The SBA now lets buyers bring their own QoE. Who's writing the scope?
Quick summary of this week's SBA technical update to SOPredactedeffective Oct 1): on SBA deals of $3M or more, a QoE the buyer commissioned can now be used, as long as it comes with a reliance letter or a secondary review by a different firm. A QoE prepared by or for the seller still doesn't count. What it doesn't say is what the QoE has to cover. Lenders are already pointing that out. So in practice, the buyer who orders it decides. My suggestion: scope the QoE around the numbers your documents disagree on. The add-back the CIM claims and the tax return doesn't show. Revenue that doesn't tie to deposits. The "one-time" expense that appears every year. That list is the work that actually needs a professional, and it also tells you whether the deal is worth a QoE at all. Questions for anyone who's been through one: - If you've ordered a QoE, who set the scope: you, the firm, or the lender? - On sub-$3M deals where it isn't required, did you still get one, and was it worth it? Alex Every AI tool is a Clerk. Verity adds the Guard and the Judge. redacted