Quality of Earnings for SBA Lenders
SBA Quality of Earnings Reports.
Built for the Credit File.
The Exceptional Plan prepares lender-ordered SBA quality of earnings reports under SOP 50 10 8.1. Every report follows a fixed 17-section template, includes the required cash proof, and is signed by a licensed Certified Public Accountant who holds the ABV credential.
We built this practice specifically for lender-ordered work. Fees are billed hourly against a written not-to-exceed quote, the delivery date sits in the engagement letter, and our financial analysis team has worked hundreds of SBA transactions, so we know which numbers tend to hold up.
17
Report Sections
10 Days
Focused Delivery
48 Hrs
Written Quote
100%
CPA-Signed Reports
Lender-ordered only
Billed hourly, capped in writing
Signed by a CPA, ABV
Independence
SBA Quality of Earnings
With Written Conflict Rules.
SOP 50 10 8.1 states that the report may not be prepared by or for the borrower or seller. Our conflict rules go further than the SOP requires, and they apply the same way on every file.
A Distinct Practice
Built for Lender-Ordered Work
Our Quality of Earnings practice runs on its own template, review process, and conflict rules, designed around what a credit file needs.
No Plan, No Report
We Decline Conflicted Files
We decline any lender-ordered engagement on a transaction where we prepared the business plan, the projections, or the loan package for the applicant.
One Role Per File
No Valuation, Packaging, or Referral
We do not perform a valuation, act as a packager, or act as a referral agent on any file where we prepare the report.
CPA Signature
Signed, or Sent Back
A licensed CPA reads the workpapers, traces every adjustment in the bridge to the document behind it, and either signs the report or sends it back.
Our borrower-side work, including acquisition business plans and SBA business plans, runs on separate files from our Quality of Earnings practice and never crosses into a file where we prepare the report.
Buying a business? See how to prepare for your lender's QoE →
The Report
Inside Every SBA Quality of Earnings Report.
Every report runs the same 17 sections in the same order, and each one closes a specific credit question. Where the data room cannot support a section, the report says so and quantifies what the gap costs the file.
#
Section
The Credit Question It Closes
01
Executive Summary
Does the deal cover, and what would break it
02
Scope and Limitations
Who ordered this, what was reviewed, and what was withheld
03
Industry Context
Is this business normal for its industry, or an outlier
04
Management Q&A Summary
What did the seller represent, and does the data agree
05
Adjusted EBITDA Bridge
How does reported become adjusted, adjustment by adjustment
06
Cash Proof
Did the reported revenue actually arrive in the bank
07
Revenue and Client Analysis
Where does revenue come from, and how concentrated is it
08
Contract Continuity
Is the revenue contracted, or goodwill with a 30-day life
09
Cost Structure and Headcount
Is the cost base stable, and is it rising into the transition
10
Capital Expenditure Analysis
What must the buyer spend that EBITDA does not show
11
Working Capital Analysis
Will the business have operating cash the day after close
12
Debt and Debt-Like Items
What obligations never reached the balance sheet
13
Related-Party and Tax Exposures
What follows the entity, and what stays behind
14
DSCR Calculation
At what debt level does this deal stop covering
15
Pro Forma Earnings
Can this buyer make the payment in month 1
16
Supportable Price Framework
What price do these earnings actually support
17
Findings Table
What is the dollar impact of every risk in the file
The Sections Most Providers Leave Out.
A report that stops at the EBITDA bridge is the market norm at the boutique price point. These 4 sections are where a bridge becomes a report a credit file can use.
01
Cash Proof
Ties reported revenue to deposits that actually landed in the operating account. SOP 50 10 8.1 now requires it, and it is the section most often missing from a buy-side memo.
02
Capital Expenditure Analysis
Separates maintenance capital expenditure from growth, so coverage is tested against the cash the buyer keeps rather than EBITDA as reported.
03
Working Capital Analysis
Sets the peg the business needs to operate, which is the difference between a borrower who funds day 1 and one drawing on a line in week 2.
04
Debt and Debt-Like Items
Surfaces deferred compensation, accrued time off, earnouts, and tax obligations that never reached the balance sheet but follow the entity through closing.
Reports are built by the same accounting team that runs our monthly close for more than 20 client entities and supports our outsourced CFO clients, so the reconstruction work on an SBA quality of earnings file is work they do every month against a deadline.
Fees and Billing
SBA Quality of Earnings, Billed Hourly.
We do not price by loan amount. A fee set as a percentage of the deal charges the bank more for identical work and produces a number nobody can benchmark. Deal size predicts how many hours an SBA quality of earnings file takes, and that is the only part it decides.
The Rate
One Hourly Rate, Every Role
The analyst who rebuilds the ledger and the Certified Public Accountant who signs the report bill at the same rate.
