SOP 50 10 8.1 and the Feasibility Study Consultant: What Changes on 1 October 2026

On 14 August 2026 SBA issued SOP 50 10 8.1 under Information Notice 5000-880695. It applies to any 7(a) or 504 application that receives an SBA loan number on or after 1 October 2026; applications numbered through 30 September 2026 remain under SOP 50 10 8, in force since 1 June 2025. Most of the coverage since has been written for buyers and acquisition lenders, and rightly so: the new Appendix 15 rewrites how a change of ownership is underwritten. Less has been written for the people who prepare the third-party reports that now sit between the lender and the borrower, and almost nothing for the feasibility study consultant specifically.

That gap matters, because 8.1 changes the consultant's job without changing a word of the consultant's rulebook. The permissive authority in 13 CFR 120.160(b) under which SBA "may require" a feasibility study is untouched. The SOP still names no trigger, no content list, no credential, and no independence standard for the study author. The 504 triggers, the special-purpose property list, the appraisal regime, the environmental decision tree, and the construction controls carry forward. What changed is the file the study goes into: what the lender may and may not rely on, which reports are mandatory beside it, what coverage it has to clear, and which deals still turn on a projection at all.

This is the consultant's reading of the new edition, current as of 7 September 2026. It covers the effective-date mechanics, what 8.1 changed, what it left alone, how the three third-party reports now divide the work, and what the study has to do differently on each deal type from 1 October.

The rule follows the loan number

The single most practical fact about 8.1 is its trigger. Information Notice 5000-880695 applies the new SOP to applications issued an SBA loan number on or after 1 October 2026 and directs lenders to continue using SOP 50 10 8 for applications submitted through 30 September 2026. The dividing line is the moment E-Tran assigns the number, not the application date, the letter of intent, or the day the package was delivered. For a Preferred Lender that step is within the lender's control, which makes the effective date behave like a timestamp: a file submitted on 25 September that clears E-Tran on 2 October is underwritten under 8.1.

For a consultant that means one question before any engagement in the transition window: which SOP will govern this file, and when does the lender expect the loan number? The answer determines whether the study's coverage section has to clear 1.15x with projections in the analysis or 1.25x on trailing results with the projections set aside, whether a quality of earnings report will sit beside the study, and how the equity sources the study describes will be classified. SBA has also said the application forms are still being revised; until conforming Forms 1919 and 1244 are released, lenders collect the information and certifications required by the existing forms and by 8.1 and retain them in the file. The substantive rules bind on 1 October whether or not the forms do.

What 8.1 changed

The new edition does two things. It consolidates a year of notices issued since June 2025 into the base text, and it carves acquisition lending out into its own rulebook. Seven appendices are new or newly self-contained: Appendix 14 for debt refinancing, Appendix 15 for changes of ownership, Appendix 16 for maximum guaranty amounts and percentages, Appendix 17 for loan maturity, Appendix 18 for interest rates, Appendix 19 for collateral, and Appendix 20 for submission of the application. Page references from the 2025 edition no longer hold; appendix-level references do.

Appendix 15 is the substantive change. It sorts every 7(a) change of ownership into four categories the lender must code and defend in the credit memorandum, and it governs over any conflicting provision elsewhere in the SOP.

Initial Acquisition is the default: a new majority or largest owner who was not previously an owner or employee. Equity injection is 10% of total project cost and cannot be reduced or eliminated. Coverage is 1.25x. A quality of earnings report is required where the business purchase price is $3 million or more.

Business Expansion is the lane for proven operators: an existing small business operating for at least two full fiscal years under current ownership, acquiring 100% of a target in the same four-digit NAICS industry group, with the same or a greater number of full personal guarantors. The test loosened from the prior edition's six-digit NAICS, identical ownership, and same-geography requirements. Equity is nominally 10% but may be reduced or eliminated on a documented liquidity finding. Coverage stays at 1.15x. The $3 million QoE trigger applies.

