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For SBA lenders and credit teams

Quality of earnings your credit memo can use

Prepared and signed by Sergei Mochtchenkov, a CFA charterholder.

I prepare independent, buyer-side quality of earnings reports for SBA 7(a) acquisitions. Scope, Cash Proof and reliance terms are agreed with you before fieldwork, so the report fits your file rather than being reworked after it lands.

Engaged by
The buyer, never the seller
Fee
Fixed, from $6,000 buy-side
Timeline
2–3 weeks after NDA and complete data
Proposal
Fixed scope within 24 hours

Scope

What the report covers

Cash Proof

Bank deposits and disbursements reconciled to reported revenue, earnings and filed tax returns, period by period, with unreconciled differences listed.

EBITDA bridge

Reported to adjusted EBITDA, each add-back marked supported, unsupported or open, with the evidence referenced.

Revenue quality

Customer concentration, recurring versus one-off revenue, churn and pricing changes across the review period.

Working capital

Normalized net working capital, seasonality and items that should affect the peg or closing adjustments.

Debt-like items

Deferred revenue, accrued liabilities, related-party balances and deferred maintenance flagged for structuring.

Open issues

A short list of findings that change price, DSCR or conditions, written for the credit memo rather than for the buyer alone.

Process

Built around your file, not after it

  1. 01

    Lender call

    Before fieldwork, I confirm your provider, scope, Cash Proof format and reliance or secondary-review requirements.

  2. 02

    Engagement

    The buyer engages me. The letter names you as a permitted user, sets the reliance terms and fixes fee and dates.

  3. 03

    Fieldwork

    Ledger, bank and tax-return reconciliation, add-back testing and management questions. You get early notice of material issues.

  4. 04

    Signed report

    Signed findings memo with schedules, delivered to the buyer and to you, followed by a call with your underwriter if wanted.

Independence

Engaged by the buyer. Paid the same either way.

  • No equity, success fee or contingency in any deal I review.
  • No engagement by, or work for, the seller on the same transaction.
  • Fee fixed before fieldwork; it does not move with the findings.
  • Conflicts confirmed in writing in the engagement letter.

I am not a CPA firm and the report is not an attest engagement. I am asking lenders to review my scope and a sample before adding me to any provider list; nothing here implies existing lender approval.

SBA acquisition financing

A $3 million acquisition? Plan for quality of earnings.

Effective October 1, 2026, SBA 7(a) initial acquisitions and business expansions with a business purchase price of $3,000,000 or more require a quality of earnings report in addition to a business valuation. The updated SOP applies to applications received by SBA on or after that date.

The threshold is the business purchase price—not the loan amount—and is measured before buyer equity or seller financing. The appraised value of owner-occupied commercial real estate is excluded. Owner buyouts, ESOP and cooperative transactions are outside this specific QoE requirement; lenders may still request diligence below the threshold or for excluded transactions.

Agree the engagement with your lender before commissioning the report. SBA requires an independent financial professional and a Cash Proof reconciling bank activity to earnings and tax records. Provider approval, scope and reliance arrangements must meet the lender’s requirements. A seller-prepared report does not satisfy this requirement; a CFA charter or a signature alone does not establish lender acceptance.

FAQ

Questions from credit teams

Two ways to start

Get a quote, or start with the checklist.

If you know what you need, request a quote — a fixed-scope proposal follows within 24 hours. If you are still deciding, take the checklist investors effectively run your model against and see where it stands.

One email with the checklist. No sequence, no sharing your address.

Get a quote

Send the brief — what exists, what it needs to do, and who has to be convinced. A fixed-scope proposal with the exact fee follows within 24 hours.

or write directly
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