No partner rate
No administrative surcharge
No charge for scoping or post-delivery questions
The Quote
A Written Not-to-Exceed Quote
Scoping call Day 0
Written quote 24 to 48 Hrs
Delivery date In Writing
We read what you already have, usually the purchase agreement, the financial statements, and the tax returns, and mark what is present and what is missing. Those gaps drive the hours on the file.
Not-to-exceed figure and delivery date
Under the estimate, you pay hours worked
Any overrun raised before the work starts
The Invoice
Time You Can Audit
Time is recorded in 0.25-hour increments, and a timesheet accompanies every invoice, so your team can benchmark the fee against the work.
0.25-hour increments
Timesheet with every invoice
Fee benchmarked on hours worked
What Adds Hours to a File.
These are identified on the scoping call and built into the quote, rather than discovered halfway through and billed as an overrun.
#
Complexity Factor
Why It Adds Hours
01
Multi-entity structure
Each entity needs a separate bridge and intercompany eliminations.
02
Cash-basis or disorganized books
The ledger has to be reconstructed before analysis can begin.
03
Related-party real estate
Market rent analysis, lease review, and normalization.
04
History beyond 3 years
Additional periods to rebuild and tie out.
05
3 or more revenue streams
Each stream needs separate trending and verification.
06
Multi-location operations
Location-level results and unit economics.
We would rather be benchmarked on the hours than on the loan, because that is the only basis on which a lender can tell whether the fee is fair. Book a scoping call below, or start with a free consultation to walk through your next file.
How It Works
How an SBA Quality of Earnings
Engagement Runs.
The sequence is the same on every SBA quality of earnings file, which is what lets us hold the fee and the date. A named analyst owns the file from intake through delivery.
1
Day 0 to 1
Scoping and Quote
We walk through the structure of the business and the condition of the records with you, then return a not-to-exceed figure and a delivery date in writing.
2
Day 1 to 3
Document List
The fixed request list goes to your team for review against your closing checklist before any borrower sees it. The clock starts when we confirm the list is complete.
3
Day 3 to 8
Build and Reconstruction
Ledger rebuild, the monthly model, the bridge, the cash proof, and every supporting schedule, with each adjustment tied to a named source document.
4
Day 8 to 10
Review and Signature
A second preparer who did not build the file tests it, then the reviewing Certified Public Accountant signs the report or sends it back.
Day counts shown are for a Focused engagement. A Full scope file runs the same sequence across 15 business days, and no file exceeds 3 weeks. The clock starts on our written confirmation that the document list is complete, and if we miss the date, a 10% credit is applied to the invoice automatically.
The Leadership Team
The Team Behind Every SBA Quality of Earnings Report.
A named analyst from our accounting team builds each file, the principal reads it, and the Certified Public Accountant either signs it or sends it back to be corrected. A report is worth roughly what the person willing to put a name on it is worth.

Kaylee Philbrick-Theuerkauf
Chief Executive Officer and Founder
The Exceptional Plan
Principal · Final Read Before Issue
Kaylee founded The Exceptional Plan in 2021 and has built it into a full-lifecycle consulting practice serving more than 1,000 clients across 65+ countries, with over $2.2 billion in client funding facilitated and a 100% SBA approval rate.
She reads every Quality of Earnings report before it is issued and leads the firm's strategic advisory work.

Seth Kimble
Director of Accounting
FMVA, FPAP, CBCA
Technical Build · First Review
Seth has led the accounting practice since 2021 and owns the technical build on Quality of Earnings files. He runs the monthly close for more than 20 client entities and works daily in revenue recognition under ASC 606, inventory under ASC 330, and cash flow forecasting.
He came to the firm from public accounting, served as interim CFO for a wholesale distributor, and holds a degree in Financial Management from Clemson University.

Cathy Mitchell
Reviewing Certified Public Accountant
CPA, ABV
Signs It, or Sends It Back
Cathy reviews and signs the firm's Quality of Earnings reports and has held a CPA license since 1987. She most recently served as Senior Vice President of Business Valuation Services at Allen, Gibbs and Houlik in Wichita, and began her career as a tax manager at KPMG.
She earned a BBA in Accounting from the University of Kansas and received the Elijah Watt Sells Award, given to the highest scorers on the uniform CPA examination nationally.
$2.2B+
Client funding facilitated since 2021
1,000+
Clients served across 65+ countries
100%
SBA approval rate on files we prepare
20+
Client entities closed monthly by our accounting practice
Accredited in Business Valuation is one of the qualified source credentials SBA recognizes for change-of-ownership valuation work, so the person testing our adjustments holds the same credential SBA looks for in the valuation sitting beside the report in the credit file.
Beyond the Report
Working Together
Beyond the Report.
The report is the engagement. These are the other ways we work with lenders, and none of them depend on it.
Referrals
Borrowers We Send to Lenders
Many of our clients need financing first. We introduce them to lenders whose credit appetite fits the deal, arriving with a plan, projections, and documents built to the standard underwriting expects, kept entirely apart from any QoE work.
