SBA SOP 50 10 8.1 — a lender-commissioned QoE is now required on 7(a) acquisitions at $3M+ purchase price. What the rule requires

Independence policy

We decline the files we shouldn't take.

A lender-commissioned QoE is only worth something if the person preparing it has no stake in the deal. This is how we make sure of that, published so you can hold us to it.

The affiliation, first

Ikigai QoE is a service of MyIkigai LLC. Its founder is also a licensed washington business broker, and the QoE service operates under the Ikigai Properties name. We volunteer that rather than wait to be asked, because every rule below exists to manage it.

The decline rule

When a lender asks us to prepare the report the SOP requires, and an Ikigai-affiliated broker represents either party to the transaction, we decline the engagement outright. We do not disclose the relationship and proceed; we do not wall it off; we do not ask the lender to waive it. The engagement is refused when it is created — the portal will not open it — and the lender receives a referral instead.

Zero-consideration reciprocity

Declined files are referred to a network of peer QoE providers under a signed protocol. Nothing of value moves in either direction: no referral fee, no revenue share, no reciprocal-volume commitment, no credit against future work.

Why so strict? Because a referral fee would recreate the conflict the rule exists to prevent. If we were paid when a conflicted file went to a peer, we would have an economic interest in the transaction we just declined to touch — and the peer would have one in ours.

No contingent fees

Fees are fixed and quoted before work begins. They never depend on whether the deal closes, on the purchase price, on the loan amount, or on what the report concludes. A Quality of Earnings report whose fee depends on the answer is worthless, and on a lender-engaged file it would breach the independence the SOP requires.

Separation in practice

  • QoE mail is sent only from the QoE domain, never from a brokerage address.
  • QoE leads are kept in a dedicated store, never in the brokerage's client database.
  • A reviewer whose organization referred the transaction cannot sign the file; the portal enforces this at sign-off.
  • Lender engagements carry no remediation plan. Findings go to the lender as found.
  • Readiness reports, ordered by sellers, carry a statement that they do not satisfy the lender-commissioned requirement.

Who is behind it

Ed Sarausad — Founder; designated Qualified Individual for the information security program. Licensed Washington business broker.

The protocol

The written referral protocol, and the conflict register we check every engagement against, are available to any lender on request. Ask for them here.