SBA SOP 50 10 8.1

    What the new acquisition rules mean for lenders.

    A practical lender summary of the changes affecting change-of-ownership transactions, valuation, Quality of Earnings, historical cash flow, and supporting documentation.

    This summary is for informational purposes only. Lenders should rely on the applicable SBA SOP, notices, and their own legal and credit guidance for transaction-specific requirements.

    01 · Appendix 15

    The change-of-ownership framework is more explicit.

    Appendix 15 provides a dedicated framework for change-of-ownership transactions, effective October 1, 2026.

    01

    Initial Acquisition

    Generally a 10% equity injection and 1.25x DSC.

    02

    Business Expansion

    Generally 1.15x DSC, with more flexibility when post-close liquidity and financial strength are documented.

    03

    Owner Buyout

    04

    ESOP / Cooperative

    Lender resources

    A quick read, and a deeper guide.

    Quick read

    SBA SOP 50 10 8.1 + Technical Update

    One-page lender brief. Explains what changed.

    Meet the QoE guidebook cover

    Field guide · What good QoE work looks like

    Meet the QoE

    A Field Guide to Quality of Earnings for SBA 7(a) Lenders

    02 · QoE

    Quality of Earnings now has a defined role.

    Independent Quality of Earnings is required for an Initial Acquisition or Business Expansion when the business purchase price is $3 million or more, excluding owner-occupied real estate.

    Why it matters

    A lender may now need both a defensible valuation conclusion and independent analysis of the historical earnings supporting the transaction.

    03 · History

    Historical performance matters.

    The credit file is expected to support a more defensible historical earnings baseline.

    01

    Historical earnings

    02

    Normalization

    03

    Cash flow support

    For businesses operating less than two years, cash proof must cover all years of operation.

    04

    Source documentation

    Collect required information and certifications and retain the evidence in the loan file.

    05

    Debt service coverage

    06

    Transaction structure

    Chief organizes this information into a source-linked acquisition analysis rather than leaving it scattered across documents.

    04 · Technical Update

    What the Technical Update clarified.

    01

    7(a) Small and SBA Express

    May be used for change-of-ownership transactions. For business purchase prices of $350,000 or less, an internal valuation is permitted.

    02

    Reusing a prior QoE

    A previously prepared QoE may be reused with a reliance letter or secondary review by a different firm, but it can't have been prepared by or for the seller.

    03

    Working-capital true-ups

    Working-capital purchase-price true-ups are expressly permitted and aren't treated as seller rebates.

    04

    Forms still being updated

    Lenders must collect the information and certifications required by SOP 50 10 8.1 even while SBA forms are updated, and retain the evidence in the loan file.

    05

    Trust guaranties

    Where trusts collectively own at least 20% of the applicant, the trust must provide an unlimited guaranty and the Trustor must personally guarantee.

    06

    Mixed-purpose loans

    If at least 51% of proceeds are for real estate, maturity may extend to 25 years.

    Source basis: SBA Information Notice 5000-882227, "Issuance of SOP 50 10 8.1 Technical Policy Updates" (Sept. 25, 2026), plus lender-industry summaries of Appendix 15. This summary is for informational purposes only. Lenders should rely on the applicable SBA SOP, notices, and their own legal and credit guidance for transaction-specific requirements.

    05 · Chief

    What Chief does with this information.

    Chief preserves the information used in the acquisition analysis so it stays available after the report is delivered.

    1. Financials

    2. QoE

    3. Valuation

    4. Transaction structure

    5. Source evidence

    6. Living Credit Record

    Working on an acquisition under the new rules?

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