Let me make sure I understand precisely what you are saying. As I understand what you've written, for the company's purposes, it is sufficient for them to know the names and the amount of holdings of each shareholder, and it would not be necessary for each beneficial owner to declare themselves a NOBO to their broker/dealer?
I understand the benefit of that to the company in terms of effective communication and attendant costs. I do not see how that would benefit them in any way with the SBA. (But, I would be delighted if it did)
If the above is the case/substantially the case, I think it incumbent upon the company to so state and unequivocally declare that this will satisfy the SBA's requirements.
"Libenter homines id quod volunt credunt"