The First Funded
The first known AI-generated credit writeup submitted, approved, and funded through the U.S. SBA 504 program — a 75-year-old institution. Nine months of live trials led to this moment. January 2023.
The Juan Pollo transaction didn’t arrive from nowhere. It was the product of nine months of systematic, live testing — real commercial transactions, real borrowers, real stakes — conducted quietly across industries throughout 2022. These were not simulations. Each deal was a funded loan, with Indigo Commercial Funding running OpenAI’s API directly inside the underwriting workflow.
Starting in April 2022, a series of SBA 504 transactions became the proving ground for what would become Trial 9 — the Generative AI trial. Thirteen distinct borrower engagements preceded the historic submission, building confidence in the model, refining the workflow, and establishing the human-in-the-loop review standard that made the final step possible.
Every transaction in the sequence above ran OpenAI’s API inside a live commercial credit workflow — industry analysis, market context, risk narrative — generated, reviewed, and approved by a licensed credit officer before submission. Juan Pollo was the one that crossed the finish line first: submitted to the SBA, authorized, and sold to a major money center bank.
When Trial 1 ran on April 19, 2022 — Xtreme Tint, Whittier, California — ChatGPT did not exist. The application that would reach 100 million users faster than any product in history would not launch for another seven months. What Indigo Commercial Funding operated with was something more fundamental: direct programmatic access to GPT-3 through OpenAI’s REST API — a tool available only to developers with an API key and the ability to write code against it.
There was no chat interface. No consumer product. A credit officer constructed text prompts, submitted them to the API as single-turn completions, reviewed every output against source documents, and incorporated approved content into institutional credit memoranda. The human-in-the-loop wasn’t a design philosophy adopted for regulatory optics. It was the only available workflow. And the AI authorship was disclosed — in footnote 1, page 10 of the CAM.
ChatGPT launched November 28, 2022. By that date, ten of the thirteen preceding trial transactions had already closed. Juan Pollo was approved six weeks later. The trials that produced the first AI-funded SBA deal in history were conducted almost entirely before the world discovered what these models could do.
Juan Pollo Mora, Inc. is a minority-owned, family-operated franchisee of the Juan Pollo rotisserie chicken chain — a Southern California institution since 1984. The owner-operators had run their first franchise location (Juan Pollo #22) in Upland since 1994 — nearly three decades in the business. This transaction financed the purchase of a permanent property at 273 East 9th Street in Downtown Upland to relocate and stabilize that location.
The SBA 504 structure brought together three parties: Indigo Commercial Funding providing the senior 1st Trust Deed, AmPac Business Capital (the CDC) funding the SBA debenture, and the borrowers contributing the 10% equity injection from personal savings. Total project cost: $1,236,650. A 25-year, fully amortizing structure for a 2,100 SF freestanding restaurant building — a permanent home for a business that had been leasing for thirty years.
| Borrower | EPC / Co-Borrowers (Individual) |
| Operating Co. | Juan Pollo Mora, Inc. (dba Juan Pollo #22) |
| Property | 273 East 9th Street, Upland, CA 91786 |
| Property Type | 2,100 SF Freestanding Restaurant · Downtown Upland |
| Purchase Price | $1,200,000 |
| Senior Lender | Indigo Commercial Funding I, LLC |
| CDC | AmPac Tri-State CDC, Inc. (dba AmPac Business Capital) |
| SBA Loan # | 47353491-02 |
| Approval Date | January 10, 2023 |
| Credit Officer | Matthew Dobson, Chief Credit Officer — Indigo Investment Servicing, LLC |
Loan Structure
The credit package included three years of business tax returns, a 10-month interim financial statement, and a two-year forward projection. The operating company — incorporated in December 2019 after nearly 26 years as a sole proprietorship — showed the classic COVID-19 recovery arc: a 2020 loss, a strong 2021 rebound of 24.2% revenue growth, and a continued trajectory into 2022. The key addback in the cash flow analysis was the elimination of non-recurring rent for Juan Pollo #22, which the property purchase permanently removed from the debt service calculation.
The 2020 DSCR of 0.61x reflected mandatory restaurant closures and the pivot to take-out only operations. The operating company absorbed the disruption without bankruptcy, maintained its customer base, and grew revenues 24.2% in 2021 as restrictions lifted. The key cash flow adjustment: non-recurring rent for Juan Pollo #22 was added back in full, as the property purchase permanently eliminates that lease obligation. A 2% rate shock sensitivity analysis on Year 1 projections yielded 1.86x — well above threshold.
The SBA Authorization for Debenture Guarantee is the final stamp of approval in the 504 program — issued by the Sacramento Loan Processing Center after the full credit package has been reviewed. It authorizes the CDC to issue the debenture, specifies all loan terms, and is signed by an authorized SBA representative. For this transaction, that signature came on January 10, 2023.
Following the precedent set by Google’s open-sourcing of “Attention Is All You Need,” the primary source documents for this historic transaction are available on request. The AI disclosure is in footnote 1 of page 10 of the CAM. The SBA Authorization is the final proof of approval.
22-page institutional CAM prepared by Indigo Investment Servicing, LLC. Includes the OpenAI disclosure in footnote 1, page 10. Investment committee signatures dated January 16–17, 2023.
15-page U.S. Small Business Administration authorization. SBA Loan #47353491-02. Signed January 10, 2023, by Authorized SBA Representative, Sacramento Loan Processing Center.
The First Funded — First AI-Generated SBA 504 Credit Writeup in History
The first known AI-generated credit writeup submitted, approved, and funded in the 75-year history of the U.S. SBA 504 program. SBA Loan #47353491-02, authorized January 10, 2023. Borrower: Juan Pollo Mora, Inc., Upland, California. Third-party lender: Indigo Commercial Funding I, LLC. CDC: AmPac Tri-State CDC, Inc. (AmPac Business Capital). Project total: $1,236,650. OpenAI API used for industry analysis sections, disclosed in footnote 1 of the Credit Analysis Memorandum prepared by Indigo Investment Servicing, LLC. Preceded by 13 live OpenAI trial transactions from April 2022 through January 2023. AVA Credit Inc., Toronto, Ontario, Canada.