Since October 1, 2026, SBA SOP 50 10 8.1 requires a Quality of Earnings (QoE) report on 7(a) acquisitions with a business purchase price of $3 million or more. Our two-page checklist shows whether your deal is covered and how to get ready before the lender orders the work.
Get the Free ChecklistThe test is the business purchase price, measured before buyer equity, seller debt or other financing. It is not the loan amount.
The QoE must be done for the lender’s benefit. A report prepared by or for the seller cannot be used.
The report reconciles financial statements, tax returns and IRS transcript data, and rebuilds cash for the trailing 12 months and the last two fiscal years.
The QoE is in addition to the business valuation. It does not replace it.
General information summarizing SBA SOP 50 10 8.1 as of its October 1, 2026 effective date, not legal, tax or lending advice. Read our full guide to the rule.
Quality of Earnings experience from PwC, failed-bank resolution work for the FDIC, and businesses our partners have bought and run themselves.
Founding Partner
James did Quality of Earnings work at PwC, where he was Head of the Turnaround & Restructuring practice for the Southeastern U.S. Since COVID-19 he has built a portfolio of businesses acquired from retiring owners, so he has sat on the buyer’s side of the table himself.
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Founding Partner
David has more than 20 years in financial analysis and accounting. He has served as a subject matter expert to the FDIC on resolving failed banks, consulting on more than 20 bank resolutions during the crisis that began in 2008. He is a CPA (non-practicing) and managing member of several operating companies.
Read full bioCRWN holds a Michigan CPA firm permit. Our Managing Partner, Steve Wilmers, CPA, is a former commercial lender at The Bank of Holland.