Federal data released November 5 show that banks made 217,253 fewer small-business loans in 2025 to firms with $1 million or less in annual revenue. One bank accounts for the net drop. JPMorgan Chase reported 1,439,055 such loans in 2025, down 242,249 from 1,681,304, while every other reporting bank combined made 24,996 more.1 2 The national figure comes from the agencies' Community Reinvestment Act tables; the bank figures come from the same agencies' bank-level files.3 2
What changed:
JPMorgan's total small-business originations fell to 1,776,436 from 2,219,044, a 19.9% drop. In 2025, 99.6% of them were under $100,000, at an average of about $12,600.1
Among the other largest reporters, Bank of America reported 81,917 fewer loans to small firms, Capital One 28,018 fewer and American Express 17,233 fewer, while Citibank reported 25,322 more. Outside JPMorgan and Bank of America, loans to small firms rose by 106,913, or 4.1%.1
The biggest gains came at Wells Fargo, up to 118,875 from 68,567, Truist, up to 101,785 from 70,513, and TD Bank, up to 74,352 from 48,148. Of the banks reporting in either year, 377 made more such loans and 329 made fewer, so the gain is a combined figure, not a rise at every bank.1
What these loans are: the files do not say whether a loan is a credit card line, a small line of credit or a term loan, so they cannot tell you whether the loans missing from JPMorgan's 2025 count looked like the working capital a funder offers. They do show size: JPMorgan's 2025 small-business originations averaged about $12,600, and the largest reporter by count, American Express National Bank, made 2,348,368 small-business originations averaging about $16,100.1 Read the 242,249 as loans, not merchants: a business with two loans counts twice, and none of these figures says a merchant lost working capital. We found no JPMorgan statement explaining the change, and the files cannot rule out a change in how the bank reports these loans rather than in how much it lent.
Bottom line for funders: this is not a bank retreat from small business. Dollars lent to firms with $1 million or less in revenue rose to $92.1 billion in 2025 from about $89.0 billion, by our arithmetic from the published shares, and outside JPMorgan the small-firm count grew.2 1 The net national drop is a JPMorgan number, with Bank of America a distant second at 81,917, so it tells you about your market only to the extent those banks lend there.
What Alternative Business Lenders Need to Know
Why this matters to an MCA, factoring or revenue-based funder: the CRA's $1 million revenue flag is the closest public line this data set draws to the small merchant those funders typically serve. On November 3 we covered banks tightening credit to nonbank lenders, the funding side.4 This is the customer side: how many loans banks made to the businesses you also serve, and which banks changed.
What did the agencies report?
The CRA disclosure covers business loans of $1 million or less made by banks with assets of $1.609 billion or more, plus banks that report voluntarily; 720 lenders reported for 2025, against 732 a year earlier.5 The fact sheet says "the number of loans originated decreased by 2 percent relative to 2024" and "the dollar amount of small business loans originated increased by 4.7 percent."5 Originations to businesses with revenue of $1 million or less were 4,481,524 loans and $92.1 billion, 52.4% of all originations by count, down from 53.8%.2 ABA Banking Journal reported the release's loan counts the same day.6
How do we know one bank explains the net drop?
The agencies publish the data behind the national tables as bank-level flat files. We read the 2025 file and the revised 2024 file, took each bank's national totals for small-business originations, and added them up. For 2025 the sums match the published tables exactly: 8,559,067 originations and 4,481,524 loans to small firms. For 2024 they give 8,734,573 originations, the published total, and 4,698,777 loans to small firms, which is the published 53.8% share.1 2 So the 217,253 decline is the agencies' own data summed, not an estimate.
From there the arithmetic is short. JPMorgan's small-firm count fell by 242,249. Every other bank together rose by 24,996, from 3,017,473 to 3,042,469.1 Anyone can repeat this from the public files; the agencies' data products page links them.7 Loans to small firms, 2024 to 2025, at the five largest reporters by total 2025 originations:1
American Express National Bank: 438,447 to 421,214
JPMorgan Chase Bank: 1,681,304 to 1,439,055
Citibank: 447,199 to 472,521
Bank of America: 385,565 to 303,648
Capital One: 273,158 to 245,140
What the files cannot tell us is whether the JPMorgan change is lending or reporting. The files record what each bank reported, so they cannot separate a change in lending from a change in which loans a bank counted, and the 2024 figures here come from the agencies' revised 2024 file. JPMorgan has published no explanation that we could find, and we have not confirmed the cause with the bank. Treat the 242,249 as what JPMorgan reported, not as proof of a pullback in credit.
