Probably some inaccurate generalizations at work here. (There's a lot of those in ZFS, unfortunately.)
I would say that the following statements are more likely to be what was intended:
"Some lower-end HBAs might not be able to offer the full performance of a large number of SATA SSDs"
The early generation SAS2008 (Dell H200/H310, IBM M1015) cards aren't suitable for handling a large number of SSDs from a performance perspective.
"SATA SSDs have issue with TRIM behind some HBAs"
Also true, most LSI HBAs require the SSD to have specific requirements which aren't necessarily found in many consumer SSDs (Deterministic Read Zero After TRIM, sometimes called DRAT or RZAT by vendors)
TRIM and SG_UNMAP support for LSI HBAs and RAID controllers
www.broadcom.com
I and many others are running SATA SSDs through HBAs, including through SAS expanders.