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

Trust & security

Built like it holds a business's tax returns. Because it will.

Every lender who engages us has to review us as a third party. This page answers the first questions that review asks, honestly — including what is not finished yet.

Compliance status

  • SOC 2: SOC 2 Type I in preparation — target Q1 2027. Scope: Security, Confidentiality and Processing Integrity.
  • Penetration testing: External penetration test scheduled before the first Tier 1 lender engagement.
  • Insurance: Cyber and E&O coverage being bound.

Until a SOC 2 report exists, the security package (below) carries our information security program summary, a completed questionnaire, the architecture overview, the subprocessor register and our incident response and continuity summaries.

Data classes

Everything we hold is classified, and the class decides where it may go.

Data classification
ClassExamplesHandling
RestrictedIRS transcripts, tax returns, bank statements, account and routing numbers, SSNs and EINs, aggregator tokensEncrypted per engagement on top of storage encryption. Never in logs, analytics or email. Seen by a language model only after identifiers are removed. Viewing requires a fresh sign-in check, and every view is recorded.
ConfidentialGeneral ledger, adjustment schedules, reports, deal terms, borrower identityEncrypted at rest, scoped to the engagement's tenant, logged by record ID only.
InternalDe-identified benchmarks, marketing inquiriesStaff only.
PublicThis site, the methodology, the fictional demo file—

We ask for less

A QoE is about the business. Intake asks for business returns, business bank statements, the general ledger and a business Form 4506-C. If a personal return, personal financial statement or consumer credit report is uploaded, it is flagged as not required, excluded from processing, and offered for deletion.

Encryption and disposal

  • TLS 1.2 or later on every connection, with HSTS on every QoE host.
  • Documents stored in AWS S3 with KMS encryption, public access blocked, versioning on.
  • Restricted fields encrypted with a data key unique to each engagement. Disposal destroys that key, which makes the engagement's restricted data unrecoverable everywhere it was copied — including backups.
  • Issued reports held in write-once storage.

Sign-in and access

  • Multi-factor sign-in is mandatory for every account. Staff sign in with passkeys. Lenders can use their own single sign-on.
  • Viewing restricted excerpts, downloading a report and every administrative action require a sign-in no older than five minutes.
  • Borrowers on a lender engagement can upload documents and see their checklist and status — nothing else. They cannot see findings or the report.
  • No standing production database access. Emergency access requires a written reason, alerts immediately and expires in an hour.

Tenant isolation

Each lender is a separate tenant, and isolation is enforced by the database itself — row-level security — not only by application code. A test that one tenant cannot read another's rows runs on every change.

No third-party scripts in the portal

The portal, where tax data is displayed, loads no analytics, pixels, tag managers, chat widgets or session replay. Its content security policy forbids scripts from any other origin; the bank-connection widget is the single exception, and only on the one page that uses it. This public site uses cookieless analytics at most, and never on the demo.

Uploaded documents

Every upload is treated as hostile until scanned: file-type verification, malware scanning, removal of scripts and embedded content from PDFs, detection of hidden text, and checks for signs of editing. The IRS transcript is the cross-check a seller cannot alter.

Logging and monitoring

Application logs are redacted at the logger. Security-relevant events — sign-ins, every view of restricted data, downloads, role changes, engagement declines, report issuance — go to a tamper-evident, append-only event log kept for seven years.

Report verification

Every issued report is digitally signed, watermarked with its recipient, and carries a verification ID and code. Anyone holding a copy can check it at /verify, which returns only whether it is genuine, when and to whom it was issued, and whether it is current, superseded or revoked.

Incident notification

Lender clients are notified within 24 hours of our determining that an incident affects their data or disrupts service.

Subprocessors

Updated 2026-10-11. Lender administrators are notified when this list changes.

Subprocessor register
VendorPurposeDataSecurity reports
RailwayAll compute (marketing, portal, API, worker, scanner, engine), Postgres, Redis, TLS terminationBusiness-confidential data; restricted data only as ciphertext at rest and in transit to the servicesSOC 2 Type II and SOC 3; DPA available(source: Railway Trust Center)
Amazon Web ServicesDocument storage (S3), key management (KMS), backupsBusiness-confidential and restricted data, encryptedConfirmConfirming
CloudflareTurnstile bot check on public forms; optional cookieless web analytics on the marketing site onlyForm-submission metadata; no financial dataConfirmConfirming
Identity provider (WorkOS or equivalent)Single sign-on, multi-factor authentication, passkeysUser identityConfirmConfirming
AnthropicClassification and drafting of prose — never figuresRedacted business-confidential dataConfirm terms; zero data retention requestedConfirming
PlaidBank connectivityBank data (restricted)ConfirmConfirming
IntuitQuickBooks Online APIGeneral ledger (business-confidential)ConfirmConfirming
IVES participant vendor (to be selected)Form 4506-C transcript retrievalIRS transcripts (restricted)SOC 2 and IVES participant status requiredConfirming
Postmark or AWS SESTransactional emailContact data onlyConfirmConfirming
E-signature vendorEngagement letters and reviewer sign-offNames and signaturesConfirmConfirming
StripeInvoicingBilling contacts; card data stays with StripeConfirmConfirming
SentryError tracking with server-side scrubbingScrubbed telemetryConfirmConfirming
Log platformApplication logsRedacted logsConfirmConfirming
Compliance automation platformEvidence collectionConfiguration metadataConfirmConfirming

Responsible disclosure

If you believe you have found a security vulnerability in any Ikigai QoE system, email security@qoe.ikigai.properties. Our contact details are also published at /.well-known/security.txt.

  • Give us reasonable time to fix the issue before disclosing it publicly. We acknowledge reports within two business days.
  • Test only against your own accounts. Do not access, change or delete data that is not yours, and stop and tell us if you encounter any.
  • No denial-of-service testing, social engineering, or physical attacks.
  • We will not pursue legal action against research done in good faith under this policy.

Our remediation targets: critical within 7 days, high within 30, medium within 90.

Request our security package

For lenders conducting vendor due diligence. We review each request by hand and send the package to verified lender contacts.

Please don't send financial documents through this form.