What kind of loans make up this count?
Mostly very small ones. Nationally, 94.6% of 2025 originations were under $100,000, and banks with $10 billion or more in assets made 87.5% of all originations.2 The bank-level averages show who writes the smallest tickets: Synchrony Bank about $4,300, Citibank about $5,800, JPMorgan about $12,600 and American Express about $16,100, against about $38,300 at Wells Fargo.1 The bank with the largest gain points the other way: Wells Fargo added 50,308 loans to small firms, and its originations averaged about three times JPMorgan's.1 These averages cover each bank's small-business originations, not only its loans to small firms, and we do not have them for Truist or TD, so read this as one bank's pattern, not a rule.
What the numbers do say is that a few very large banks with very small average loans dominate the count. When one of them reports far fewer loans, the national total can move by hundreds of thousands in a year even while more banks report gains than declines. That is why the national figure says less about your market than the bank and county files do.
Is bank credit to small firms tightening?
Only slightly, by the Fed's latest read. In the October loan officer survey, banks reported that standards "tightened for C&I loans to small firms," with tighter collateral requirements, and named "customer borrowing shifting to more attractive bank or nonbank funding sources" as one reason demand weakened.8 The move was small: 4 of 59 banks tightened standards for small firms and 1 eased, and none of the 21 banks in the survey's large-bank group tightened. The survey's small firms have sales under $50 million, far larger than the CRA's $1 million line.9
Where do small firms apply, and who reaches you?
The Federal Reserve Banks' Small Business Credit Survey gives the best public read. In the 2025 survey, 29% of employer firms that applied for a loan, line of credit or cash advance applied at an online lender, up from 17% in the 2020 survey; the report says that share rose for the fifth consecutive survey year.10 Across all employer firms, 8% applied for a merchant cash advance, and of those applicants 48% were fully approved, 40% partially approved and 12% denied.10
The survey also found that medium- and high-credit-risk applicants were much more likely than low-risk applicants to apply at online lenders.10 The survey does not say which firms a bank stopped serving, but it suggests that a rise in application volume may bring a riskier mix of files, not only more of them. Sixty percent of online-lender borrowers said their costs ran higher than expected, against 37% at small banks and 32% at large banks.10
How can a funder check its own markets?
Pull the disclosure reports for the banks that dominate your top counties and compare 2024 with 2025; the aggregate reports give the county totals, reported in three loan-size bands at the census-tract level.7 5 If the banks that fell nationally also fell in your top counties, those counties are where to look first in your own application data.
The limits: the CRA data count loans made, "but not applications for loans that were not originated," so they cannot show a denial or where a firm went next.5 The revenue field is a yes-or-no flag at $1 million. Fewer banks reported, 720 against 732, which can move the combined counts by itself.5 2024 was the high point of the seven-year national table, and the 2025 small-firm count is about where it was in 2022.2
Our Opinion
The national headline will be read as "banks retreat from small business," and the bank-level data say otherwise. One very large bank accounts for the net drop, Bank of America also reported fewer, and the rest of the banking market, taken together, reported more than it did a year earlier. Funders who build a 2026 plan on a broad bank retreat would be building it on the reported counts of one or two banks.
For the next 90 days, three moves. First, tag your 2024 and 2025 applications with the merchant's primary bank, which most MCA files already show in the bank statements, and compare the Chase-banked share across the two years. A very large bank will always show up often in your files, so only the change between years means anything, and a rise is a signal worth watching, not proof that JPMorgan's lower count sent those merchants to you. Second, add broker capacity only where two signals line up: your Chase-banked share is rising, and the county disclosure reports show the same banks falling in those counties. Third, make the cost disclosure the center of the sale, not the paperwork at the end, because a merchant who used to borrow from a bank will compare your offer with that experience: New York, for one, requires sales-based financing providers to disclose the finance charge, the estimated annual percentage rate and the total repayment amount when they make an offer.11 Six in ten online-lender borrowers told the Fed their costs ran higher than expected, against about a third at banks; a disclosed number that matches what the merchant later pays is the plain answer to that gap.