Owner Buyout is the only category in which a seller may retain equity, subject to limits; coverage is 1.25x; no QoE is required.

ESOP and cooperative conversions acquiring a controlling interest are exempt from the injection and from the QoE, at 1.25x.

Four provisions inside Appendix 15 reach the feasibility study directly.

First, coverage is measured on history. Debt service coverage is EBITDA over combined post-transaction debt service, measured on the last fiscal year-end or an average of the last two years, historical or adjusted. Lenders must still review projections, but may not rely on post-closing projections to meet the floor. Total transaction debt, including any seller note not on full standby, is capped at the appraised business value, and any excess price must be made up by equity.

Second, the quality of earnings report is mandatory at $3 million. On Initial Acquisitions and Business Expansions where the business purchase price, measured before buyer equity and seller debt and excluding the appraised value of owner-occupied real estate, is $3 million or more, the lender must obtain a QoE in addition to the business valuation. The report must be performed by an independent, experienced financial professional for the lender's benefit; a report prepared by or for the borrower or seller does not satisfy the requirement. It must reconcile accountant-prepared statements, tax returns, internal financials, and IRS transcript data into a normalized earnings figure and include a cash proof over the trailing twelve months and the last two fiscal years. The lender must use the QoE earnings figure in the coverage determination.

Third, equity sources are sorted into two buckets. Unlimited sources, chiefly the buyer's own unborrowed cash and qualifying grants, may fund the whole injection. Limited sources, standby debt, subordinated standby seller debt, and non-controlling minority equity from investors holding under 20% with no control, may in aggregate fund no more than half of it. That leaves at least 5% of total project cost in real cash on every Initial Acquisition. A standby seller note still counts, and may now be refinanced after 36 months in place and current, up from 24.

Fourth, the small-loan path closes. The use of 7(a) Small loans is not permitted for change of ownership transactions. Every acquisition, at any size, is a Standard 7(a) loan underwritten to Appendix 15.

Two further changes touch files with real estate. The 25-year maturity shortcut where real estate was at least 51% of the project is removed; maturity is a blended weighted average of the assets financed, and only the real estate portion may exceed ten years. And Appendix 14 consolidates debt refinancing, allowing qualifying same-institution debt to be processed under delegated authority for the first time, subject to the standing prohibition in 13 CFR 120.452 on using delegated authority to reduce the lender's own exposure.

The consolidation layer absorbs the notices a lender already had to read alongside SOP 50 10 8: the ownership and residency rule effective 1 March 2026 under which all direct and indirect owners must be U.S. citizens or nationals with a U.S. principal residence; the sunset of the SBSS score for 7(a) Small Loans and the 1.10x coverage floor that replaced it; the coordination of 7(a) and 504 maximum loan limits effective 4 July 2026; the Prior Loss Rule waiver for minority investors; the MARC revolving credit program for manufacturers; SOFR and Treasury alternate base rates; and the International Trade Loan expansions.

What 8.1 left alone

For a feasibility consultant the list of what did not change is the more useful one.

The feasibility study provisions. The "may require" authority, the absence of any codified trigger or content list, the five 504 circumstances in which a CDC obtains a study (market saturation, an unproven concept, a specialized or special-purpose property, a project disproportionate to the applicant's size, and rapid growth on unseasoned debt), and the absence of a preparer standard all carry forward.

Special-purpose property. The definition, the non-exhaustive list from hotels and gas stations to marinas and funeral homes, and the 504 equity overlay of 15% for special-purpose collateral and 20% for a new business in one, are unchanged.

The going-concern appraisal. Certified General appraiser, four equivalent going-concern assignments in the prior 36 months, lender-ordered, never one prepared for the borrower or seller, value allocated across land, building, equipment, and intangibles, loan amount capped at appraised value.

Environmental and construction. The NAICS screen, questionnaire, records search, and Phase I and II escalation path are unchanged. Construction disbursement controls, the completion statement, the $350,000 performance bond threshold, and the 15% 504 construction contingency set by Procedural Notice 5000-872764 on 30 September 2025 all carry into 8.1.

