SBA lender quality of earnings with cash proof

Earnings, proven to the bank statement. Delivered in ten days.

Credex Advisors prepares the independent quality of earnings report with cash proof that SBA 7(a) lenders must obtain under SOP 50 10 8.1 for Initial Acquisition and Business Expansion loans with a purchase price of $3,000,000 or more. Lender engaged, CPA prepared, fixed fee from $12,500, delivered in ten business days from complete seller documents, and written to hold up in credit committee, SBA loan review, and a guaranty purchase.

Last updated September 2026
The requirement, in brief.
Effective
Loan numbers issued on or after October 1, 2026
Applies to
Initial Acquisition and Business Expansion deals with a purchase price of $3,000,000 or more, measured before buyer equity, seller debt, or other financing
Engaged by
The lender, with an engagement letter in place at loan number
Must include
Cash proof of TTM and each of the two prior fiscal years, normalized earnings with each add back supported, revenue sustainability
Feeds
DSC of 1.25x for acquisitions, 1.15x for expansions
Who pays
May be passed to the borrower, financed, and counted toward equity injection
Source
SOP 50 10 8.1, Appendix 15, Section C
10 days
From complete documents, against the three to four weeks most providers quote. Five, expedited.
From $12,500
Fixed by purchase price tier. May be passed to the borrower and financed.
36 months
Of bank activity proven, every transaction, not a sample.
A CPA firm
CPAs on every engagement, a partner on every conclusion.

The four things lenders worry about, answered.

Cost

Fixed fees tiered to purchase price and published below. No hourly billing. Most 7(a) deals over $3M fall between $12,500 and $20,000, and under Appendix 15 the fee can be passed to the borrower, financed with loan proceeds, and counted toward the equity injection.

Timeline

Most providers quote three to four weeks from complete information. Credex delivers in ten business days from the day the seller's documents are complete, five on an expedited basis, with a written flash on any material exception by day five so you can pause, restructure, or walk away early.

A qualified provider

A licensed CPA firm with CPAs on every engagement, engaged by and working for the lender, independent of the borrower, the seller, and the broker. One review of the standard statement of work and engagement letter with credit and legal, then every deal uses the same paper.

Findings you can use

Every add back individually identified and supported, never netted into a single total. A DSC schedule in your template, a one page credit memo insert, and a report mapped procedure by procedure to Appendix 15 so the file self certifies against the SOP.

Fixed fee schedule.

Fees assume one operating entity, one set of books, up to six bank and card accounts, electronic access to revenue and customer data, and a cooperative seller. Multiple entities, carve outs, or more than six accounts are quoted as adjustments before engagement, never after.
Business purchase price
Base scope fee
Working capital module
Expedited, 5 business days
$3.0M to $4.0M
$12,500
+ $3,000
+ 40% of base fee
$4.0M to $6.0M
$16,500
+ $3,000
+ 40% of base fee
$6.0M to $7.5M
$20,000
+ $4,000
+ 40% of base fee
$7.5M to $10.0M
$24,000
+ $4,000
+ 40% of base fee
$10.0M and above
Quoted, from $30,000
Quoted
Quoted

Inside every Credex lender QoE.

Cash proof, three periods.
Bank receipts and disbursements, every account and every transaction, reconciled to the financial statements, the filed tax returns, and the IRS transcripts the lender orders, for FY-2, FY-1, and TTM, with every variance explained.
Normalized earnings.
Adjusted EBITDA by period across the four adjustment categories the SOP names: non recurring items, owner compensation, related party transactions, and deferred maintenance and capital expenditures. Each add back accepted, reduced, or rejected on evidence, plus the adjustments the seller did not propose.
Cash to accrual conversion.
Where the seller keeps cash basis books, revenue and expenses are restated to an accrual basis for receivables, payables, prepaids, accrued payroll, inventory, and deferred revenue, as the SOP requires.
Owner and related party analysis.
Owner compensation reset to a market benchmark, family payroll, personal and non business expenses, and related party rent, wages, or services restated to arm's length.
Revenue sustainability.
Concentration, retention, contract terms, pricing and margin trends, with a plain conclusion.
DSC inputs and credit memo insert.
Earnings on the last fiscal year and two year average basis in your template, and a one page summary written for the credit presentation.
Report and databook.
Final report with supporting schedules in Excel for the loan file, retained to support any later SBA review.

How the engagement runs.