Not Yet, Instead of No
Files That Are Not Bankable Yet
Good businesses with unready records usually end in a decline. We can take that borrower, clean up the books, rebuild the projections, and bring the file back in a condition that can be underwritten.
After Closing
After the Loan Funds
When a borrower stays with us after closing, your file keeps receiving clean, timely financials through our fractional CFO work instead of going quiet until something goes wrong.
None of this is a condition of an engagement, and none of it is priced into the fee. On any file where we work for the borrower, we do not prepare the SBA quality of earnings report.
FAQ
SBA Quality of Earnings Questions From Lenders.
Common lender questions on the SOP 50 10 8.1 requirement, our conflict rules, billing, and turnaround.
Under SOP 50 10 8.1, which applies to loans assigned an SBA loan number on or after October 1, 2026, lenders must obtain a quality of earnings report for Initial Acquisition and Business Expansion transactions with a business purchase price of $3 million or more. Owner-occupied real estate is excluded from that price, and Owner Buyout and ESOP transactions are exempt.
Every change of ownership also needs an independent business valuation ordered by the lender, with no dollar threshold. Borrowers can see what to expect on our quality of earnings report page.
The report must include a cash proof reconciling bank statement data to the income statement and tax return for the trailing 12 months and the last 2 fiscal years. It should also document add-backs and assess customer concentration and contract continuity.
Our SBA quality of earnings reports run 17 sections, from the adjusted EBITDA bridge and cash proof through the DSCR calculation, closing on a findings table that puts a dollar figure on every risk.
The SOP requires an independent, experienced financial professional who performs the work for the benefit of the lender. A report prepared by or for the borrower or seller does not qualify, and a sell-side report commissioned by a broker will not satisfy the rule.
Every report is reviewed and signed by Cathy Mitchell, CPA, ABV, who has held a CPA license since 1987. She reads the workpapers, traces every adjustment in the bridge to its source document, and either signs the report or sends it back.
Seth Kimble, our Director of Accounting, owns the technical build and first review, and Kaylee Philbrick-Theuerkauf reads every report before it is issued.
We accept lender-ordered engagements only. We decline any engagement on a transaction where we prepared the business plan, the projections, or the loan package for the applicant, and we do not perform a valuation, act as a packager, or act as a referral agent on any file where we prepare the report.
Our borrower-side services, such as acquisition business plans and M&A preparation, stay on separate files.
Hourly, at the same rate for every role on the file, from the analyst who rebuilds the ledger to the CPA who signs. We do not price by loan amount, because deal size only predicts how many hours a file takes.
Within 24 to 48 hours of the scoping call, you receive a written not-to-exceed figure and a delivery date. Time is recorded in 0.25-hour increments with a timesheet on every invoice. Schedule a scoping call to get a quote on your next file.
A Focused engagement is delivered in 10 business days and a Full scope engagement in 15, measured from a complete document list. No file exceeds 3 weeks.
The clock starts on our written confirmation that the list is complete, which comes within 1 business day of the final upload. If we miss the date, a 10% credit is applied to the invoice automatically.
The fixed list covers annual and monthly financial statements for 3 fiscal years plus the current stub period, the general ledger, bank statements and reconciliations, merchant processor reports, federal and state tax returns, payroll registers, a client schedule, client contracts, receivable aging, deferred revenue, loan and lease documents, related-party agreements, and the purchase agreement or term sheet.
We send that list to your team for review against your own closing checklist before any borrower sees it. Borrowers with an organized data room clear this step fastest.
Yes. We coordinate timelines and document requests with your valuation firm so the borrower is not asked for the same files twice. We never perform the valuation on a file where we prepare the report.
Yes. Many lenders order an SBA quality of earnings report on smaller deals when add-backs are large, the business is cash-heavy, or the records are thin. The same 17 sections, conflict rules, and CPA signature apply at every deal size.
Scoping Call
Scope Your Next SBA Quality of Earnings File.
Tell us about the file, the purchase price, and your closing date. We will walk through the 17-section report and our conflict rules, then return a written not-to-exceed quote and delivery date within 48 hours.
$2.2B Facilitated Funding
1,000+ Clients Served
100% SBA Approval Rate
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Prefer to talk now? Call 316-218-9898
Request a Scoping Call
Line Up Your QoE Provider.
Before the Next $3M Deal.
The new rule took effect October 1, 2026. Add an SBA quality of earnings provider with a fixed 17-section template, a CPA signature, and a delivery date in writing before your next Initial Acquisition file stalls. Book a scoping call, or start with a free consultation.
10 to 15
Business Days•From a Complete Document List
Prefer to talk now? Call 316-218-9898
Lender-Ordered Only
Signed by a CPA, ABV
10% Credit if We Miss the Date