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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

On Friday, Dec. 5, the U.S. Small Business Administration (SBA) sent letters to all 4,300 8(a) Business Development Program (8(a) Program) participants requiring production of detailed financial records for the last three years. Contractors must comply with the SBA’s request by <strong>Jan. 5, 2026</strong>. Noncompliance may lead to loss of 8(a) Program certification, further investigation and remedial actions.

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The records to be produced include, but are not limited to:

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Contracting and subcontracting agreements

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The 8(a) Program was established to create growth opportunities for socially and economically disadvantaged small businesses. In July 2025 SBA Administrator Kelly Loeffler ordered a full audit of the 8(a) Program after a Department of Justice investigation uncovered a $550 million fraud and bribery scheme and amidst growing media reports of misconduct within the 8(a) Program. The requirement that all 8(a) Program participants produce financial records is touted by the SBA as its next effort to address fraud, waste and abuse.

Federal contractors who are participants in the 8(a) Program should immediately take the following actions:

Acknowledge receipt of the letter or email from SBA.

Check spam folders to ensure the request was not misdirected.

Read the letter carefully to understand each request.

Conduct an internal audit of all records before submitting them to the SBA.

Assess and ensure regulatory compliance with 8(a) Program requirements.

Our Aerospace, Defense and Government Services industry group is here to assist companies with these SBA requests. Please reach out to Aida Dismondy, Adam Bruski, Mike Stone or your Warner attorney.

Aerospace and Defense

Government and DoD Contracting

Senior Counsel

Aida Dismondy

Adam D. Bruski

Partner

Michael A. “Mike” Stone

Regulatory and Compliance

SBA Requires 8(a) Federal Contracting Program Participants to Produce Financial Records

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SBA Requires 8(a) Federal Contracting Program Participants to Produce Financial Records

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