The Franchise Directory, the 10% start-up injection, the $5 million maximum 7(a) loan, the $3.75 million maximum guaranty, and the 85% and 75% guaranty percentages, now housed in Appendix 16.

That continuity is the point. SBA did not add a feasibility requirement. It removed the one use of projections that had been doing the most work in the program, and in doing so it moved the feasibility study from the center of the acquisition file to the edge of it, while leaving it exactly where it was on every deal that has no history to underwrite.

Three reports, three questions

Under 8.1 an acquisition file at $3 million or more can carry three third-party reports, and the market is conflating them. The distinction is the consultant's operating brief.

The business valuation answers what the business is worth. It comes from a Qualified Source holding one of five named accreditations, is requested by and prepared for the lender, and, under Appendix 15, caps the total transaction debt.

The quality of earnings report answers whether the historical earnings are real and recurring. It is lender-owned, independent of borrower and seller, mandatory at the $3 million business price, and its output is the numerator of the 1.25x test.

The feasibility study answers whether a projected business or project is viable. It has no size threshold and no mandate. It is ordered where underwriting rests on projections: start-ups, ground-up construction and major expansions, conversions, special-purpose and limited-market properties, and acquisitions where the buyer's plan departs from the seller's history.

Neither the valuation nor the QoE forecasts anything. The feasibility study is the only one of the three that tests the future, and 8.1 sharpens what that means. On a stabilized acquisition underwritten on trailing results, the study is not the coverage exhibit and should not be written as one. On an acquisition whose plan depends on doubling revenue, the study can no longer help the buyer clear the floor; it can only help the lender judge whether the plan is credible on its own terms, and whether the post-closing risk it creates is priced. On a start-up, a ground-up build, or a conversion, nothing has changed except the burden of proof around the study, which rose in June 2025 and rises again now.

What the consultant does differently from 1 October

The changes resolve into practice by deal type.

Acquisitions of stabilized businesses. The study is optional and, where ordered, subordinate. If the lender commissions one, it should be scoped to the questions the QoE and valuation do not answer: market position and competitive durability, customer and supplier concentration in forward terms, capex the trailing numbers hide, management transition risk, and the sensitivity of post-closing coverage to the buyer's operating changes. The coverage section should present the historical ratio the lender will code, reconciled to the QoE earnings figure, and treat the projection as a downside and upside case around it, not as the base case. A study that leads with a projected 1.35x on a deal the lender must underwrite at a historical 1.25x is answering a question the SOP no longer asks.

Acquisitions with a growth or conversion plan. This is where the study's value rose. Appendix 15 removes the projection from the coverage test but not from the credit decision; the lender must still review it and remains accountable for it at guaranty purchase. The study's job is to test the plan the coverage arithmetic now ignores: whether the revenue the buyer intends to add exists in the market, at what capture rate, on what ramp, with what capital, and what happens to coverage if it arrives late. Where the plan includes a change of concept or a special-purpose conversion, the 504 triggers apply on their own terms.

Business Expansions. The loosened test, four-digit NAICS and 100% of the target with guarantors held or added, brings more serial-acquirer files into a lane with 1.15x coverage and a waivable injection. The lender's liquidity finding to reduce the injection is a documented judgment, and the study's financial component is where that judgment is supported or contradicted. Integration risk, the combined entity's working capital, and the 90-day permanent working capital restriction on a 7(a) term loan are the items to address.

Start-ups and ground-up construction. Unchanged in the rulebook and unchanged in practice, with two refinements. The study's cost build-up should reconcile to the budget the lender will administer draws against, including the 15% contingency on 504 construction, and its completion-value logic should be consistent with the appraisal at completion. And gating conditions the study cannot cure should be flagged first: the ownership and residency rule, Franchise Directory status, special-purpose classification, and the loan-number date that decides which SOP applies.