Before the clock starts

Engage and collect

Letter countersigned within one business day. The seller uploads directly to the Credex portal; you are copied on status and never chase documents.
Days 1 to 3

Intake

Bank data, ledgers, statements, and returns loaded to the Credex diligence platform and checked for completeness.
Days 3 to 7

Cash proof

Receipts and disbursements reconciled to reported revenue and expense for FY-2, FY-1, and TTM. Exceptions investigated.
Days 5 to 7

Normalize and assess

Add backs rebuilt from source, owner compensation reset to market, related party items isolated, capex and cash to accrual adjustments made, customer and margin trends tested.
Days 7 to 8

Seller interview

A recorded call with the seller and the seller's accountant to walk through the cash proof exceptions, the trends, and how the business actually runs. Answers go into the report, not into a footnote.
Days 8 to 10

Report

Partner reviewed draft, lender review call, final report with DSC schedule, credit memo insert, and Excel databook.
Day 5
interim flash
Find out early if the deal will not work. Within five business days of receiving complete bank data we send a short note on any material exception: unreported deposits, personal spending in the ledger, a customer that carries the business, or earnings that do not survive the cash proof. You can pause, restructure, or walk away before the full timeline is spent.

Five things the credit file has to show.

Every Credex lender QoE closes with a one page credit memo insert that answers these five items in order, so a reviewer can confirm the SOP was met without reading the whole report.
01
Purchase price is $3 million or more, measured before buyer equity, seller debt, and other financing.
02
The report was engaged by, and prepared for, the lender, not the borrower or the seller.
03
The cash proof covers the trailing twelve months and each of the last two fiscal years.
04
Every add back is individually identified and supported, not netted into a single total.
05
The QoE earnings figure is the one used in the debt service coverage calculation.

Questions SBA lenders ask.

When does the SBA quality of earnings requirement take effect and what does it apply to?

It applies to loans that receive an SBA loan number on or after October 1, 2026, under SOP 50 10 8.1. The trigger is an Initial Acquisition or Business Expansion change of ownership with a business purchase price of $3,000,000 or more. Owner buyouts and ESOP or cooperative transactions are exempt.

Who is allowed to prepare the QoE for an SBA loan?

An independent, experienced financial professional engaged by the lender and working for the benefit of the lender. The borrower, the seller, and the broker cannot supply it, and a report they commissioned does not satisfy the SOP. Credex Advisors is a licensed CPA firm engaged directly by the lender.

Does the QoE replace the business valuation?

No. The SOP requires both. The valuation supports the purchase price; the QoE tests whether the earnings behind that price are real and sustainable, and the lender must use the QoE earnings in the debt service coverage calculation.

What is a cash proof and why does the SBA require one?

A cash proof reconciles the revenue and expenses on the financial statements and tax returns to the cash that actually moved through the bank accounts. It is the one procedure that catches unreported deposits, personal spending in the ledger, and earnings that exist on paper only.

When do we have to engage the QoE vendor?

Under PLP authority, a vendor must be retained and an engagement letter must be in place when the SBA loan number is issued; the report itself can follow. Credex countersigns within one business day of a request, so the file is never held up on this.

How long does it take, and what if the seller is slow?

Ten business days from complete seller documents, five expedited. The engagement letter ties the delivery date to document delivery, Credex requests documents from the seller and the seller's accountant directly, and you are copied on every status note. A slow seller extends the seller's clock, not yours.

What adjustments does the SOP require in the normalized earnings?

Appendix 15 names four categories: non recurring items, owner compensation restated to market, related party transactions restated to arm's length, and deferred maintenance and capital expenditures, plus a conversion from cash basis to accrual basis where the seller's books are kept on a cash basis. A Credex report presents each adjustment on its own line with its support, so the lender can see the management adjusted number and the diligence supported number side by side.

Does an audited financial statement satisfy the requirement?

No. An audit opines that the statements are fairly stated for a fiscal year. It does not test whether the earnings recur, does not produce an adjusted earnings figure, and is not engaged by the lender. The QoE is a separate diligence report and is required even when the target has audited statements.

Who pays for the QoE?

The lender engages Credex, but under Appendix 15 the cost of financial due diligence may be passed to the borrower, financed with loan proceeds, and counted toward the equity injection. Most lenders pass it through.

Will the report stand up to an SBA review or a guaranty purchase?

It is written for exactly that. Every procedure is documented, every adjustment is supported, the databook is retained, and the report is addressed to the lender with SBA reliance stated.

How do we set Credex up as an approved vendor?

One review of the standard statement of work and engagement letter with credit and legal. After that, every deal uses the same paper: send the deal terms, we countersign within one business day and issue the seller request the same day.

Set Credex up as an approved QoE vendor before October 1.

Ask for the statement of work and engagement letter. One review with credit and legal, then every deal uses the same paper.