a debt, but together they make surviving a cash crunch less forgiving than it used to be.

What Changed With SBA Loans

For years, a small business applying for an SBA loan of $350,000 or less could get a fast answer. Lenders checked a single number called the SBSS score, and a high enough score meant quick approval. That system ended on March 1, 2026, and the SBA no longer requires the check at all.

Lenders now apply the same credit review they use for similar loans the SBA does not guarantee. They may still use their own scoring models, but those models cannot rely only on the owner’s personal credit score.

The new rules also add specific steps. Lenders must review at least two months of business bank statements and write a short summary covering the business, its owners, and the loan request. They must explain why the borrower cannot get credit elsewhere. And they must confirm the business earns at least 1.1 times what it owes each month in debt payments, a test known as the debt service coverage ratio.

No single number guarantees a fast yes anymore. Because each bank sets its own process, approval times and approval odds can vary widely from one lender to the next.

This matters because overdue invoices make up 43% of credit-based B2B sales across North America. The average small business with unpaid invoices is owed roughly $17,500 in total. Business bankruptcy filings reached 24,737 in 2025, about 9% above the 2019 level and 83% above the 2022 low.

Businesses with the messiest cash flow are usually the ones whose own customers pay late, and they are exactly the businesses that will struggle most under a slower, less predictable review.

What Is Changing At The CFPB

The Consumer Financial Protection Bureau is the federal agency that watches debt collectors. Right now, any collection company earning more than $10 million a year falls under its direct supervision, a threshold that has not changed since 2012.

In August 2025, the CFPB asked the public whether it should raise that number. It floated three options: $25 million, $50 million, or $100 million. At the highest of those, roughly 95% of the collectors now supervised would drop out of routine examination. At a $25 million threshold, roughly 100 to 125 agencies would remain larger participants; at $50 million, 60 to 90; at $100 million, 11 to 64.

95 of Every 100 Supervised Collectors Could Drop Out.

That is the CFPB’s own estimate at the highest threshold it is weighing: $100 million in annual receipts.

Each dot = 1% of collection agencies now under routine CFPB supervision

Still a “larger participant” Falls below the threshold
Where it stands
  1. 1Advance notice only — no rule issued yet
  2. 2Comments closed September 2025
  3. 3Proposal expected September 2026
  4. 419 state AGs urged the CFPB to drop it

The three options on the table

$25 million100–125 agencies remain
$50 million60–90 agencies remain
$100 million11–64 agencies remain

Today’s threshold is $10 million, unchanged since 2012.

But the agencies still covered would account for most of the market’s revenue.

Source: CFPB advance notice of proposed rulemaking, Docket CFPB-2025-0030, August 2025. Percentage is the CFPB’s estimate for the $100 million option; it did not publish shares for the others.

The agency also pointed to a gap in its own rules. The SBA considers a collection agency small if it earns less than $19.5 million a year, which is nearly double the CFPB’s cutoff. A company can therefore be a small business to one agency and a large participant to another.

None of this is final, it is an advance notice, the step that comes before a proposal. Public comments closed in September 2025, and no rule has been issued since.

That may change soon. The CFPB’s own regulatory agenda points to a formal proposal in September 2026, which would finally name a specific number instead of three options. But that target was set in January 2026, before several months of agency changes, and agenda dates often slip. Nineteen state attorneys general have also urged the Bureau to drop the plan.

This Does Not Make Collecting Illegal

It is worth being precise here. Nothing in the CFPB’s plan takes away a business’s right to collect what it is owed, and nothing makes chasing an unpaid invoice against the law. What could change is how often mid-size collectors get examined on things like call limits and credit reporting timelines. Less routine review could make some of them less careful.

Collectors outside the CFPB’s close supervision still have to follow the federal Fair Debt Collection Practices Act for consumer debt. State regulators can still take action, and consumers can still sue. The honest way to describe this shift is that one layer of routine checkups gets thinner, not that the rules disappear.

The enforcement record backs that up. Nine debt collection enforcement actions were tracked in 2025, down from 16 the year before. Six of those nine came from the Federal Trade Commission, not the CFPB. Oversight is not vanishing so much as moving. States and cities are also writing denser rules, and New York City’s new collection rule takes effect in January 2027.

Is This All Overblown?

Both stories deserve a reality check. SBA lending has not dried up, and loan limits actually increased in 2026. The combined cap for 7(a) and 504 loans doubled to $10 million, effective July 4. Some loan types, including SBA Express, were not affected by the score change at all. A business with clean, organized books can probably still get approved, and possibly quite quickly.

On the collections side, the industry has been shrinking for years. It has fallen from about 4,500 firms in 2012 to somewhere between 2,500 and 3,000 today. Smaller collectors rarely drew close CFPB attention anyway, because examinations already concentrated on the biggest players.

So this is not a sudden collapse in either direction. It is a gradual tightening, and it hits hardest for businesses that were already struggling to keep clean books or choose trustworthy partners.

The Best Protected Businesses Are Already Doing This

Here is the thread connecting both changes. A business that collects quickly and keeps tidy books needs less emergency borrowing, because it is not waiting as long to get paid. And if it does need a loan, its paperwork already resembles what the new SBA rules expect to see.

The same logic applies to hiring a collector. In a world with less routine federal review, the choice of partner matters more than ever. Look for a strong compliance record, limits on how often the agency calls, a waiting period before it reports debt to credit bureaus, and easy opt-outs. Do not simply assume that every collector is being watched closely by the government.

In short, businesses that stay on top of their own receivables and choose their partners carefully are far better protected from both of these shifts. The ones at risk are those hoping to lean on borrowed money, or on oversight that may no longer be there.

Methodology

This analysis draws on two SBA procedural notices, 5000-875701 and 5000-876777. They ended the SBSS score and set the rules that replaced it, including the 1.1:1 debt service coverage ratio and the bank statement review. Both amend SOP 50 10 8 and took effect March 1, 2026. The loan limit change comes from SBA Policy Notice 5000-879058, announced May 18, 2026.

Oversight figures come from the CFPB’s advance notice on the Consumer Debt Collection Larger Participant Rule, published August 8, 2025 (Docket CFPB-2025-0030). It is the source for the $19.5 million size standard, the industry counts, and the agency estimates at each threshold. Timing for the expected proposal comes from the CFPB’s 2026 regulatory agenda, released July 6, 2026, which is current only through January 13, 2026.

Enforcement counts come from Goodwin’s 2025 year-in-review tracking of debt collection and debt settlement actions.

Late payment figures come from the Atradius Payment Practices Barometer 2025 for North America and the 2025 Intuit QuickBooks Small Business Late Payments Report. Bankruptcy counts come from the Administrative Office of the U.S. Courts.

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