Files with real estate. The blended maturity rule raises annual debt service on any acquisition that used to amortize entirely over 25 years, and that increase flows straight into the coverage test. The study's debt service schedule must use the blended term, with only the real estate portion beyond ten years, or its coverage conclusion will not match the lender's. On mixed deals, the going-concern appraisal's allocation between business and real estate now carries a diligence consequence, since it determines whether the business price crosses the $3 million QoE line; the study's cash flows should be consistent with that allocation.

Same-institution refinances. Now processable under delegated authority where Appendix 14 is met, with the lender documenting that the refinance does not reduce its own exposure. Where the refinance is paired with expansion or construction, the study's role is the improved-position case: reduced debt service on a longer amortization and the cash flow to carry the new project.

The independence standard, read across

One more change matters to the consultant even though it is written for someone else. The QoE requirement is the clearest statement SBA has yet made of the independence it expects from a third-party report: engaged by the lender, for the lender's benefit, not prepared by or for the borrower or seller, and not satisfied by a sell-side report supplied through a broker. The same architecture already governs the going-concern appraisal and the business valuation. The feasibility study is the only report in the file the SOP does not regulate this way, and a lender applying 8.1 to the other three will not accept a lower standard from the fourth.

The practical consequence is that the study should state its independence rather than assume it: no financial interest in the borrower, seller, franchisor, developer, or vendors; a fixed fee not contingent on approval; no other role on the transaction; and a signed certification the lender can carry into the credit memorandum. Under USDA that standard is codified. Under SBA it is the standard the file now implies.

Sizing the effect

The changes land on the largest and fastest-growing segment of the program. Change of ownership ran to roughly $8 billion across about 7,000 loans in fiscal year 2025, on the order of a fifth of 7(a) approval volume, against a record program year of 78,078 loans and $37.3 billion. SBA publishes no loan-purpose field and no size band at $3 million, so the share of acquisitions that will trigger a QoE is an inference; an average acquisition loan near $1.2 million implies a typical business price well under the line, which means the QoE will be a minority of files by count and a disproportionate share by dollars. The fiscal year 2026 backdrop is a smaller program, with approvals through nine months down about a third by count and a fifth by dollars against the record prior year. Whether October's rules shrink acquisition lending further or shift it toward Business Expansions and better-capitalized buyers is the number to watch in the first quarter of fiscal year 2027.

Fees reset on the same date. SBA has issued its fiscal year 2027 fee notices, Information Notice 5000-881797 for 7(a) and 5000-881796 for 504, covering loans approved from 1 October 2026 through 30 September 2027; the schedules should be pulled directly before any fiscal year 2027 file is priced. The fiscal year 2026 baseline was a 0.55% annual service fee and upfront guaranty fees of 2%, 3%, and a 3.5% and 3.75% marginal tier by loan size on the guaranteed portion.

A consultant's checklist for the first 8.1 file

1. Confirm in writing which SOP governs the file and when the lender expects the loan number.
2. Ask which Appendix 15 category the lender will code, because the coverage floor, the injection rule, and the QoE trigger follow from it.
3. On any acquisition, obtain the QoE earnings figure and the Qualified Source valuation before finalizing the financial component, and reconcile to both.
4. Present coverage on the lender's basis: historical or adjusted trailing EBITDA for acquisitions, projected for start-ups and construction, and never a projected base case on a deal the lender must underwrite on history.
5. Use the blended maturity on any file with real estate, and match the appraisal's business and real estate allocation.
6. Sort every equity source the study describes into Unlimited or Limited, and confirm the cash portion clears 5% of project cost on an Initial Acquisition.
7. Treat the projection as the plan to be tested, not the number to be cleared, and lead with the sensitivity that breaks it.
8. Flag the gating conditions first: ownership and residency, Franchise Directory, special-purpose classification, 504 triggers, and the loan-number date.
9. Reconcile the construction budget to the draw schedule and the 15% 504 contingency, and the completion value to the appraisal.
10. State independence and qualifications in the study, signed and dated, to the standard 8.1 now applies to the valuation and the QoE.