Starting October 1, 2026, a lender financing a business purchase of $3 million or more with an SBA 7(a) loan has to commission an independent Quality of Earnings report before closing, and has to use that report's earnings to decide how much it can lend. Here is what changed and what it means for you.
The SBA published SOP 50 10 8.1 on August 14, 2026. Its new Appendix 15 applies to change-of-ownership loans approved on or after October 1, 2026. Deals in the pipeline now will close under the new rule.
Measured as the purchase agreement amount less any owner-occupied real estate at its appraised value.
An independent financial professional engaged by the lender, working for the lender's benefit.
A sell-side report passed along by a broker, or the buyer's own diligence, does not satisfy Appendix 15, however good the work.
Bank activity reconciled to reported receipts and disbursements and to the tax returns, for the trailing twelve months and the two most recent fiscal years. Plus normalized earnings with documented adjustments, and revenue quality including customer concentration.
The lender uses the report's normalized earnings, not the broker's add-backs, to decide how much it can lend. Minimum debt service coverage is 1.25x for initial acquisitions and owner buyouts, and 1.15x for business expansions.
Initial acquisitions and business expansions at $3 million or more are covered. Owner buyouts and ESOP or cooperative conversions are exempt from the QoE requirement.
The lender's QoE is not yours. It is prepared for the bank, on the bank's timeline, and its job is to tell the bank how much it can lend. Your own buy-side QoE still does the work it always did: telling you what the business really earns before you commit, and giving you a basis to negotiate.
The lender picks who writes its report. What that report finds is up to you. The add-backs you claim, the deposits that tie to your revenue, and the tax returns that agree with your books are all yours to get right in advance. A clean report supports the price. A clean report on a prepared business supports it faster.
Every $3M+ acquisition in your pipeline now needs an independent QoE you engage, with a cash proof, in a form your credit team can rely on for DSCR. Anchor Earnings prepares them, with no ties to the buyer, the seller, or the broker.
Not for the SBA loan. Appendix 15 requires a report engaged by the lender, for the lender. A sell-side report is still useful to you, because it tells you what an independent team will find, but the bank has to commission its own.
It adds a report to the closing checklist, so yes, unless the business is ready for it. A QoE on clean books with a working data room runs a few weeks. One that has to rebuild three years of records runs longer, and the clock is not on the seller's side. The fix is to prepare before the lender starts.
The SOP names a role, not a credential: someone experienced in this work, engaged by the lender, and independent of the buyer, the seller and anyone advocating for the deal. Most lenders will look for a team with a track record of these reports. Read Appendix 15 itself, or ask your lender what their credit policy requires.
Yes. We prep your financials for the Quality of Earnings, and because we are independent of your business we can perform the QoE as well. For the lender's own report under the SBA rule, the lender chooses its preparer, and you will already know what it finds.
This page summarizes SBA SOP 50 10 8.1, Appendix 15, as described in published guidance from BPM, EisnerAmper, Doeren Mayhew and PilieroMazza. It is a summary, not legal advice. Your lender's credit policy and the SOP itself control.
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