The Small Business Administration's new Standard Operating Procedure (SOPredactedreplaces SOPredactedon October 1. For anyone buying with SBA financing, it's a bigger change than the version number suggests — and I'd rather learn from this group than keep guessing at the parts I can't pin down. Here's what I think I understand: A quality of earnings (QoE) report is now mandatory on Initial Acquisition and Business Expansion deals where the business purchase price is $3 million or more. The threshold is measured before the equity injection and before any seller note, and it excludes owner-occupied real estate. The report has to include a cash proof tying bank statements to the income statement and the tax return. The lender must use the QoE earnings figure in the debt service coverage calculation. That's the part I think people are underrating. If the analysis rejects add-backs the seller proposed, coverage falls and the supportable loan falls with it — after you're already in exclusivity. Coverage floors moved. 1.25x on Initial Acquisition and Owner Buyout, 1.15x on Business Expansion. It has to be met on historical or adjusted earnings; projections can be evaluated but can't be relied on to reach the ratio. Which SOP governs is set by the date SBA assigns the loan number, not the date you applied. A file submitted in September can land under the new rules. 7(a) Small underwriting is no longer permitted for change of ownership at any loan size. Now the part I actually can't answer, which is why I'm posting: 1. Does a buy-side QoE satisfy the requirement, or does the lender have to commission its own? The language is that the report is for the lender's benefit. If that means a fresh engagement, buyers at $3M+ could end up paying for the same analysis twice. Has anyone gotten a straight answer on whether a buyer-commissioned report can be re-addressed to the lender or relied upon? 2. What counts as a qualified independent provider? I can't find credential requirements spelled out anywhere. Are any lenders publishing approved lists, or is it case by case? 3. Is the $250,000 self-valuation tier really gone? Published summaries say the exception doesn't appear in the new appendix, which would mean an independent valuation on every change of ownership regardless of size — a second cost line with no dollar threshold at all. Nobody I've asked will confirm it either way. 4. How are lenders handling deals in flight? If you're targeting a September close and the loan number slips to October 2, the rules change underneath you. Is anyone getting written commitments on expected E-Tran timing? I put everything I could find into a working reference here: redacted — it's free, there's nothing to fill out, and I've flagged where I'm uncertain. Fair warning: it's assembled from published summaries and secondary sources, not the SOP text itself, so treat every figure as something to confirm rather than rely on. I'd rather have it corrected than have anyone lean on it. So — what are your lenders telling you? Especially interested in anyone with a deal in flight right now who has already had this conversation.