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KBRA's Q3 2026 compendium covers 3,070 sponsored borrowers with more than $1.4 trillion of direct lending debt. On KBRA's Middle Market Default Monitor, the default rate for lower middle market borrowers reached 5.8%, against 3.6% by count for the whole portfolio, and downgrades hit a record 121. A record 31% of new assessments came in at ccc+ or lower, though KBRA cautions that a new assessment can be its first look at a seasoned loan.12 These borrowers are far larger than an MCA merchant. If your warehouse or forward-flow capital comes from a direct-lending fund, ask how much of that fund's book sits in the lower middle market.
Chicago private credit manager Victory Park Capital has provided a $100 million facility to Billd, an Austin lender that gives commercial construction subcontractors working capital tied to construction payment cycles, Alternative Credit Investor reported November 6. Pricing, advance rate and term were not disclosed.13 It follows Victory Park's October 2025 $100 million facility to Libertas Funding, a working-capital provider to small and medium-sized businesses that said it funded nearly 1,800 deals in 2024.14 For a factoring or revenue-based shop that funds construction subcontractors, Billd is a newly funded competitor for those subcontractors' working-capital needs.
LoanBud, a marketplace that links borrowers with SBA lenders, launched LoanBud Acquire in October to finance purchases of established small businesses priced at $100,000 to $350,000, outside the SBA program and with a 15% buyer equity injection, American Banker reported. CEO Burke Purcell said the company's SBA marketplace has more than 50 bank capital partners but "virtually none" have shown interest in small acquisition loans at scale. The article says lenders sidestep these deals because they take as long to underwrite as larger ones and carry no SBA guarantee; most are financed with buyer cash and seller financing. LoanBud is working with a select group of capital providers and is seeking banks and credit unions.15 For an MCA or revenue-based shop, this is not a competing product; the businesses it helps buyers acquire may need working capital after closing.
Sources
1 FFIEC | CRA Flat Files: 2025 and revised 2024 disclosure files (table D1-1) and transmittal sheets (Nov. 5, 2026)
2 FFIEC | 2025 CRA Fact Sheet Tables, Tables 1.1, 2 and 3 (Nov. 5, 2026)
3 Federal Financial Institutions Examination Council | Federal Bank Regulatory Agencies Release 2025 Small Business, Small Farm, and Community Development Lending Data (Nov. 5, 2026)
4 Beyond Banks | Fed: 12 of 50 Banks Tighten Nonbank Lender Credit (Nov. 3, 2026)
5 FFIEC | 2025 CRA Small Business, Small Farm, and Community Development Lending Data Fact Sheet (Nov. 5, 2026)
6 ABA Banking Journal | Banking agencies release CRA data on small-business, small-farm lending in 2025 (Nov. 5, 2026)
7 FFIEC | CRA Data Products: aggregate, disclosure and flat files
8 Board of Governors of the Federal Reserve System | The October 2026 Senior Loan Officer Opinion Survey on Bank Lending Practices (Nov. 2, 2026)
9 Board of Governors of the Federal Reserve System | October 2026 Senior Loan Officer Opinion Survey, Table 1, Question 1 (Nov. 2, 2026)
10 Federal Reserve Banks | 2026 Report on Employer Firms: Findings from the 2025 Small Business Credit Survey (Mar. 3, 2026)
11 New York State Senate | Financial Services Law Section 803: Sales-based financing disclosures
12 KBRA via Business Wire | Private Credit: Q3 2026 Middle Market Compendium: Direct Lending's Smallest Borrowers and Largest Sectors Showing Signs of Stress (Nov. 5, 2026)
13 Alternative Credit Investor | Victory Park backs construction lender Billd with $100m facility (Nov. 6, 2026)
14 Alternative Credit Investor | Victory Park Capital backs Libertas with $100m credit facility (Oct. 8, 2025)
15 American Banker | Fintech targets small-business niche that banks have spurned (Nov. 5, 2026)
