role of the CDC to obtain SBA approval of the 504 loans. (Doc. No. 37 at 751.) The CDC representative working on Loadman's loans was Ralph Ansell ("Ansell") of the CDC Self-Help Ventures Fund. (Id. at 752, 833; Doc. No. 38 at [Ansell Dep.] 980.) Ansell testified that the SBA's 504 loan program require